How does a marketer split RINs that go to downstream buyers (i.e. next owners like a refiner)?

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

Parties such as marketers that are required to transfer assigned RINs with renewable fuel are not required to align the number of gallon-RINs transferred with the number of gallons transferred for every transaction.

Rather, the regulations require only that the number of assigned gallon-RINs (with a K code of 1) transferred with each gallon of renewable fuel be no more than 2.5. See regulation Section 80.1128(a)(4) and preamble discussion at page 23939, column 3.

Within this limit, a marketer is free to allocate gallon-RINs to volumes of renewable fuel in whatever way he chooses, so long as an end-of-quarter check on the balance of RINs versus renewable fuel in inventory is met. See regulation Section 80.1128(a)(5).

Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)