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If an obligated party (a refiner) imports non-denatured ethanol and denatures it, is the refiner considered a renewable fuel producer and is the refiner obligated to establish RIN numbers and file quarterly reports for the ethanol it denatures?

The party would be identified as a renewable fuel importer rather than a renewable fuel producer, and would need to establish RIN numbers and file reports required of an importer. The party in this example would also be required to file reports required of a refiner.

Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)