The Renewable Fuels Association submitted comments (Oct. 31, 2025) to the U.S. Environmental Protection Agency in response to its supplemental proposal addressing reallocation of biofuel blending volumes lost to small refinery exemptions under the Renewable Fuel Standard.
RFA praised EPA for taking steps to protect market integrity by returning expired renewable identification numbers (RINs) to refiners that were granted exemptions for 2016-2022, years for which compliance is now closed. For the 2023-2025 compliance years, however, the association strongly urged EPA to reallocate 100 percent of exempted renewable fuel volumes, given the agency’s statutory obligation to ensure that finalized blending requirements are met. Additionally, RFA reiterated its position that EPA must prospectively reallocate exempted volumes anticipated for 2026 and 2027.
At the same time, RFA expressed serious concern with the agency’s continued reliance on an outdated and flawed Department of Energy study to evaluate petitions for small refinery exemption, and the association urged EPA to take a more modern, transparent, and data-driven approach going forward.
“RFA appreciates EPA’s recognition that a strong RFS is crucially important to rural America, and we applaud the decision to return expired RINs to exempted refiners for RFS compliance years that are already closed,” said RFA President and CEO Geoff Cooper. “However, it is critically important that EPA reallocate 100% of exempted volumes for compliance years that are still open and for future years, and we remain deeply concerned about EPA’s reliance on a 14-year-old Department of Energy study that no longer reflects the realities of today’s energy and fuels markets. If EPA returns ‘live’ RINs to small refiners for their 2023-2025 exemptions and then fails to reallocate those volumes, the effects on RIN values and biofuel marketplace could be catastrophic. Some refiners have shown over and over again that they will comply with the RFS by turning in cheap RINs rather than blending physical volumes of renewable fuel.”
RFA emphasized that EPA should modernize its evaluation process for exemption petitions by using current market data, transparent metrics, and rigorous economic analysis when determining claims of “disproportionate economic hardship.” According to the association, doing so would help ensure a more level playing field across the refining sector and protect the integrity of the RFS program.
EPA issued the supplemental proposal in connection with its earlier proposed rule setting the 2026 and 2027 RFS volume obligations.
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