The following is a two-part question: a. We are a petroleum refiner and recognize that we are an obligated party under the regulation. We are considering importing ethanol that has not been denatured. We will hold title to the un-denatured ethanol. Title and custody will pass to another party who will denature the ethanol and transfer title back to us. We will sell it for use as a motor fuel. Are we an importer of renewable fuel under the RFS program? b. How would RINs be generated?

See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help.

A. Un-denatured ethanol is not a renewable fuel. See 80.1101(d)(3). Under the described scenario, the party to whom custody is transferred and who denatures the ethanol would be producer of the renewable fuel.

B. Under the described scenario, RINs would be generated by the party who denatures the ethanol and produces the renewable fuel. See 80.1126(d). If the petroleum refiner wishes to generate RINs, then the petroleum refiner would have to keep title to the ethanol throughout the described transaction.

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)