Cutting Through the E15 Compatibility Confusion
By Steve Stewart
How Bridging the Gap Between E15 Deployment and E25 Safety Standards Safeguards Equipment Investments
With the expanded distribution of E15 in certain retail and commercial markets, fueling operations are confronting a confusing combination of regulatory, compatibility and certification information.
Often, a manufacturer’s warranty or letter of compatibility indicates one thing, while a third-party safety standard requires another. This contradiction leaves operators questioning whether their equipment is legitimately compatible with E15. As a result, the OPW Retail Fueling team is consistently fielding more and more questions about E15 equipment compatibility and site readiness in North America. Here are five critical things operators need to know to safely dispense E15 and meet local code and regulatory requirements.
1. Dispensing equipment must meet very specific criteria required by several regulatory and safety oversight entities to be approved to pump E15 in North America.
In the U.S., there is a distinction between standards for underground fuelling system equipment and aboveground dispensing equipment and hanging hardware. The Environmental Protection Agency (EPA) regulates compatibility with the underground storage tank equipment. But it is actually the Occupational Safety and Health Administration (OSHA) that calls for safety standards for dispensers and hanging hardware. OSHA mandates that all fuelling dispensers and associated aboveground components handling flammable liquids be “approved,” which OSHA defines as being tested and certified by a Nationally Recognized Testing Laboratory (NRTL), such as Underwriters Laboratories (UL).
In Canada, the National Fire Code (NFC) establishes broad baseline criteria for fuel-handling equipment. It incorporates standard requirements by reference, making conformance with UL/ULC and joint ANSI/CAN/UL/ULC standards legally binding. Secondarily, provincial authorities, such as Ontario’s Technical Standards and Safety Authority (TSSA), issue official directives that formally adopt standards, which they may customize to their province’s needs.
2. When it comes to E15 dispensing equipment, neither a warranty nor a compatibility letter from a manufacturer can be used as a substitute for the correct UL listing.
Some manufacturers have issued letters stating their E10 products will work with E15. While their products may work with E15, simply communicating they will work does not help operators meet their regulatory obligations. The product must have the appropriate UL safety listing for dispensing equipment to meet the regulatory code.
3. Just because the dispensing equipment has a UL listing doesn’t necessarily mean it is the correct UL listing for E15. This is especially true for legacy dispensing equipment.
Many retail fuel dispensers still operating in the field are manufacturer-warranted for blends up to E15, but they are certified by UL or ULC only for blends up to E10. Here’s why:
In February 2009, UL announced that using UL 87-certified equipment nominally rated for up to 10 per cent ethanol to dispense blends of no more than 15 per cent ethanol should not pose immediate safety concerns. However, UL later clarified that E15 fuel can contain more than 15 per cent ethanol in practice due to blending variations, splashing and transport mixtures. As a result, UL does not have a specific E15 safety listing. Instead, UL is testing and certifying equipment at the next-highest safety tier (E25). To that end, UL 87A-E25 for dispensers was ratified in 2015. Additional standards have been established for hoses, breakaways, valves and nozzles.
“Replacing an entire dispenser to make it compatible with E25 is expensive. Thankfully, major dispenser manufacturers have developed E25 field retrofit assemblies that offer retail and commercial operators a modular, cost-effective path to pumping E15 while preserving their original investment.”
4. Equipment that is compatible with E85 does not automatically mean the equipment is compatible with E25.
A common misconception about E15, E25 and E85 (and the equipment used to dispense these fuels) is that if the equipment is NRTL-approved to dispense E85, it is automatically grandfathered in to handle ethanol blends with lower concentrations. But the material compatibility of fuel system components handling ethanol blends is non-linear. That is to say, while E85 contains more ethanol than E25 and E15, mid-level blends like E25 are actually far more aggressive at swelling and breaking down seals and gaskets. As such, UL tests equipment for E25 and E85 differently to assure safe operation.
5. Retrofit kits and à la carte options are available to replace dispenser components and hanging hardware that do not have the appropriate UL listing for E25.
Replacing an entire dispenser to make it compatible with E25 is expensive. Thankfully, major dispenser manufacturers have developed E25 field retrofit assemblies that offer retail and commercial operators a modular, cost-effective path to pumping E15 while preserving their original investment. E25-rated meters, specialized valves, manifolds and, importantly, gaskets tested against aggressive fluids are among the field retrofit components available to upgrade internal dispenser components for E25.
Advanced manufacturing partners such as OPW Retail Fueling are also engineering their hanging hardware to support safe E25 fuelling. Here are equipment features commercial and retail fuel site operators should look for in hanging hardware UL-listed for E25:
Automatic nozzles: Look for corrosion-resistant materials such as nickel-plated aluminum, Teflon and high-performance Viton seals.
Reconnectable breakaways: Look for high-grade fluorocarbons such as Viton for seals, stainless steel springs and acetal guides and poppets that provide extreme chemical resistance.
Swivels: Look for dual seals that include high-performance Viton.
Whip hose, curb hose and hose kits: Look for hoses with an oil- and solvent-resistant (ORS) synthetic nitrile inner tube, wire-braid reinforcement and low-permeation materials to meet UL’s strict low-perm limits.
Leveraging à la carte options such as these will enable operators to upgrade to E25 at a fraction of the cost.
Formula for Forecourt Success
As the transportation fuel mix continues to evolve in North America, installing the correct, appropriately UL/ULC-listed fuelling system equipment is essential for both immediate success and long-term business continuity. In the short term, offering E15 signals to motorists that a store is committed to lower-cost, lower-emission fuel. This approach can attract new customers and grow loyalty. In the long term, installing E25-certified hardware seamlessly positions future-fuel-focused operations for higher blend tiers without forcing a second round of capital outlay.
Achieving this readiness requires proactive due diligence. Fuel site operators must work with distributor and manufacturing partners to review existing fuelling system equipment. Auditing every component in the fluid path, from internal hydraulic manifolds to the nozzle, helps confirm that retrofits and hanging hardware are fully rated for the job. Taking these collaborative steps will help fuel retailers safeguard their investments, maintain operational continuity, support adherence to local codes and regulations and ultimately grow their business.
For Reference:
- U.S. Code of Federal Regulations (40 CFR § 280.32): https://www.ecfr.gov/current/title-40/chapter-I/subchapter-I/part-280/subpart-C/section-280.32
- OSHA Standard 29 CFR § 1910.106 (Flammable Liquids): https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.106
- National Fire Code of Canada: https://nrc-publications.canada.ca/eng/view/object/?id=d77ca42c-caef-4769-930e-2eb618111c8e
- Technical Standards & Safety Authority: https://www.tssa.org/fuels-dashboard
- National Renewable Energy Laboratory, “E15 and Infrastructure”: https://afdc.energy.gov/files/u/publication/e15_infrastructure.pdf
- ANSI: https://webstore.ansi.org/standards/ul/ansiululc87a2024
- Growth Energy “Growth Energy Comments on EPA’s Proposed E15 Fuel Dispenser Labeling and Compatibility with Underground Storage Tanks Regulations”: https://growthenergy.org/wp-content/uploads/2021/04/Growth-Energy-E15-Labeling-UST-Compatibility-Letter-with-Attachments_US_169654708_1.pdf
Steve Stewart is senior Canadian and Caribbean sales manager for OPW Retail Fueling, based in Smithfield, N.C. He can be reached at steve.stewart@opwglobal.com. For more information on OPW Retail Fueling, go to opwretailfueling.com.
