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Gas Station Franchise: The Fuel Contract, the Store Franchise and the Tank Rules

Empty unbranded fuel station forecourt at dawn with tank fill caps in the foreground

A gas station franchise can be two separate contracts: a fuel supply or branding deal that the Petroleum Marketing Practices Act can govern, and a convenience store franchise sold under the FTC Rule, both resting on EPA-regulated tanks.

Key takeaways

  • The Petroleum Marketing Practices Act (15 U.S.C. 2801) calls a contract to sell motor fuel under a trademark owned or controlled by a refiner a franchise, and the FTC Franchise Rule does not apply to those relationships (16 CFR 436.8(a)(4)), so a fuel-only dealer deal can arrive with no disclosure document.
  • Under the Act a fuel supplier may end or refuse to renew only on grounds listed in 15 U.S.C. 2802(b), with written notice at least 90 days ahead under 2804(a), and the dealer has 1 year to sue under 2805(a).
  • Two current filings disagree about the Act: the Circle K Motor Fuel Supply Agreement (FDD issued July 10, 2026, Exhibit H, section 36) says the PMPA does not apply, while the APLUS Premises Lease in the Sunoco Retail FDD issued April 24, 2025 calls the operator a PMPA franchisee and retailer.
  • Owners of petroleum tanks at a fuel retail site must carry $1 million per occurrence in financial responsibility for leaks and $1 million in annual aggregate for 1 to 100 tanks (40 CFR 280.93).
  • EPA counted 534,189 active underground storage tanks at about 190,224 facilities as of March 2026, and a 60.9% technical compliance rate from April 2025 to March 2026 (EPA UST performance measures).
Key numberWhat it isSource
$25,000Circle K Initial Franchise Fee, single storeCircle K FDD (July 10, 2026), Item 5 and Item 7 Note 1
$30,000 to $125,000Circle K Security Deposit paid with the Motor Fuel AgreementCircle K FDD (July 10, 2026), Item 5 and Item 7 Note 13
$0.0075 per gallonMotor fuel leg of the Circle K royalty testCircle K FDD (July 10, 2026), Item 6
$15,000APLUS initial franchise feeAPLUS FDD (April 24, 2025), Item 5
Up to 6% of Gross SalesAPLUS royalty, non-captive storesAPLUS FDD (April 24, 2025), Item 6
90 daysMinimum PMPA notice before termination or nonrenewal15 U.S.C. 2804(a)(2)
$1 millionTank financial responsibility per occurrence at a fuel retail site40 CFR 280.93(a)(1)
30 daysDeadline to notify the agency after buying a tank system40 CFR 280.22(b)

Is a gas station franchise one contract or two?

It is one or two, depending on whose name is on the canopy and on the store. A dealer selling a refiner’s brand of fuel signs a supply or branding agreement with the refiner or a distributor, which 15 U.S.C. 2801(1) defines as a franchise. A store brand such as Circle K or APLUS adds a business-format franchise with its own disclosure document. One operator can hold both at the same address.

The two sides answer to different federal law. The FTC Franchise Rule does not apply where the PMPA covers the relationship (16 CFR 436.8(a)(4)), which is why a branded fuel dealer agreement can come with no FDD at all. Circle K’s FDD issued July 10, 2026 bundles both: a Franchise Agreement (Exhibit F) and a Motor Fuel Supply Agreement (Exhibit H), under which the franchisee must buy its motor fuel from TMC Franchise Corporation or an affiliate (Circle K FDD, Item 1).

Diagram: fuel supply chain under the PMPA beside the store franchise under the FTC Rule, both over EPA tank rules One canopy, two contracts: who signs what at a branded gas station Fuel side: supply or branding agreement Refiner owns or controls the fuel trademark Distributor (jobber) buys fuel for resale to stations PMPA franchise: 15 U.S.C. 2801(1) End only on 2802 grounds 90-day written notice (2804) Sue within 1 year (2805) No FTC disclosure document: 16 CFR 436.8(a)(4) Store side: convenience store franchise Store franchisor Circle K (TMC) or APLUS (Sunoco Retail) FDD at least 14 days before signing FTC Franchise Rule: 16 CFR 436 Item 5 and 6 fees, Item 7 build cost Termination per the contract and state relationship laws Circle K fuel agreement s.36: PMPA does not apply Station operator (retailer and franchisee) Under both: EPA tank rules, 40 CFR Part 280, bind the tank owner and operator
A branded station can sit under two contracts: a fuel agreement covered by 15 U.S.C. 2801 to 2806 and a store franchise under 16 CFR 436, which exempts PMPA relationships at 436.8(a)(4). Sources: GovInfo, eCFR, Circle K and APLUS FDDs, accessed November 3, 2026.
  • Fuel side: Refiner (owns or controls the fuel trademark), then Distributor (jobber, buys fuel for resale to stations), then the station operator. A PMPA franchise under 15 U.S.C. 2801(1): end only on 2802 grounds, 90-day written notice (2804), sue within 1 year (2805). No FTC disclosure document: 16 CFR 436.8(a)(4).
  • Store side: Store franchisor, Circle K (TMC) or APLUS (Sunoco Retail), delivers an FDD at least 14 days before signing. FTC Franchise Rule, 16 CFR 436: Item 5 and 6 fees, Item 7 build cost; termination per the contract and state relationship laws. Circle K fuel agreement s.36: PMPA does not apply.
  • Under both: EPA tank rules, 40 CFR Part 280, bind the tank owner and operator.
QuestionFuel supply or branding agreementConvenience store franchiseSource
Federal lawPetroleum Marketing Practices Act, 15 U.S.C. 2801 to 2807FTC Franchise Rule, 16 CFR Part 436Statute; 16 CFR 436.8(a)(4)
Disclosure before signingNo FDD where the PMPA covers the relationshipFDD at least 14 calendar days before signing or paying16 CFR 436.8(a)(4); cover pages of the Circle K and APLUS FDDs
Who grants itA refiner or distributor (2801(3))TMC Franchise Corporation (Circle K); Sunoco Retail LLC (APLUS)15 U.S.C. 2801(3); FDD Item 1
How it can endOnly on 2802(b) grounds, after notice under 2804Contract terms, subject to state relationship laws15 U.S.C. 2802, 2804
State termination lawsPreempted unless the same as the Act (2806(a)(1))Apply where a state has enacted one15 U.S.C. 2806
Fuel purchaseBranded fuel from the franchisorCircle K: fuel from TMC or an affiliate. APLUS: fuel optional; other fuel brands eligibleCircle K Item 1; APLUS Item 1

State rules that govern how a store franchisor may end the store agreement are compared in our franchise relationship laws tracker. Sector counts, SBA lending to fuel retailers and the cover-page investment ranges of 11 filings sit in our convenience store franchise statistics report, so this page does not repeat them.

What does the Petroleum Marketing Practices Act protect, and when does it apply?

The Act protects the dealer’s right to keep the brand and, at a leased station, the premises. A franchisor may terminate or refuse to renew only for reasons in 15 U.S.C. 2802(b) and only after notice under 2804. Coverage turns on the trademark: 2801(1) reaches a mark owned or controlled by a refiner, or by a refiner that supplies the distributor granting the brand.

RuleWhat the statute saysSection
Grounds to end or not renewFailure to comply with a provision that is reasonable and of material significance; failure to exert good faith efforts after written notice; a relevant event; a written mutual agreement; a good-faith withdrawal from the market area15 U.S.C. 2802(b)(2)
Relevant events listedFraud or criminal misconduct, bankruptcy, severe disability of at least 3 months, loss of the franchisor’s underlying lease, and others2802(c)
Knowledge windowThe franchisor must have learned of the failure or event no more than 120 days before notice (60 days when less than 90 days’ notice is given)2802(b)(2)(A) and (C)
NoticeIn writing, by certified mail or personal delivery, at least 90 days before the effective date, with reasons and the federal summary statement2804(a), 2804(c)
Mutual terminationSigned no more than 180 days ahead; the dealer may repudiate within 7 days by certified mail2802(b)(2)(D)
Trial franchiseFirst-time franchisee, written, initial term of 1 year or less; nonrenewal protections do not apply2803(b)(1)
Interim franchiseCombined term of 3 years or less after a market-withdrawal nonrenewal2803(b)(3)
Deadline to sue1 year after the later of the termination or the franchisor’s failure to comply2805(a)
Waivers and choice of lawA franchisor may not require a waiver of the Act as a condition of signing or renewing; a clause choosing another state’s law is not enforceable2805(f)
Renewable fuelAgreements signed or renewed on or after December 19, 2007 may not bar an E85 or 20% biodiesel pump (tanks on franchisor-leased premises excepted)2807(b)
State lawState termination and notice rules are preempted unless identical; no state-mandated goodwill payment2806(a)

Two current contracts, two answers on the Act

The two FDDs we opened take opposite positions. Section 36 of the Circle K Motor Fuel Supply Agreement (Exhibit H, page H-9) picks Arizona law and states that the PMPA does not apply to the agreement or the relationship; the same agreement sells fuel under the CIRCLE K trademarks (Circle K FDD issued July 10, 2026).

Circle K Motor Fuel Supply Agreement section 36: Arizona law and the PMPA does not apply
Circle K FDD issued July 10, 2026, Exhibit H Motor Fuel Supply Agreement, section 36 (page H-9): Arizona law governs and the parties agree the PMPA does not apply. Minnesota CARDS, accessed November 3, 2026.

Section 1.11(C) of the APLUS Premises Lease (Attachment 6 to the Franchise Agreement, page 8) says the operator is a franchisee and a retailer as defined by the PMPA, and section 1.11(B) says Sunoco loans the motor fuel equipment for the lease term (APLUS FDD issued April 24, 2025). The same lease lets Sunoco end it when a fuel supply default gives PMPA grounds.

APLUS Premises Lease section 1.11(C): operator is a franchisee and retailer under the PMPA
APLUS FDD issued April 24, 2025, Attachment 6 Premises Lease, section 1.11(C): the operator is a franchisee and a retailer as defined by the PMPA, 15 U.S.C. 2801. Minnesota CARDS, accessed November 3, 2026.

This is not legal, financial or investment advice. Which statement holds for a given site is a question for a petroleum marketing attorney, and three questions frame it: is the fuel trademark owned or controlled by a refiner under 2801(1); does 2805(f)(2) reach a clause choosing another state’s law; and what notice applies if the store agreement ends first? Our guide to hiring a franchise attorney covers what that review costs and which clauses to send.

What do the Circle K and APLUS filings charge for the fuel side?

Circle K prices fuel into its royalty and a deposit; APLUS leaves fuel optional and charges on store sales. Circle K’s royalty test includes $0.0075 per gallon of Motor Fuel Sales, and a $30,000 to $125,000 Security Deposit secures the Motor Fuel Agreement. APLUS charges up to 6% of Gross Sales, with a minimum monthly royalty difference of up to $2,000 (Item 6).

TermCircle K (Standard), FDD issued July 10, 2026APLUS, FDD issued April 24, 2025Source
Fuel requiredYes: motor fuel from TMC or an affiliateNo: Sunoco or another fuel brand, or no fuelItem 1
Initial franchise fee$25,000; $15,000 to $5,000 per store under a Multiple Site Operator schedule; 25% off under the Conversion Program$15,000; Captive Market supplemental fee $15,000 to $300,000Item 5
RoyaltyThe greater of (a) (i) 3.5% of Gross Sales and (ii) $0.0075 per gallon of Motor Fuel Sales, or (b) $1,500 per Accounting PeriodUp to 6% of Gross Sales; up to 15% at Captive Market locationsItem 6
Minimum royalty$1,500 per Accounting Period (currently 28 or 35 days)Difference between royalty paid and up to $2,000 a monthItem 6
Fuel-linked chargesMotor Fuel Pass-Through Fee or Delivery Fees: $35 to $50 per deliveryKerosene fee $250 per month, where kerosene is allowedItem 6
DepositSecurity Deposit $30,000 to $125,000, non-interest-bearing, secures the Motor Fuel AgreementCollateral Security Deposit $10,000 to $21,000, set by credit ratingItem 5
Term10 years for the Franchise Agreement and the Motor Fuel Agreement5 years leased store; 10 years non-leased; one renewal of equal lengthItem 17

Under the Circle K fuel agreement, TMC is the exclusive supplier of the station’s motor fuel (section 2), the franchisee buys all of its fuel requirements from TMC (section 4) and pays for each delivery within 3 days (section 5). Conversion Program stores that convert within 9 months pay only the $0.0075 per gallon royalty for the first 25 Accounting Periods (Item 6).

APLUS adds a 1% of Gross Sales Alcoholic Beverages Assessment if the store does not sell alcohol, a marketing fee of up to $1,500 or 2% of Gross Sales (currently $750), and rent of $5,000 to $34,000 a month at a leased store (Item 6). Its Item 11 training plan includes 4 classroom hours and 3 on-the-job hours of Underground Storage Tank Review within 75 classroom and 116 on-the-job hours.

Item 7 with a forecourt: which lines move the budget?

Construction and equipment move it most. Circle K’s new-build table lists $1,800,000 to $6,000,000 for construction and $500,000 to $1,200,000 for furniture, fixtures and equipment, where fuel equipment cost turns on the canopy and the number of multi-product dispensers (Item 7, Note 5). An APLUS leased store has no construction line because Sunoco supplies the premises and loans the equipment.

Item 7 lineCircle K new buildCircle K conversionAPLUS leased storeSource
Initial franchise fee$25,000$25,000$15,000Item 7
Construction, remodeling, leasehold improvements$1,800,000 to $6,000,000$100,000 to $650,000N/AItem 7
Other site development or permitting$135,000 to $250,000$20,000 to $80,000N/AItem 7
Furniture, fixtures and equipment (Circle K includes fuel equipment)$500,000 to $1,200,000$300,000 to $1,100,000$83,000 to $275,000 (store fixtures)Item 7, Circle K Note 5
Signs$50,000 to $150,000$20,000 to $120,000N/A (graphics)Item 7
Inventory$100,000 to $220,000 (merchandise and fuel)$100,000 to $220,000$42,000 to $125,000 (store)Item 7, Circle K Note 9
Fuel or collateral deposit$30,000 to $125,000$30,000 to $125,000$10,000 to $21,000Item 7
Optional car wash, building plus equipment (two lines added)$365,000 to $1,300,000$265,000 to $1,200,000Not listedItem 7
Additional funds, 3 months$10,000 to $20,000$10,000 to $20,000$56,000 to $115,000Item 7
Real estateExcluded (Note 3)Excluded (Note 3)Rent for 3 months: $16,000 to $124,000Item 7
Figure 4Fuel and store lines in Item 7: Circle K new build vs APLUS leased storeLow and high estimates as printed; furniture, fixtures and equipment for Circle K shown in the table
Low estimateHigh estimateCircle K fuel security deposit$30,000 vs $125,000Circle K inventory, merchandise and fuel$100,000 vs $220,000Circle K signs$50,000 vs $150,000APLUS collateral deposit$10,000 vs $21,000APLUS opening inventory$42,000 vs $125,000APLUS store fixtures$83,000 vs $275,000
Source: Circle K (Standard) FDD issued July 10, 2026, Item 7; APLUS FDD issued April 24, 2025, Item 7 (Minnesota CARDS, accessed Nov 3, 2026).

Circle K’s fuel security deposit ($30,000 to $125,000) alone exceeds the whole APLUS collateral deposit range ($10,000 to $21,000). Sources: Circle K FDD (July 10, 2026) and APLUS FDD (April 24, 2025), Item 7, accessed November 3, 2026.

The notes carry costs that sit outside the totals. Circle K stores average about 5,200 square feet on at least 50,000 square feet of land, and land is not in the estimate (Note 3). Liquor licenses can reach $1,000,000 where licenses are scarce (Note 7), and forecourt inventory depends on tank size and the price per gallon on delivery day (Note 9). APLUS warns that engineering permits can add $20,000 or more to a conversion (Note 3) and that licenses sell for over $250,000 in a few areas (Note 10).

Do the Circle K Item 7 totals match their own lines?

Not exactly. Adding the 18 priced lines in each Circle K table gives figures that differ from the printed totals by $10,000 at the low end and $75,000 at the high end, in both the new-build and the conversion tables. The cover page and the Multiple Site Operator table also put the new-build top figure $1,000,000 below the printed Item 7 total.

CheckNew buildConversionSource
Sum of the 18 priced lines (our arithmetic)$3,108,500 to $9,505,500$963,500 to $3,755,500Circle K FDD, Item 7, pages 21 to 23
TOTAL printed in Item 7$3,098,500 to $9,430,500$953,500 to $3,680,500Item 7, Notes 15 and 16
Gap (sum minus printed total)$10,000 to $75,000$10,000 to $75,000Our arithmetic

We report the arithmetic only. Before sizing a loan on these figures, ask TMC Franchise Corporation in writing which total it stands behind and whether a line was changed after the totals were set. Item 7 ranges across other sectors are compared in our franchise initial investment report.

Which EPA tank rules start on the day you own the tanks?

Part 280 binds the owner and the operator of the tanks, whatever the brand. A buyer files an ownership notice within 30 days (40 CFR 280.22(b)), carries $1 million per occurrence of financial responsibility (280.93(a)(1)), trains Class A and B operators within 30 days (280.243), runs 30-day walkthroughs (280.36) and reports suspected releases within 24 hours (280.50).

DutyInterval or amount40 CFR section
Notify the agency of a new tank systemWithin 30 days of bringing it into use280.22(a)
Notify the agency of an ownership changeWithin 30 days of acquisition280.22(b)
Secondary containment with interstitial monitoringTanks and piping installed or replaced after April 11, 2016280.20
Walkthrough: spill buckets and release detectionEvery 30 days280.36(a)(1)(i)
Walkthrough: containment sumps and hand-held gaugesAnnually280.36(a)(1)(ii)
Release detection equipment testAt least annually280.40(a)(3)
Release monitoring, tanks installed after April 11, 2016At least every 30 days280.41(a)(2)
Spill bucket and containment sump testAt least once every three years (unless double-walled and monitored)280.35(a)(1)
Overfill prevention inspectionAt least once every three years280.35(a)(2)
Cathodic protection testWithin 6 months of installation, then at least every 3 years280.31(b)
Report a suspected releaseWithin 24 hours280.50
Report a petroleum spill or overfillWithin 24 hours if over 25 gallons or causing a sheen280.53(a)
Start the initial response to a confirmed releaseWithin 24 hours: report, stop further release, mitigate fire and vapor hazards280.61
Financial responsibility per occurrence$1 million at fuel retail sites or over 10,000 gallons a month; $500,000 otherwise280.93(a)
Financial responsibility, annual aggregate$1 million for 1 to 100 tanks; $2 million for 101 or more280.93(b)
Class A and B operator trainingWithin 30 days of assuming duties; Class C before duties280.243
Notice before closing a tankAt least 30 days before permanent closure280.71(a)
Timeline of tank duties: 24-hour reports, 30-day walkthroughs, annual tests, 3-year tests and one-time deadlines The tank owner’s clock under 40 CFR Part 280 Within 24 hours Every 30 days Every year Every 3 years Report a suspected release (280.50) Report a spill over 25 gallons (280.53) Start response to a confirmed release (280.61) Walkthrough: spill buckets and release detection (280.36) Monitor tanks for releases (280.41) Test release detection equipment (280.40) Check containment sumps and hand-held gauges (280.36) Test spill buckets and sumps (280.35) Inspect overfill prevention (280.35) Test cathodic protection (280.31) One-time deadlines Within 30 days of buying a station: file the ownership change notice (280.22(b)) Within 30 days of taking the job: Class A and Class B operators trained (280.243) Before taking the job: Class C operators trained (280.243) At least 30 days before closing a tank: notify the implementing agency (280.71)
Recurring and one-time duties of an underground storage tank owner under 40 CFR Part 280 (sections 280.22 to 280.243). Source: eCFR, current as of October 30, 2026, accessed November 3, 2026.

Franchise contracts layer their own terms on top. Circle K’s Item 1 requires inspections of release detection, automatic tank gauging and vapor recovery equipment, and its insurance rules call for environmental pollution coverage of at least $1,000,000 that runs at least two years past the end of the Motor Fuel Agreement, with tank financial assurance through a state UST fund or commercial UST insurance (Item 8). A self-insurer must show tangible net worth of at least ten times the required aggregate (280.95(b)(1)). Brand-by-brand insurance minimums are indexed in our franchise insurance requirements report.

How often do tank sites fall short of these rules?

EPA’s national figures show the walkthrough and technical rules are where sites slip most. From April 2025 to March 2026 the technical compliance rate was 60.9%, and 83.2% of facilities met walkthrough requirements, against 89.7% for operator training and 90.4% for financial responsibility (EPA UST performance measures).

Figure 6UST facility compliance rates, United States, April 2025 to March 2026
Technical compliance60.9%Walkthrough requirements83.2%Class A and B operator training89.7%Financial responsibility90.4%
Source: U.S. EPA, UST Performance Measures, April 2025 to March 2026 (accessed Nov 3, 2026).

Technical compliance at federally regulated tank facilities was 60.9% from April 2025 to March 2026, the lowest of the four EPA measures. Source: EPA UST Performance Measures, accessed November 3, 2026.

EPA measureValuePeriod
Technical compliance rate60.9%April 2025 to March 2026
Facilities meeting walkthrough requirements83.2%April 2025 to March 2026
Facilities meeting Class A and B operator training requirements89.7%April 2025 to March 2026
Facilities meeting financial responsibility requirements90.4%April 2025 to March 2026
On-site inspections38,326October 2025 to March 2026
Confirmed releases1,997October 2025 to March 2026
Releases remaining to be cleaned up52,859As of March 2026

Can the brand pay for the build, and what does leaving early cost?

Both franchisors offer build money tied to staying. Circle K’s Funding runs $100,000 to $1,000,000, needs no payments while the store is in compliance, and is written down 30% at the third anniversary of opening, then by 1/120th a month (Item 10). Leave early and the unamortized balance comes due, on top of liquidated damages under the fuel agreement.

  • Circle K Additional Funding: up to $100,000 more for a new build signed by January 31, 2027 and opened within 15 months; it cannot be combined with the Conversion Program royalty discount (Item 10, Note 1).
  • Circle K security: a security interest in the store’s assets and personal guaranties from all owners (Item 10, Note 4).
  • Circle K volume default: TMC may end the fuel agreement after a 30-day cure period if the store buys less than 75% of its minimum volume (Exhibit H, section 22(b)).
  • Circle K liquidated damages: the greater of $0.04 per gallon times the minimum Accounting Period volume, or $0.04 times the average volume of the prior 13 periods, multiplied by the lesser of 52 Accounting Periods or the periods left (section 22(c)).
  • APLUS funding: Item 10 states that Sunoco Retail does not offer direct or indirect financing, while Item 1 describes optional Equipment and Construction Funding for Non-Leased stores, amortized monthly over the franchise term and generally set at 8.33% of the prior 12 months’ gross sales for a conversion.

Neither figure says what a station will earn. The Circle K Standard FDD includes an Item 19 built on company-operated Circle K stores, and the APLUS FDD states it makes no financial performance representation; what each kind of Item 19 can and cannot show is explained in our franchise Item 19 report.

Buying an existing branded station: what carries over?

The tanks, their records and any compliance gaps carry over to the buyer; the brand contracts may not. Under 40 CFR 280.22(b) the buyer notifies the implementing agency within 30 days of acquisition, and Circle K requires upgrades within nine months when a franchisee buys a company-operated store (Item 7 notes).

  1. Get the tank file the seller must keep under 40 CFR 280.34(b): release detection records, 30-day walkthrough logs, 3-year spill and overfill results, cathodic protection tests and the operator training list (280.245).
  2. Ask when each tank and piping run was installed or replaced; after April 11, 2016 they must be secondarily contained (280.20).
  3. Confirm the financial responsibility mechanism (state fund under 280.101, insurance, or self-insurance) and that it covers $1 million per occurrence (280.93).
  4. Read the fuel agreement’s transfer clause; the PMPA leaves transfers to the franchise terms and applicable state law (15 U.S.C. 2806(b)), and a transferred term does not count as a trial franchise (2803(b)(2)).
  5. If converting to Circle K, check the Conversion Program: 25% off the Initial Franchise Fee for agreements signed before the Program Expiration Date (Item 5), and the per-gallon royalty for 25 Accounting Periods if the store converts within 9 months (Item 6).
  6. Within 30 days of closing, file the ownership notice (280.22(b)) and have Class A and B operators trained (280.243).

Resale loans and FDD transfer fees across franchise systems are covered in our franchise resale report.

Fuel-only deal, store franchise or both: a decision table

Match the contract to what you already control: land, tanks, a store and capital. The thresholds below come from the two FDDs, the PMPA and 40 CFR Part 280. They are screening rules, not legal, financial or investment advice, and a franchise attorney and a lender should read the fuel agreement, the franchise agreement and the tank file together.

IfThenWhy (source)
You own a station with tanks and want a fuel brand onlyCompare refiner and distributor supply offers; expect no FDD; ask for the federal summary statement16 CFR 436.8(a)(4); 15 U.S.C. 2804(c)
You want a store brand and already sell another fuel brandAPLUS accepts operators selling other fuel brands; Circle K requires its own fuelAPLUS Item 1; Circle K Item 1
You have no landCircle K needs at least 50,000 square feet and excludes real estate; an APLUS leased store rents from SunocoCircle K Item 7 Note 3; APLUS Item 7
Your fuel volume is uncertainPrice the 75% minimum volume trigger and the $0.04 per gallon liquidated damages before signingCircle K Exhibit H, section 22
The brand offers build fundingModel repayment if you leave before the write-down ends (30% at year 3, then 1/120th a month)Circle K Item 10
Tanks or piping were replaced after April 11, 2016Confirm secondary containment and interstitial monitoring are in place40 CFR 280.20
You will sell alcohol in a capped-license stateBudget the license outside the Item 7 range: up to $1,000,000 (Circle K) or over $250,000 (APLUS)Circle K Note 7; APLUS Note 10
A supplier sends a termination noticeCheck the grounds against 2802(b), the 90-day notice and the 1-year suit deadline15 U.S.C. 2802, 2804, 2805

Every store franchisor must deliver its FDD at least 14 days before you sign; our franchise disclosure document guide walks through all 23 Items. How SBA lenders check an agreement is explained in our SBA Franchise Directory report, and the federal rules on disclosure timing are in our FTC Franchise Rule explainer.

How we compiled this

On November 3, 2026 we opened two current FDDs from Minnesota’s CARDS registry (Circle K Standard, issued July 10, 2026, and APLUS, issued April 24, 2025) and read Items 1, 5, 6, 7, 8, 10, 11, 17 and 19, the Circle K Motor Fuel Supply Agreement and the APLUS Premises Lease. We read 15 U.S.C. 2801 to 2807 on GovInfo, 40 CFR Part 280 and 16 CFR 436.8 on eCFR, and EPA’s UST performance measures. A third CARDS search returned an unrelated brand and was discarded; we excluded Item 19 figures, fuel margins and brand cost claims that cite no filing.

Frequently asked questions

How much does it cost to open a gas station franchise?

It turns on whether you build, convert or lease. In the Circle K FDD issued July 10, 2026, the 18 priced Item 7 lines for a new build add to $3,108,500 to $9,505,500 before land, against $963,500 to $3,755,500 for a conversion. An APLUS leased store has no construction line: its fee is $15,000 and store fixtures run $83,000 to $275,000.

Is a gas station a franchise if it only sells a brand of fuel?

It can be, under federal law. The Petroleum Marketing Practices Act, 15 U.S.C. 2801(1), treats a contract to sell motor fuel under a trademark owned or controlled by a refiner as a franchise. Those relationships are exempt from the FTC Franchise Rule under 16 CFR 436.8(a)(4), so the dealer may receive a supply agreement but no Franchise Disclosure Document.

How can a fuel supplier end a gas station franchise?

Where the PMPA applies, only on the grounds in 15 U.S.C. 2802(b), such as failure to comply with a material, reasonable provision, a relevant event like bankruptcy, or a market withdrawal. Notice must be written, sent by certified mail or delivered in person at least 90 days ahead under 2804, and the dealer has 1 year to sue under 2805(a).

How much is a 7-Eleven or Chevron gas station franchise?

We did not open a 7-Eleven or Chevron filing for this page, so we quote no figure. Check Items 5, 6 and 7 of the current FDD for a store brand, and for branded fuel ask the refiner or distributor for the supply agreement; under 16 CFR 436.8(a)(4) a PMPA fuel deal comes with no FDD.

Is owning a gas station franchise profitable?

This page publishes no earnings figures. Owner results depend on the Item 6 fees, such as Circle K’s $0.0075 per gallon royalty leg, the Item 7 build cost and fuel deal terms. The Circle K Standard FDD includes an Item 19 on company-operated stores; the APLUS FDD issued April 24, 2025 includes none.

Who pays if the tanks at a franchised gas station leak?

The tank owner and operator. Under 40 CFR 280.93 they must show $1 million per occurrence in financial responsibility at a fuel retail site, through a state fund, insurance or self-insurance. Circle K also requires at least $1,000,000 of pollution coverage lasting two years past the end of its Motor Fuel Agreement (Item 8).

Sources

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