Insights

Articles dedicated to regulatory issues to keep participants informed of constant changes to the EPA’s Renewable Fuel Standard and other fuel industry issues.

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Beyond the BTC: What 45Z Means for Biodiesel Blenders

July 15, 2026

The expiration of the Biodiesel Blender’s Tax Credit (BTC) at the end of 2024 and its replacement by the Section 45Z Clean Fuel Production Credit has been characterized as a policy upgrade – a more sophisticated, carbon emissions-based framework that is renewable fuel neutral. While that characterization has some merit for renewable fuel producers, the picture is less favorable for downstream biodiesel blenders. Under the BTC, blenders had a path to the credit value – sometimes negotiated through the purchase of B99 – but it was real. Under 45Z, that path is murky at best. What was once a fixed,... Read More →

RIN Separation Reasons: How to Pick the Right One for Transactions

June 10, 2026

When you have a client dinner expense, do you struggle with submitting it under Meals or Entertainment? Neither option is wrong, exactly, but choosing the right one aligns the expense with the budget, makes the review process faster, and complies with accounting standards. Think of RIN Separation Reasons like the options for submitting business expense report. You could probably make a case for a client dinner under Meals or Entertainment. Choosing the right separation reason probably leaves the person transacting RINs feel the same way. Separation reasons tell EPA why a RIN is being separated from its associated volume of... Read More →

Choosing the Right Reason for a RIN Trade (and Why It’s Simpler Than You Think)

May 13, 2026

Selecting the right reason for a RIN trade is like ordering a meal for dine in or to go at a restaurant. Seems simple, right? Same food, but very different handling. Reasons for RIN trades work the same way. Spot, Term, Consignment, and Standard don’t change what you’re selling; they describe how the deal is structured. Once you understand what each one is actually describing, picking the right one becomes very straightforward. The Common RIN Trade Types You Need to Know Each time you sell RINs, you’ll select one of four primary trade types when entering the transaction. Each corresponds... Read More →

March Came in Like a Lamb, Out Like a Lion: SRE Reallocation Continues to Evolve

April 14, 2026

March is often described as coming in like a lion and going out like a lamb, but this year, the opposite played out with respect to Small Refinery Exemptions (SREs) under the Renewable Fuel Standard. On March 13, the D.C. Circuit Court of Appeals quietly stepped aside on one of the closely watched issues in the RFS: SRE reallocations. The court ruled the case moot, declining to weigh in and leaving the question unresolved in Clean Fuels Alliance v. EPA. By the end of March, that quiet moment gave way to a much louder, roaring development. EPA finalized its Set... Read More →

Anatomy of a RIN: What Every RFS Participant Should Know

March 11, 2026

Every Renewable Identification Number (RIN) tells a story under the Renewable Fuel Standard (RFS). For RFS participants, understanding that story is not academic. It informs trading decisions, blending economics, compliance planning, and risk management. Whether you are receiving RINs with biofuel for blending, acquiring RINs for obligation coverage, evaluating inventory, or analyzing market exposure, the ability to quickly interpret what a RIN represents is essential. This guide focuses on what every RFS participant should know — and how to read a RIN in 30 seconds. First: What a RIN Really Represents A RIN is generated when qualifying renewable fuel is... Read More →

When the RFS Clock Slows Down: What 2025 Reporting Deadlines Mean for RINs

February 11, 2026

The Renewable Fuel Standard (RFS) is designed around annual compliance obligations and quarterly reporting deadlines that, on paper, look predictable. The annual schedule is set with requirements, timelines, and expectations. The RFS calendar has a habit of slowing down when EPA has not yet finalized every regulatory piece needed to close out a compliance year. As obligated parties look to finalize 2025 reporting, timing is once again a key variable, with implications that extend beyond paperwork and into RIN validity and market behavior. Two clocks, one program For most RFS participants, reporting obligations for 2025 remain unchanged. Producers, renewable fuel... Read More →

The Responsible Corporate Officer: The Pivotal Position within the EPA’s Renewable Fuel Standard

January 12, 2026

If you participate in the Renewable Fuel Standard (RFS) program, whether as a renewable fuel producer, obligated party, exporter, or other regulated entity, you are required to designate a Responsible Corporate Officer (RCO) with the U.S. Environmental Protection Agency (EPA). The RCO plays a pivotal role in ensuring the accuracy, legality, and integrity of all compliance activities under the RFS. But what exactly does it mean? And who is eligible to serve in this role? Below, we break down the essentials. What Is a Responsible Corporate Officer (RCO)? The Responsible Corporate Officer is the individual legally accountable for the information... Read More →

A Brief History of the RFS: How It Started and How It Has Evolved Across Administrations

December 5, 2025

Understanding how the Renewable Fuel Standard (RFS) began, how much the program has changed, and why it even exists in the first place can be challenging. The RFS didn’t simply appear fully formed. It has been reshaped repeatedly by Congress, the courts, market forces, and each presidential administration. Taking a step back to understand the evolution helps explain many of the complexities we navigate today. Origins: Energy Security, Rural Development, and Early Biofuel Policy The RFS was enacted with the Energy Policy Act of 2005 (EPAct), which is rooted in Section 211(o) of the Clean Air Act. At the time,... Read More →

What the SRE Reallocation Fight Means for the RFS

October 15, 2025

EPA has moved to address how to account for billions of gallons of renewable fuel blending obligations that were waived by Small Refinery Exemptions (SREs). The Agency’s supplemental proposal would either fully or partially (50%) reallocate those waived volumes into future Renewable Volume Obligations (RVOs)—a move that would directly increase demand for biofuels (and RINs) if added to the increases for biofuels in the proposed 2026–2027 RVOs. This proposal has once again pitted importers and refiners against the agricultural and biofuels sectors. Background — How We Got Here SRE authority was created within the Renewable Fuel Standard (RFS) framework to... Read More →

How to Manage the RIN Rollercoaster

September 28, 2025

The complex and frequent regulatory shifts within the federal Renewable Fuel Standard (RFS) program are the primary drivers of volatility in Renewable Identification Number (RIN) prices, and we’ve all been stuck riding the RIN rollercoaster. RINs are the compliance currency and market incentive of the RFS, and it’s crucial your company understands how to value and plan your RINs. When the Environmental Protection Agency (EPA) or Congress signals a potential change in RFS policy, such as delays in setting Renewable Volume Obligations (RVOs), the granting of Small Refinery Exemptions (SREs), or proposals for market-altering reforms (like a price cap), it... Read More →