Where a company is both an obligated party and an importer of renewable fuel, the company will generate RINs in its importer capacity and separate the RINs from the volume of imported fuel in its capacity as an obligated party. Is this activity considered
No transaction report is required for internal company transfers as all RINs are owned at the corporate level. The company would submit a RIN generation report for the RINs it generated for the imported renewable fuel and a compliance demonstration report to demonstrate compliance with its RVO. The company would also submit a quarterly gallon-RIN activity report.
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)