New Filing Requirements for Terminal Operators, Position Holders and Vessel Operators

The IRS made changes to existing Form 720-TO/CS for expanded reporting.  All new requirements are effective June 6, 2011.  Therefore, the April 2011 filing period electronic submissions and all subsequent periods will have to be submitted to include the new requirements.

After June 6, 2011 all original, correction, replacement and supplemental files will have to be submitted in the new format.  Because of the deletion of mode codes and the addition of several new requirements, ExSTARS filers using the new format will need to be able to submit replacement files for error correction purposes, as correction files may not be capable of clearing some outstanding errors in the new format and during the transition between formats.

A summary of the changes are listed below and are also listed in Publication 3536.  We have listed each of the changes and the corresponding page numbers in the Publication for more details regarding the nature of these changes.

  • Vessel operators are now required to report receipt and delivery transactions at every facility that has an FCN. Previously, only transactions at approved terminals were reportable. Note: Pipeline operators are only required to report transactions at approved terminals. (Page 8)
  • Position Holder EINs must be reported on all terminal receipts of product codes Exx, Bxx and Dxx.
  • All 7’s, 8’s & 9’s for use as an EIN are not allowed. All 9’s can only be used to report rail or truck carriers when EIN is unknown. (Page 12)
  • Removal of references to SSN (Page 12)
  • Terminal operators and bulk carriers must report United States Coast Guard Vessel (USCG) Official Numbers (VON) when mode of transport code is B_ (Barge), IB (Import by Barge), and EB (Export by Barge) for all receipt and delivery transactions. (Pages 12 and 13)
  • Terminal operators and bulk carriers must report International Maritime Organization (IMO) Vessel Official Numbers when mode of transport code is S_ (Ship), IS (Import by Ship), ES (Export by Ship) for all receipt and delivery transactions. (Pages 12 and 13)
  • Expansion of Mode Codes to require reporting of imports and exports.  (Page 13)
  • Expansion of Mode Codes to require reporting codes for end-use, replacing “RT”.  (Page 14)
  • Expansion of Mode Codes for Airport and Railroad refueling terminals (page 13).
  • Position Holder EINs for certain fuels disbursements and receipts of (Exx, Bxx and Dxx) product codes must be reported when blended in terminal and reported as a product reclassifications. Use Book Adjustment (mode code BA). (Page 14)
  • Only certain products can be reported by terminal operators as receipts in book adjustment transactions (Page 14 and Pages 170-171)
  • Summary reporting instructions for expanded “other” product codes (Pages 170-171)
  • Error handling:
    The 151 acknowledgement will identify if outstanding “must fix” errors remain or if all errors have been resolved. (Pages163-167)
  • Elimination of error response code ‘00002’ (record correct as submitted) for correction transactions BTI14=’CO’. (Page 280)
  • As an alternative to correction files (BTI14= “CO”), replacement files for error correction (BTI14 = “6R”) See Appendix M - Use of BTI13(‘00’) vs BTI14 (‘CO’, ‘6S’ or ‘6R’) (Page 280)
  • Error correction processing:
    For data errors identified in the 151 Acknowledgement as “must fix”, an alternative to using correction files (BTI14= “CO”), is to submit a replacement file (BTI14=’6R’). Use the Transaction Set Control Number (ST02) from the original file for the period that resulted in an in-balance file with “must fix” errors in the REF~FJ REF02 element of the replacement file. (Page 280)
  • Corrections/amendments to files submitted in previous ANSI X12 version (4010) can be accomplished using supplemental files (BT114 = 6S) in ANSI X12 version 4030. You must contact the EDI help desk for assistance. (Pages 280-281)
  • Filing submissions guidelines for Supplemental, Correction, and Replacements files (Pages 282-291)
  • Receipt or disbursement transactions of zero net gallons should not be reported. (Page 292)
  • Fractional gallon amounts are not accepted (Page 292)

For any assistance with implementing any of these changes, please contact the EDI help desk at 216-898-6432.

Any other questions that you may have can be sent to

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