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Fuels Registration, Reporting, and Compliance Help

How to Register a Quality Assurance Plan (QAP) Provider Company

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About Quality Assurance Plans

The Renewable Fuel Standard (RFS) program requires the use of valid RINs to demonstrate compliance with the RFS volume obligations. Parties in the RFS program can spend considerable time and effort in evaluating whether RINs were validly generated.

Quality Assurance Plans (QAPs) provide:

  • A means for ensuring that RINs are properly generated through audits of renewable fuel production conducted by independent third-parties
  • An affirmative defense under certain conditions for the transfer or use of invalid RINs that had been verified under an approved QAP
  • The conditions when RINs must be replaced
  • A process for determining who will replace invalid RINs.

Both the QAP providers and the Renewable Fuel Producers that wish to implement QAPs must take steps to register properly in OTAQREG. Select the company type below for specific instructions.

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Instructions for QAP Providers

QAP providers are independent third-parties that conduct audits of renewable fuel production. There are two registration steps required for QAP providers before they can begin providing services to renewable fuel producers: 

  • Step 1: Register as a QAP provider in OTAQREG
  • Step 2: Associate with renewable fuel producer companies in OTAQREG 

Step 1: Register as a QAP provider in OTAQREG:

  1. Read Sections 1 through 3 of the user guide: 
    User guide to OTAQREG for QAP (PDF)(61 pp, 1.88 MB, EPA-420-B-15-061, March 2015)
  2. In addition to submitting the required company information, QAP providers are required to submit the following materials through OTAQREG:
    1. Company qualifications
    2. General Quality Assurance Plan
    3. Pathway-specific QAP plan(s)
  3. After the New QAP Company request is submitted:
    1. EPA will review the request.
    2. An email notification is sent to the Responsible Corporate Officer (RCO) and associated users when the request is activated by EPA.
    3. EPA will contact you if there are any issues that prevent EPA from activating the request.

Step 2: Once approved in OTAQREG, the QAP provider should associate with the renewable fuel producer company:

  1. Read Section 4 "QAP Company to Fuel Producer Company Associations" in this user guide: 
    User guide to OTAQREG for QAP (PDF)(61 pp, 1.88 MB, EPA-420-B-15-061, March 2015)
  2. Submit the QAP Auditor Association request in OTAQREG.
  3. The RCO of the renewable fuel producer company must approve the QAP Auditor Association request before the QAP provider can begin auditing the renewable fuel producer.

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Instructions for the Renewable Fuel Producer Company

After the QAP Auditor Association request is submitted by the QAP Provider:

  • The Responsible Corporate Officer (RCO) of the renewable fuel producer company must have RCO e-signature capability in order to approve the QAP Auditor Association request in OTAQREG. To register for RCO e-signature capability, follow the instructions in this user guide: How to Enable RCO E-Signature Capabilities in OTAQREG (PDF)(5 pp, 822 K, June 2018, EPA-420-B-18-033, About PDF)
  • RCOs should follow the instructions in Section 4.2 of this user guide to approve QAP Auditor Association requests: User guide to OTAQREG for QAP (PDF)(61 pp, 1.88 MB, EPA-420-B-15-061, March 2015)
  • Please note: The RCO must approve the QAP Auditor Association request before the QAP provider can begin auditing the renewable fuel producer.

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