Fuel Quality Standards (Petrol) Determination 2024

The instrument is framed around three core concepts: parameterised specifications, mandated testing methods, and supplier-level averaging for one parameter.

Parameterised specifications: The petrol table in s 5 lists discrete parameters (Column 1) and attaches to each a numerical specification or range (Column 2). These include concentration limits (for benzene, MTBE, ETBE, DIPE, TBA, lead, phosphorus), content maxima or minima (aromatics, olefins, existent gum, oxidation stability, distillation end point), octane minima differentiated by grade (RON and MON minima for 91 and 95 RON grades), and distinct treatment of oxygen content depending on whether petrol contains ethanol (s 5 table items 1-18). The ethanol table in s 6 operates the same way for ethanol-specific parameters (acidity, purity, denaturant concentration and nature, water, methanol, chloride, copper, sulphate, pHe, solvent-washed gum and sulfur) (s 6(1)-(3)).

Mandated testing methods: For every parameter the determination prescribes a testing method (Column 3), mostly ASTM standards (for example ASTM D1319 for aromatics, ASTM D4815 for ethanol and certain ethers, ASTM D5453 for sulfur), and in one instance an EN standard modified as noted (EN 15837 as modified in CEN/TS 15293 for copper in ethanol) (s 5(2); s 6(2)). Compliance is determined by using the listed method for that parameter. The specification-method linkage makes compliance both a substantive and procedural requirement.

Pool average and supplier measurement: The instrument defines “pool average for aromatic content” as the average across all batches of petrol across all grades manufactured in Australia, or imported, by a supplier in each 12 months starting on 1 January (s 4). The aromatics parameter in s 5 has both a per-grade maximum and a pool-average maximum, with the pool-average maximum set at 35% v/v after 14 December 2025 (s 5 table, item 1). This creates a supplier-level averaging obligation and an annual measurement window tied to the calendar year.

Transitional specification timing: Some parameters change at a fixed future date. Aromatics have one regime from commencement until 14 December 2025 and a changed regime after that date; sulfur limits are looser during the transitional period and tighten to 10 mg/kg for all grades after 14 December 2025 (s 5 table items 1 and 17). Other parameters are fixed from commencement.

Interdependence of standards: The determination contains cross-references that make compliance interdependent. For example, s 5(4) requires that any ethanol component of petrol comply with the ethanol standards in s 6, and s 6(3) requires that the denaturant component of ethanol be petrol. Oxygen content limits vary depending on the presence of ethanol (s 5 table item 14). The rule prohibiting compounds containing phosphorus being added to petrol (s 5(5)) sits alongside a numeric phosphorus limit in the petrol table (item 15).

Scope and exclusions: The definition of petrol excludes aviation gasoline (avgas) supplied for aircraft (s 4), so the standards apply to fuels meeting the instrument’s definition of petrol only. The authority for making the instrument is limited to the statute cited (s 3), which situates the determination as a delegated standard under the Fuel Quality Standards Act 2000.

Primary regulated actors: The determination directly imposes obligations on suppliers of petrol. The definition of “pool average” explicitly operates at the supplier level, requiring aggregation of all batches manufactured in Australia or imported by a supplier over each 12‑month period starting 1 January (s 4; s 5 table item 1). The testing-method prescriptions (s 5(2), s 6(2)) indicate that parties supplying petrol must ensure products are tested in accordance with those standards to determine compliance. A supplier who manufactures petrol domestically or imports petrol is within the operational scope of the instrument because the pool-average concept and the tables refer to manufacture in Australia or importation (s 4 definition).

Blenders and ethanol producers: The determination affects entities that blend ethanol into petrol and producers or importers of ethanol destined for petrol. Section 5(4) makes any ethanol component of petrol subject to the ethanol standards in s 6. Section 6(3) further requires that the denaturant component of ethanol be petrol, and s 6(4) mandates a 1-1.5% v/v denaturant concentration in ethanol, so ethanol suppliers and blenders must ensure the denaturant is petrol and that its concentration is within the specified range (s 6 table items 4 and 3(3)). The ethanol table also sets a 95.6% v/v minimum ethanol purity and limits for methanol, water, and chloride, which will affect ethanol processing and quality control (s 6 table items 5, 7, 12, 6).

Importers and distributors: Importers must ensure imported fuel meets the testing-method requirements and the numeric specifications outlined in the instrument. The pool-average definition explicitly includes imported petrol (s 4). Distributors who handle multiple grades will need to ensure grade-specific requirements are met and that batch testing supports supplier-level compliance claims.

Testing laboratories and standards bodies: The prescriptive use of named ASTM methods and an EN standard imposes capacity demands on accredited testing laboratories that are used by suppliers. Compliance requires testing infrastructure or contracted laboratory services that can produce results using the specified methods (s 5(2); s 6(2)).

Equipment manufacturers, additive suppliers and refiners: Refiners and blenders who source blending components and additives must ensure those inputs will enable compliance with the numeric limits (for example, aromatics limits, sulfur, olefins, oxygenate contents). The prohibition on adding compounds containing phosphorus (s 5(5)) directly affects additive suppliers who might otherwise provide phosphorus-containing agents. Additive and blending decisions will be influenced by the sulfur and aromatic specifications, which may alter demand for certain feedstocks or additives.

Regulatory authority and enforcement bodies: The Minister made the instrument under statutory authority (s 3). The instrument itself does not set enforcement mechanisms but will be enforced under the statutory regime set out in the Fuel Quality Standards Act 2000; therefore, regulators operating under that Act are actors who will enforce compliance once the determination is in force (s 3).

Excluded actors: Aviation operators using avgas are outside the instrument’s scope because petrol is defined not to include aviation gasoline supplied for use in aircraft (s 4).

Duties

Ensure conformity to numeric specifications: Suppliers must ensure that petrol conforms to the parameter specifications in the petrol table (s 5(1), (3)). Each parameter has a specific maximum, minimum or range (e.g., benzene 1.0% v/v maximum, existent gum 5 mg/100 mL maximum, MON and RON minima for specified grades) and some parameters are grade-specific (s 5 table items 2, 8, 12, 16, etc.).

Use prescribed testing methods to determine compliance: Compliance with each parameter is to be determined by the testing method specified in Column 3 of each table item (s 5(2), s 6(2)). That creates a procedural duty to test using the exact method cited (for example ASTM D1319 for aromatics, ASTM D4815 for ethanol and certain ethers, ASTM D5453 for sulfur).

Observe pool-average obligations for aromatics: Suppliers must measure the average aromatics content across all batches of petrol across all grades they manufacture or import in each 12‑month period starting on 1 January, and keep that average within the pool-average limit where applicable (s 4 definition; s 5 table item 1). The pool-average requirement becomes explicitly constrained at 35% v/v after 14 December 2025, with a per-grade maximum of 35% v/v pool average and per-grade maxima of 35% or 45% v/v depending on grade and timing (s 5 table item 1).

Ensure ethanol components comply with ethanol standards: Any ethanol component blended into petrol must comply with the ethanol standards at s 6 (s 5(4)). The ethanol table prescribes a 95.6% v/v minimum ethanol purity, limits on methanol and water, pHe range, denaturant concentration and the requirement that the denaturant be petrol (s 6 table items 3-5, 7, 12; s 6(3)).

Prohibit addition of phosphorus-containing compounds: The instrument explicitly forbids adding compounds containing phosphorus to petrol (s 5(5)), in addition to setting a phosphorus concentration maximum for petrol (1.3 mg/L in the petrol table item 15).

Observe transitional regimes and grade-specific minima: Suppliers must apply the transitional sulfur and aromatics limits that are time-bound in the petrol table (s 5 table items 1 and 17). Octane number minima are tied to grade labels (91 RON grade and 95 RON grade) with specified RON and MON minima (s 5 table items 12 and 16).

Rights

Certainty of prescribed method: Regulated parties gain legal certainty on which testing standard determines compliance for each parameter because the instrument prescribes the method (s 5(2); s 6(2)). That reduces (but does not eliminate) disputes about which analytical standard should be used for compliance testing.

Use of pool averaging: Suppliers have the allowance of a pool-average metric for aromatics rather than only a point-in-time batch limit. That can permit flexibility across batches provided the annual supplier-average meets the specified limit (s 4; s 5 table item 1).

Grade labelling and octane differentiation: The specification recognises distinct grade bands (91 RON grade, 95 RON grade, and other grades) and assigns different octane and sulfur expectations to those grades during the transitional period and beyond (s 5 table items 12, 16, 17). Suppliers can market grade-differentiated products subject to meeting those minima.

Procedural expectation: Because compliance is to be determined by the listed tests, suppliers can rely on results produced in accordance with those tests as the authoritative measure of compliance, subject to any enforcement or verification regime under the Act (s 5(2); s 6(2)).

Interdependencies that create duties: Because the ethanol denaturant must be petrol and ethanol used in petrol must conform to the s 6 table, suppliers who rely on ethanol blends must ensure upstream ethanol producers and denaturant arrangements meet those requirements (s 6(3); s 5(4)).

The determination itself contains no penalty clauses and does not set out enforcement mechanisms. The instrument records that it is made under section 21 of the Fuel Quality Standards Act 2000 (s 3). Accordingly, civil or criminal penalties, compliance notices, inspection powers, seizure powers, administrative sanctions and the procedures for enforcement are not contained in this determination; they will be those established by the Fuel Quality Standards Act 2000 and any regulations, compliance instruments or administrative procedures made under that Act.

What the instrument does establish relevant to enforcement:

• Objective compliance metrics and prescribed tests: By specifying numeric limits and the exact method for determining compliance for each parameter, the determination creates clear, verifiable compliance criteria for enforcement authorities to apply (s 5(1)-(2); s 6(1)-(2)). Enforcement will therefore hinge on laboratory analyses using the listed standards.

• Supplier-level averaging and record implications: The pool-average definition requires suppliers to aggregate results across batches on an annual basis (s 4). Enforcement bodies will need to examine supplier records that support pool-average calculations and the underlying batch test results.

• Temporal transition points: Some limits change after 14 December 2025 (s 5 table items 1 and 17). Enforcement authorities will need to apply the correct regime depending on the date of supply or testing.

Because the instrument does not itself spell out legal consequences, regulated parties will need to consult the Fuel Quality Standards Act 2000 for the specific enforcement tools and penalties that apply if they fail to meet the determination’s requirements. The instrument’s explicit reliance on statutory authority (s 3) indicates enforcement is statutorily grounded, but the exact sanctions and processes are not in this text.

Statutory framework: The determination is an instrument made under the Fuel Quality Standards Act 2000 (s 3). It therefore sits within the legal architecture established by that Act. The determination is a delegated legislative instrument that operationalises technical standards; any interaction with broader regulatory regimes (for example, statutory enforcement powers, appeals processes, record-retention obligations, or public reporting duties) will be governed by the Fuel Quality Standards Act 2000 and subordinate instruments made under it. The determination itself does not modify other Acts nor does it prescribe administrative enforcement mechanisms; it supplies technical content to be used by the Act’s enforcement regime.

Standards and external technical rules: The determination expressly incorporates external technical standards as the determinative testing methods (s 5(2); s 6(2)). These include ASTM standards identified by code (for instance ASTM D1319, ASTM D4815, ASTM D5453) and an EN standard modified in a particular way (EN 15837 as modified in CEN/TS 15293 for copper in ethanol). Therefore compliance requires the capability to undertake or contract tests that follow those standards. The legal effect of referencing a named standard is that conformity or non-conformity is measured against that standard’s prescribed method, not against alternative laboratory practices unless expressly permitted elsewhere in the Act or in the standard-setting regime.

Product labelling and trade rules: The instrument differentiates between petrol grades (for example 91 RON grade and 95 RON grade) and imposes grade-specific octane minima and transitional sulfur limits (s 5 table items 12, 16, 17). That may interact with product-labelling obligations under other statutory regimes or consumer law (not specified here), because grade labelling implies a minimum octane performance. Any conflict between labels used in commerce and the technical grade definitions in this instrument would likely be resolved under the Fuel Quality Standards Act 2000 or consumer/product law frameworks external to this instrument.

Trade and import compliance: The pool-average definition explicitly includes petrol imported by a supplier (s 4). Importers must therefore ensure consistency between imported product specifications and the instrument’s numeric limits and testing requirements. Where international suppliers rely on different testing standards or regulatory regimes, they must adjust testing or provide evidence that overseas testing is equivalent to the specified ASTM or EN method, subject to acceptance by the enforcement authority under the Act (the determination itself does not provide equivalence rules).

Cross-parameter dependencies and upstream regulation: The obligation that any ethanol component of petrol comply with s 6 (s 5(4)) and that the ethanol denaturant must be petrol (s 6(3)) creates an internal interaction between the petrol and ethanol standards. These cross-references may also interact with any legal requirements governing ethanol production, denaturant supply chains, or alcohol regulations outside the Act; such interactions are not specified here but will exist operationally.

No overriding of other laws stated: The instrument does not state that it overrides or displaces other Commonwealth or state laws. It sits as a delegated instrument under the Fuel Quality Standards Act 2000 and is intended to operate within that statutory framework.

This instrument is presented as the Fuel Quality Standards (Petrol) Determination 2024 and is dated 12 April 2024. It contains its own commencement table (s 2) indicating that the whole instrument commences the day after registration (s 2(1)). The commencement table includes a note that the table relates only to the provisions as originally made and will not be amended in the instrument itself to reflect later amendments (s 2 second paragraph). The table also contains a Column 3 intended for non-operative information; the instrument states any information in column 3 is not part of the instrument and may be edited in published versions (s 2(2)).

Transitional or staged specifications are embedded in the operative tables rather than introduced through amendment history. For petrol, two substantive parameters have a time-staged regime within the table: aromatics (which has one set of constraints from commencement until 14 December 2025 and a different binding regime thereafter) and sulfur (which has higher allowable sulfur for the transitional period and tightens to 10 mg/kg maximum for all grades after 14 December 2025) (s 5 table items 1 and 17). These changes are forward-scheduled within the original text rather than effected by amendment.

No prior instrument text, amending instruments, or schedules of historical changes are included in this document. The instrument contains no annexes listing prior versions or amendment dates beyond its own commencement and its internal transitional date. It explicitly cautions that the commencement table is not updated to reflect future amendments in the instrument itself (s 2 note).

If later amendments are made to the determination under the same statutory authority, they will appear as separate amending instruments or replacements. This instrument, as provided, contains the original text and the internal transitional dates described above; it does not include an amendment history beyond those embedded transitional arrangements.

The instrument itself contains no record of litigation. It does not list judicial decisions, references to case law, or notes of challenges. Given that it is a delegated legislative instrument made under the Fuel Quality Standards Act 2000 (s 3), any litigation that might arise challenging application, enforcement or validity would be brought under the legal framework established by that Act and by administrative law doctrines, but the instrument text contains no litigation history or references to judicial interpretation.

Because the determination prescribes testing methods and numeric limits, it creates potential factual disputes that could become the subject of litigation (for example, disputes over whether a particular laboratory method was correctly applied, whether a batch meets a parameter using the prescribed test, or whether pool-average calculations were correctly compiled). None of that, however, is reflected in the instrument text; the instrument supplies the technical specifications and test-method references that an adjudicator would apply, but no case law is cited or embedded.

For parties assessing legal risk, the absence of litigation history in the instrument means that precedential guidance on interpreting the particular phrasing of items in the petrol and ethanol tables must be sought in judicial or administrative determinations under the Fuel Quality Standards Act 2000 after the instrument has been applied. The instrument does not supply interpretations or examples.

Pool-average obligation timing and aggregation: The definition of “pool average for aromatic content” requires suppliers to average aromatics across all batches and all grades they manufacture in Australia or import over each 12-month period starting on 1 January (s 4; s 5 table item 1). That means suppliers cannot treat grades separately for the pool-average calculation; they must aggregate across all grades. The averaging window is a calendar-year window beginning 1 January, not a rolling 12 months unless a supplier elects to align records that way. Compliance therefore requires capturing and retaining batch-level test results across the entire year and then correctly weighting or averaging by batch volume, an operational task that may not be obvious to parties used to per-batch compliance approaches.

Transitional and post-transitional limits differ materially: For aromatics and sulfur there are explicit transitions on 14 December 2025 (s 5 table items 1 and 17). Between commencement and that date, all grades have a 45% v/v maximum aromatics limit with a 35% v/v pool-average; after the date, petrol with RON grade between 95.0 and 97.9 has a 35% v/v maximum aromatics, other grades 45% v/v maximum, and all grades a 35% v/v pool-average. For sulfur, the 91 RON grade and the 95 RON grade have higher maximums in the transitional period (150 mg/kg and 50 mg/kg respectively), but after 14 December 2025 all grades must meet 10 mg/kg maximum. Suppliers need to align inventory, blending plans and imports to meet the new lower sulfur ceiling from that date.

Testing-method specificity: For each parameter the instrument names a specific ASTM or EN method (s 5(2); s 6(2)). If a supplier uses a different but equivalent method, there is no provision in this instrument explaining if or when an alternative is acceptable. Enforcement authorities are likely to rely on the specified method when determining compliance. Parties must therefore ensure laboratory capability to perform the named method or obtain validated equivalence under the Act’s enforcement or regulatory arrangements, which the instrument does not describe.

Ethanol denaturant and composition constraints: The ethanol table requires the denaturant component to be petrol (s 6(3)) and the denaturant concentration to be 1-1.5% v/v (s 6 table item 4). That imposes an explicit supply-chain constraint: ethanol used in petrol must be denatured with petrol at a defined concentration. Ethanol purity must be 95.6% v/v minimum (s 6 table item 5), and water in ethanol is limited to 1.25% m/m maximum (s 6 table item 12). Blenders supplying petrol with ethanol up to the petrol maximum of 10% v/v (s 5 table item 6) must ensure the ethanol they use meets these detailed limits and that the denaturant is petrol.

Interplay of oxygen limits and ethanol presence: The petrol oxygen content limit varies depending on whether petrol contains ethanol: petrol without ethanol has an oxygen maximum of 2.7% m/m, while petrol with ethanol has an oxygen maximum of 3.9% m/m (s 5 table item 14). Blenders must therefore track oxygen content on a per-batch basis, accounting for ethanol’s oxygen contribution, to remain within the applicable maximum.

Prohibition on phosphorus compounds and a phosphorus numeric limit: The instrument contains both a categorical prohibition against adding compounds containing phosphorus to petrol (s 5(5)) and a numeric phosphorus limit (1.3 mg/L maximum) in the petrol table (item 15). Suppliers using additives must ensure additive formulations do not contain phosphorus either directly or as impurity, and must ensure finished petrol phosphorus concentrations do not exceed the numeric limit.

Grade labelling triggers octane minima: The RON and MON minima are tied to grade labels (s 5 table items 12, 16). For example, a product labelled as 95 RON grade must achieve the RON 95.0 and MON 85.0 minima specified. Suppliers must ensure product labelling and product testing align, otherwise label-based claims may be inconsistent with these technical minima.

Limits on specific ethers and ethers’ interactions with ethanol: DIPE, ETBE and MTBE are each limited to 1% v/v maximum (s 5 table items 4, 7, 11). If a supplier blends multiple oxygenates the combined effect on oxygen content and other properties must be managed so both individual-component maxima and aggregate oxygen maxima are respected (s 5 table items 4, 7, 11, 14).

No express equivalence or sampling rules: The instrument prescribes testing methods but does not provide detailed sampling rules, laboratory accreditation requirements, or rules about the frequency of tests, margin of error, or how to treat borderline results. Those matters, and whether enforcement bodies will accept alternative sampling designs, must be addressed under the Fuel Quality Standards Act 2000 or administrative guidance.

Create a compliance plan mapped to the instrument’s parameters and testing methods: For every parameter in the petrol table (s 5 table items 1-18) and every ethanol parameter (s 6 table items 1-12), record the numeric limit and the prescribed testing method. The determination makes compliance depend on the use of the listed method for the parameter (s 5(2); s 6(2)), so either ensure in-house laboratories can perform those specific ASTM/EN methods or contract accredited third-party laboratories that can produce results using the exact method codes cited (for example ASTM D1319 for aromatics, ASTM D4815 for ethanol and ethers, ASTM D5453 for sulfur).

Institute batch-level testing, recordkeeping and volume-weighted pool averaging: Because “pool average” is calculated across all batches and grades a supplier manufactures or imports in each 12-month period starting 1 January (s 4), maintain batch-by-batch test results and batch volumes so pool averages can be calculated accurately. Establish a documented methodology for computing the pool-average (volume-weighted arithmetic mean), retain supporting laboratory reports and batch manifests, and schedule annual reviews tied to the 1 January start date so that the pool-average can be produced for each calendar year.

Plan for the transitional dates: Identify the operational impact of the 14 December 2025 changes for aromatics and sulfur (s 5 table items 1 and 17). For sulfur, ensure supply chains, blending feedstocks and desulfurisation steps are scaled to meet the 10 mg/kg maximum for all grades from that date. For aromatics, implement blending and component selection strategies to meet the post‑14‑December pool-average and grade-specific maxima. Forecast inventory turnover so that petrol placed on the market after the transitional date complies with the tighter standards.

Ensure ethanol chain-of-custody and denaturant compliance: If blending ethanol into petrol, procure ethanol that meets the s 6 specifications, including 95.6% v/v minimum ethanol purity, methanol and water limits, pHe range, and sulfur limit (s 6 table items 5, 7, 12, 8, 11). Ensure the ethanol is denatured using petrol as required (s 6(3)) and that the denaturant concentration is within 1-1.5% v/v (s 6 table item 4). Document the supplier’s certification that ethanol provided for blending meets these specifications.

Align labelling and grade claims with octane minima: Where a fuel is labelled as a particular RON grade, ensure batch testing demonstrates compliance with the RON and MON minima specified for that grade (s 5 table items 12, 16). Maintain testing evidence in case of verification by enforcement authorities.

Avoid prohibited additives containing phosphorus and monitor phosphorus concentration: Do not add compounds containing phosphorus to petrol (s 5(5)). Verify additive formulations and supplier declarations; test finished petrol for phosphorus concentration to ensure the numeric limit (1.3 mg/L maximum) is not exceeded (s 5 table item 15).

Monitor oxygenate and ether contributions: Track individual oxygenate component concentrations against their maxima (DIPE, ETBE, MTBE at 1% v/v each, TBA 0.5% v/v) and ensure aggregate oxygen content does not exceed the applicable limit for petrol with or without ethanol (s 5 table items 4, 7, 11, 18, 14). For petrol containing ethanol, ensure total ethanol does not exceed 10% v/v (s 5 table item 6) and that oxygen content remains within 3.9% m/m maximum.

Establish laboratory accreditation and chain-of-custody procedures: Because the determination relies on specific test methods, use laboratories accredited to perform the cited ASTM/EN standards. Put in place documented chain-of-custody procedures for samples, standard operating procedures for tests, and methods for handling borderline or out-of-specification results, and retain test reports for enforcement inspection.

Record transitional stock and import timing: For imported product, track shipping, customs release and placement-on-market dates to determine which regime (pre- or post-14 December 2025) applies for sulfur and aromatics. Plan import timing and blending so that product placed on the market after the transitional date will meet the post‑transition standards.

Build internal audit, supplier warranty and contract terms: Include warranty provisions and supplier specifications in procurement contracts with refiners, ethanol producers and additive suppliers to ensure upstream compliance. Implement internal audit cycles that confirm testing, averaging and recordkeeping practices meet the instrument’s demands.

Engage with regulators where necessary: If alternative testing methods are considered or if equivalence of foreign testing procedures is an issue, engage proactively with the enforcement authority under the Fuel Quality Standards Act 2000 for guidance or a formal determination on acceptance of alternative methods. Because the instrument itself is silent on equivalence, administrative clarity from the regulator will reduce enforcement risk.

Prepare documentation for enforcement scrutiny: Maintain copies of the instrument’s relevant test results, pool-average calculations, supplier declarations for ethanol denaturant and purity, additive safety data sheets showing absence of phosphorus, and laboratory accreditation certificates. The determination’s reliance on specified testing methods means that authorities will expect corresponding technical documentation to substantiate compliance.

Review product marketing and specifications: Ensure product marketing statements (for example advertising a particular octane grade) are aligned with the technical minima in the instrument. Document testing that substantiates grade claims and keep this on file.

Update compliance policies and staff training: Train procurement, blending, QC and compliance staff on the specific numeric limits, the testing standards to be used, the pool-average calculation methodology and the transitional dates. Update compliance manuals to reflect that any ethanol component of petrol must comply with the ethanol table (s 5(4)) and the ethanol denaturant must be petrol (s 6(3)).

In summary, compliance requires operational alignment across testing capability, supply-chain contracts, blending practices, recordkeeping for pool averaging, and forward planning for the 14 December 2025 transitions. The instrument provides prescriptive technical metrics and testing-method certainty, but it leaves enforcement mechanics to the parent Act; accordingly, suppliers should couple strict technical compliance with administrative readiness to demonstrate conformity under the Fuel Quality Standards Act 2000.