Learn the Issues
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What are the requirements for a foreign producer who wishes to generate RINs for the renewable fuel they produce?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Foreign producers who plan to generate RINs must register and conduct a third-party engineering review pursuant to section 80.1450. Additionally, such foreign producers must meet the requirements in section 80.1466 prior to generating any RINs for their fuel. The…
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What is the operational tolerance for denaturant in ethanol to meet the definition of Renewable Fuel? The RFS2 definition calls for a maximum of 2% denaturant. What if the lab results come back higher or lower than 2%? For example, what if the lab results
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The definition of renewable fuel in 80.1401 specifies that the maximum amount of denaturant in ethanol that can be treated as renewable fuel is 2 volume percent. If lab results indicate that the concentration of denaturant is higher than…
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Can an engineering review on a facility with multiple fuel pathways be combined into one report?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. The engineering review for a renewable fuel facility that contains multiple fuel pathways may be combined into one report. However, all information that is required to be reviewed and verified by the third party engineer conducting the engineering…
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Does ethanol derived from cellulosic feedstock or sugar have the same Equivalence Value as ethanol derived form corn starch, i.e. 1.0?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. Equivalence Values are based on energy content in the fuel, adjusted for renewable content in comparison to denatured ethanol. See 80.1415(c). Ethanol from starch, sugar, and cellulose is all chemically identical, and is all 100% renewable (none of…
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If I produce biodiesel using waste vegetable oil, can I generate more RINs per gallon than if I use virgin soy oil? Would the use of solar panels as a heat source for our process help with our RIN number per gallon?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The number of RINs that can be generated for each gallon of renewable fuel is determined by the Equivalence Values. See regulations at 80.1415(b) and 8.1426(f)(2)(i), for example. Equivalence Values are based on energy content in the renewable fuel…
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If my fuel is already registered with the Fuels and Fuel Additives program under 40 CFR Part 79, do I still need to register with the RFS2 program under 40 CFR Part 80?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Yes. Even if your fuel or fuel additive is already registered under 40 CFR Part 79, there are additional registration requirements for parties regulated under the RFS2 program, as specified in 40 CFR 80.1450.
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How does a renewable fuel producer document that the MSW feedstock that they are using to produce cellulosic ethanol meets the definition of separated MSW as defined in Section 80.1426(f)(5)(i)(C )? How does the producer quantify the portion of the final
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The renewable fuel producer using separated MSW feedstock to produce renewable fuels such as cellulosic ethanol, cellulosic diesel, cellulosic naphtha, etc. must document that their feedstock meets the definition of separated municipal solid waste (MSW), which is "material remaining…
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May I generate RINs for renewable fuel that I produced and sold for non-motor vehicle use in the past so that I can reinstate those RINs under RFS2?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. RINs that were previously generated in 2009 and 2010 may be reinstated if they were retired for non-motor vehicle use. However, RINs may not be generated for renewable fuel produced in the past in order to retire RINs…
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Does an ethanol producer who sells undenatured ethanol to a U.S. importer who denatures it at the port need to register with EPA under RFS?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The RFS regulations specify that foreign producers of ethanol for use in transportation fuel, heating oil or jet fuel for import to the US who do not add denaturant to their product, must register under RFS. See 80.1450(b) and…
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What is the requirement for submitting the engineering review?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The engineering review must be submitted and accepted by EPA as part of a renewable fuel producer’s initial registration 60 days prior to the generation of RINs, whichever date comes later. Every 3 calendar years from the initial date…
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Table 1 in 80.1426 does not include a coal fired ethanol plant. If a coal fired plant can be demonstrated as "grandfathered-in," can we assume the ethanol produced will have a D code of 6?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Per 80.1403(c), all facilities (including coal-fired facilities) for which construction commenced prior to December 19, 2007 and which completed construction within 36 months without an 18 month hiatus in construction may qualify for grandfathered status regardless of the fuel…
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In addition to 2009 RINs, may a party reinstate 2008 and 2010 RINs that were retired for non-road use under RFS1?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Pursuant to §80.1429(g), any 2009 RINs that were retired for non-motor vehicle, heating oil or jet fuel use under RFS1 may be reinstated under RFS2. The regulations do not allow 2008 RINs to be reinstated. Since RFS1 RINs generated…
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What if pricing changes after the information has been reported to EMTS?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Parties will not be required to resubmit price information if it changes. The price information must be accurate rounded to the nearest cent (US Dollar) at the time the transactional information is sent to EMTS.
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When do I get an EPA assigned fuel ID/additive ID?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. You will receive your assigned ID after registering your fuel and/or fuel additive with EPA.
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Please clarify whether oxygenates blended into either conventional gasoline or Reformulated Blendstock for Oxygenate Blending (RBOB) downstream of the refinery need to be included in sulfur compliance calculations.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.205(c) provides that a refiner or importer may include oxygenates added downstream from the refinery or import facility if the requirements under § 80.69(a) or § 80.101(d)(4)(ii) of the RFG/CG regulations are met. Therefore, a refiner or importer…
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Is there any volume cap when using previously-retired 2008 or 2009 biodiesel RINs to satisfy an obligated party?s 2010 Biomass Based Diesel RVO? Can 2008 or 2009 biodiesel RINs that were previously-retired in 2009 also be used to satisfy Advanced Biofuel
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. 2008 and 2009 biodiesel and renewable diesel RINs (that is, RFS1 RINs with a D code of 2 and RR code of 15 or 17) used for compliance purposes in 2009 can also be used to reduce the 2010…
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