Under the Sept. 13 highway diesel fuel waiver, must high-sulfur diesel fuel be dyed?
Absent a waiver, EPA regulations require that high-sulfur diesel fuel must be dyed red, otherwise it is subject to the 500 ppm sulfur standard for highway diesel fuel. The red dye allows high-sulfur diesel fuel to be more easily identified by regulated parties and fuel users. However, the Sept. 13 diesel fuel waiver includes a waiver of the dye requirement for high- sulfur diesel fuel so that high- and low-sulfur diesel fuel may be more easily distributed as highway fuel. Through Oct. 5, refiners may introduce into the distribution system, such as into pipelines, undyed high-sulfur diesel fuel, but may not do so after Oct. 5. Any undyed high-sulfur diesel that enters the distribution system through Oct. 5 may remain in the distribution system and may be distributed to retail outlets as highway fuel until Nov. 20. However, beginning no later than Nov. 20, undyed diesel fuel in the distribution system and in the possession of parties upstream of the retail level, including terminals, mus
