Updated Engineering Reviews for Renewable Fuel and Foreign Ethanol Producers

This page will assist renewable fuel and foreign ethanol producers in completing their updated engineering review (ER) obligations under EPA’s Renewable Fuel Standard (RFS). This covers both updated 3-year ERs and updated ERs related to facility changes.

General Guidance

  • Producers should use this page in conjunction with the regulations, not in lieu of reading the regulations.
  • Updated ER reports may no longer be submitted by mail and MUST be submitted electronically. See the step-by-step instructions for more details.
  • As of April 1, 2018, updated ER reports must be submitted in OTAQREG using the ER web form by the third-party independent professional engineer (PE).
  • All producers of renewable fuel and foreign ethanol producers are required to submit an independent third-party ER report at registration and an updated ER report by January 31 of every third calendar year thereafter.
  • For example, a renewable fuel facility initially registered in 2010 is required to submit a 3-year update by January 31 of 2013, 2016, 2019, and so on.
  • To help provide clarity, the EPA has compiled a list of registered renewable fuel and foreign ethanol production facilities and a schedule for when updated 3-year ER reports are due. To view 3-year ER report due dates, see: Schedule for Three-year Update Reports for Engineering Reviews (ERs).
  • All producers of renewable fuel and foreign ethanol producers are required to submit an updated ER report when they make a change to the fuel production information at the facility.
    • If a renewable fuel or foreign ethanol producer submits an updated ER report with a VRIN analysis to EPA for a facility in the calendar year preceding the scheduled updated 3-year ER report due date, EPA will accept it in place of the updated 3-year ER report. Please contact the Fuels Program Helpdesk in the following January to confirm that submission as the 3-year ER report.

Step-by-step Instructions

Step 1: Assemble required materials.

The renewable fuel or foreign ethanol producer must assemble all materials required under §80.1450(b)(1).

Step 2: Obtain an engineering review from third-party professional engineer (PE).

The renewable fuel or foreign ethanol producer must obtain an engineering review conducted by an independent third-party professional engineer per §80.1450(b)(2). The professional engineer must verify and explain how the accuracy of all materials assembled by the producer per §80.1450(b)(1) was evaluated.

Step 3: PE reviews VRIN calculations.

For a 3-year update ER, the PE must include a detailed review of the renewable fuel producer’s VRIN calculations per §80.1450(b)(3)(iii). The VRIN calculation review is only required for a producer that generates RINs.

Step 4: Update any outdated registration information.

If any registration information has become outdated, the renewable fuel or foreign ethanol producer must generate a request for a Company Update in CDX OTAQREG. (If all registration information remains current, do not generate a request.)
To complete the request, obtain the Responsible Corporate Officer (RCO) signature.

Step 5: PE submits ER report and materials through web form.

The independent third-party PE must be associated with the renewable fuel or foreign ethanol producer in CDX OTAQREG with the “Independent Third Party Engineer” role. The PE must submit the ER report and materials required under §80.1450(b)(1) to EPA by filling out and submitting the ER web form available within CDX OTAQREG.

Step 6: Check status of your request.

Once materials have been submitted, check the status of your request.

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Last updated on February 23, 2024