CWPMA recently reached out to our friends at OPS and they provided some guidance on dispenser labeling 0 for the E-15 blends authorized by the Biden administration during the summer months.
Our dispenser labeling guidance should answer most of the questions about this topic in CO. It's derived mostly from our authority via ASTM, NIST, and EPA. There are some little gray areas around specific sticker/label placement since "eye level", etc., are a bit subjective, so a photo of the dispenser helps to answer more detailed questions. The short answer is that the consumer needs to be able to easily understand what they are selecting, its antiknock index, oxygenate content, and price in a location that is most natural to see during product selection.
As we prepare for the possibility of more E15 given EPA's April 28th RVP waiver, we're adding an E15 article to our next OPS Bulletin. Here's a section of it that could be useful to pass along if it helps:
Any retailer dispensing E15 must apply a label to the fuel dispenser that is positioned to clearly identify which control the consumer will use to select E15. If the dispenser is set up to dispense E15 without the consumer taking action to select the fuel, position the label on a vertical surface in a prominent place, approximately at eye level.
Additional details and a detailed description of the required E15 label can be found in the federal requirements for E15 labeling, and you can review our dispenser labeling guidance for Colorado-specific information.