Quality Assurance Plans under the Renewable Fuel Standard Program
The Quality Assurance Plan (QAP) is a voluntary program where independent third-parties may audit and verify that RINs have been properly generated and are valid for compliance purposes. RINs verified under a QAP may be purchased by regulated parties.
In general, the RFS program is based on a “buyer beware” liability and compliance approach, in which regulated parties are expected to conduct due diligence to confirm that RINs purchased are valid for compliance purposes. If RINs are found to be invalid, the obligated party is liable and must purchase new RINs to replace the invalid ones, and are also at risk of violations under the Clean Air Act. Obligated parties who purchase RINs verified through this program have an affirmative defense for the transfer or use of any invalid RINs that had been verified under an approved QAP. The program also defines the conditions when RINs must be replaced, and a process for determining who will replace the RINs.
EPA expects the program to promote greater liquidity in the RIN market, especially for smaller producers, helping to make the RFS program more efficient and effective.