At our terminal, we transfer ownership of ethanol to our customers simultaneously with blending that ethanol into gasoline. Who owns the RINs?
A RIN assigned to a volume of renewable fuel is separated by the party that owns that volume of renewable fuel at the time of blending. If a downstream customer is the owner of the volume of renewable fuel when it is blended into gasoline or diesel, he will own the separated RINs and be subject to all the registration, recordkeeping, and reporting requirements. In the case of a blender and a downstream customer who might both lay claim to the right to separate any assigned RINs, these two parties would need to come to agreement between themselves regarding which party will own the separated RINs.
Question and Answer was originally posted at: List of Reformulated Gasoline and Anti-Dumping Questions and Answers: July 1, 1994 through November 10, 1997 (pdf)