Learn the Issues
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The RIN is too long to fit onto my bill of lading. What are my options?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. An assigned RIN must appear in its entirety on product transfer documents (PTDs) identifying a transfer of ownership of a volume of renewable fuel. Substitute codes are not permitted. See regulation Section 80.1153. (In general PTDs would not include…
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What happens if a party registers with EPA then engages in no activities that must be reported during a given compliance period?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. There is no obligation to report if no activity occurs. Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (pdf) (55 pp, 221 KB, EPA420-F-07-041a, August 2007)
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Section 80.600(a)(10) says, Any refiner or importer shall maintain copies of all product transfer documents required under §80.590. If all information required in paragraph (a)(6) of this section is on the product transfer document for a batch, then the provisions of this paragraph (a)(10) shall satisfy the requirements of paragraph (a)(6) of this section for that batch.” Does that mean that if a refiner or importer has a PTD containing the information no other record is required? That seems unneeded. Does that paragraph mean something else?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Section 80.600(a)(10) first requires that product transfer documents under § 80.590 be maintained by refiners and importers. It then states that if such product transfer documents contain all the information required under paragraph (a)(6) of § 80.600 for each…
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What is the process to retire a RIN? Is this a reporting function that is done with the EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. RINs are retired for reasons specified in the regulations and must be reported to EPA. A retired RIN may not be used for compliance purposes or traded to another party. A retired RIN is reported to EPA in a…
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What metering system does the plant use to measure gallons? Is it a production meter, a load-out meter, etc.?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA regulations provide flexibility in terms of the specific mechanisms through which producers and importers measure volumes for purposes of generating RINs. However, the approach should ensure that gallons are neither systematically ignored nor systematically double-counted. Also, approaches that…
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Which non-obligated parties are allowed to participate in the credit trading program? Producers (with extra value RINs), oxygenate blenders, marketers?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Anyone can participate in the RIN trading program, subject to the requirement that the party first register with the EPA and then adhere to other regulatory requirements, including submitting required reports (such as quarterly reports on RINs held). Question…
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Will each compartment of a truck loaded at the rack at the refinery be deemed a different batch of reformulated gasoline and thus need a batch identification number? Could the invoice number serve as the unique identification number for that shipment?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. In the case of reformulated gasoline produced by adding oxygenate to RBOB in a truck, each truck compartment is a separate batch of reformulated gasoline. If the oxygen standard is being met on average, the reformulated gasoline in each…
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Will oversight programs and paper trail need to extend to conventional gasoline in order to comply with anti-dumping?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The requirements of the anti-dumping program apply only to refiners and importers. As a result, there are no downstream standards or requirements for conventional gasoline, other than those related to the prohibitions against using conventional gasoline in RFG areas…
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Would it be acceptable to provide all required product transfer document information on the bill-of-lading, including the transferee's name, except for the transferee's address, provided that the address is included on a follow-up invoice?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. As long as all product transfer documentation information is provided to the transferee, either prior to, during or immediately following the transfer of title or custody of the gasoline, the PTD requirements are met. As a result, it would…
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Could a refiner rely upon transfer documents produced by a pipeline to meet the refiners (i.e., shipper's) responsibility as it relates to the generation of transfer documents and would such a document provide an adequate defense for the refiner?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. If a refiner is the transferor to a pipeline, then the refiner would be responsible to provide documentation to the pipeline. (7/1/94) This question and answer was posted at
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Can conventional gasoline be used for off-road applications in an RFG area?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. No. Only reformulated gasoline may be sold or supplied in a covered area. (7/1/94) This question and answer was posted at
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Does a refiner have to use the same model at all of its refineries?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. If a refiner elects to aggregate its refineries under section 80.101(h), the same model (simple or complex) must be used at all refineries aggregated. (7/1/94) This question and answer was posted at
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EPA has stated that product codes would satisfy the product transfer documentation requirements if each downstream party is given the information necessary to know the meaning of the product codes. Please explain how this should be done.
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA believes that parties normally are able to meet the product transfer requirements by including the required information in the documents that the parties currently use to memorialize the transfer of title or custody of the gasoline. Therefore, as…
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What constitutes "periodic sampling and testing"?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. EPA has not defined the frequency or scope of sampling and testing that is necessary to meet the quality assurance program defense element, because there is no single program that is appropriate in all situations. In addition, EPA believes…
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What happens if a marketer sells a batch with one RIN to two different refiners? Can he divide the RIN? If so, how?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The basic unit of compliance in the RFS program is the gallon-RIN. However, for shorthand we allow multiple sequential gallon-RINs to be represented by a single batch-RIN through the appropriate designation of the start (SSSSSSSS) and end (EEEEEEEE) codes…
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How does a marketer split RINs that go to downstream buyers (i.e. next owners like a refiner)?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. Parties such as marketers that are required to transfer assigned RINs with renewable fuel are not required to align the number of gallon-RINs transferred with the number of gallons transferred for every transaction. Rather, the regulations require only that…
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How does a refinery that in-line blends RFG generate a certificate of analysis (key RFG parameters) prior to shipment as required by the regulations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. For the simple model, refiners who petitioned for an exemption from the independent sampling and testing requirements are required to specify their reasonable basis for knowing that the fuel meets the standards for benzene and oxygen, and RVP in…
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How often does EPA expect to audit refiners, importers, and distributors? Will such audits be conducted by EPA personnel or contract personnel?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The frequency of audits conducted at the above facilities will depend on a number of factors such as: general compliance rates, compliance history of individual facilities, EPA budget allowances, etc. Based upon the experience of past fuels enforcement programs…
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Documents of Ortho-Clinical Diagnostics in Raritan, New Jersey
Documents of Ortho-Clinical Diagnostics in Raritan, New Jersey
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How is the RVP and distillation non-linearity handled?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. The RVP of hydrocarbons and oxygenates should actually blend very linearly, with the exception of the lighter alcohols, methanol and ethanol. Methanol is not expected to be used as an oxygenate due to its high RVP, and there are…