Learn the Issues
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If a producer is able to change its D code, can it make retroactive changes in the D code of the RINs it has issued previously during the year or earlier if the production during the previous period would meet the newly classified D code criteria?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Once a RIN is generated and transferred to another party, it cannot be changed. Thus, retroactive changes to D codes in RINs are not allowed.
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How long will the grandfathering provision be effective? Once a grandfathered producer registers and completes their engineering review, will their baseline volume ever need to meet the 20% GHG reduction requirement?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . If a facility meets the requirements for exemption from the 20% GHG reduction requirement pursuant to 40 CFR 80.1403(c ) or (d), then the baseline volume of renewable fuel produced by that facility is exempt from the 20%…
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Will current canola based biodiesel production fall under the grandfathering provisions of the RFS2 regulations?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Biodiesel facilities may qualify for the exemption under 80.1403(c) from the requirement that renewable fuels achieve a minimum 20% GHG reduction as compared to baseline fuels if they "commenced construction" prior to the date of enactment of EISA…
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Can a gallon of ethanol generate more than 1.0 RIN in RFS2?
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 are determined by the Equivalence Values. See 80.1415 and 80.1426(f)(2)-(6). Equivalence Values are based on energy content in the renewable fuel in comparison to…
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How do I find a listing of all obligated parties pertaining to the new RFS2 Program?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Review the Fuels Programs Registrants list located at https://cdxnodengn.epa.gov/cdx-otaq-reg-II/action/reportExternal/Part80FuelsProgramslist . Any party registered as an importer or refiner for either the gasoline or diesel programs may be an obligated party in any given compliance year.
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Under "Business Activities" on the Company Details CDX web page, what does "Small Blender" mean?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The small blender business activity is in relation to §80.1440: "What are the provisions for blenders who handle and blend less than 125,000 gallons of renewable fuel per year?" The small blender business activity entry is for those…
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Am I required to register E15?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Yes. There are unique registration requirements for E15 fuel. See here for more information: E15 Fuel Registration .
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Is the licensed professional engineer conducting the engineering review required to perform the site visit in person, or can they delegate the site visit to another person who maybe assisting them in the engineering review?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Pursuant to §80.1450(b)(2), all verifications must be performed by the licensed professional engineer conducting the engineering review. This requirement includes conducting the site visits. The licensed professional engineer conducting the engineering review must perform the site visits to…
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Do you have any updates on the status of EPA’s modeling of palm oil biodiesel?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA is actively continuing its FRM evaluation of biodiesel produced from palm oil. We expect to complete that analysis within approximately 6 months, as stated in the preamble to the final rule. All currently available documents including meeting…
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I am a new company. How do I register with the EPA?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . Directions for registering a new company can be found here: How to Register a New Company, Facility, or User for Part 80 Fuels Program .
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80.1450 refers to a Fuel Supply Plan. Is this referring to the fuel used for process energy? If not, what is it referring to? If yes, by "source" do you mean the name of the supplier? The regulations ask for the locations from which the process energy fue
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . The Fuel Supply Plan referred to in 80.1450(b)(3) refers to fuel used at a renewable fuel production facility to generate process energy. "Source" means the name of the supplier of that fuel. Since 80.1450(b)(1)(iv) asks for the locations…
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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…
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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…
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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…
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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…
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Does EPA consider it a conflict of interest for a third-party company to assist a group of renewable fuel producers and importers of renewable fuel to help meet the requirements of the re-registration and engineering review pursuant to section 80.1450?
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help . EPA does not restrict a renewable fuel producer or an importer of renewable fuel from seeking a third-party company to assist them in meeting the re-registration and engineering review requirements pursuant to section 80.1450. The renewable fuel producer…
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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…
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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…
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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…