In many cases, no document is created on the date that title of the renewable fuel is transferred to the purchaser, which typically is the date the purchaser receives the fuel, and an invoice typically is used by the parties to recognize the transfer of t

The regulations at section 80.1128(a)(7) provide that any RINs assigned to a renewable fuel must be recorded on the product transfer document used to transfer ownership of the renewable fuel volume to another party, or the RINs may be recorded on a separate product transfer document transferred to the same party on the same day as the product transfer document used to transfer ownership of the volume of renewable fuel.

We believe, where the parties use an invoice as the document which transfers title to a batch of renewable fuel, the product transfer documentation requirements in section 80.1128(a)(7) are satisfied where the RINs assigned to the fuel are included either on that invoice or on a separate document which is transferred to the purchaser on the same day that the invoice is transferred. Where a separate document is used, the invoice must include the number of gallon-RINs assigned to the fuel and reference the document which transfers the RINs.

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)