RIN registration deadline approaches

By Anduin Kirkbride McElroy | August 03, 2007
The National Biodiesel Board (NBB) hosted a webinar July 11 to educate its members on compliance with the federal renewable fuels standard (RFS), which takes effect Sept. 1, 2007, and requires all renewable fuel production facilities, refiners, importers and exporters to register with the U.S. EPA by that date.

According to Scott Hughes, director of governmental affairs for the NBB, 120 participants attended the three-hour webinar, which discussed the various biodiesel industry regulations about to take effect. Upon EPA registration, companies will receive a four-digit company identification number. Some companies may already have an identification number through registration under the Motor Vehicle Diesel Fuel Sulfur program; reregistration isn't required for these companies.

The registration form is short, but the compliance, recordkeeping and reporting are more complicated. "Compliance is demonstrated through the acquisition of unique renewable identification numbers (RINs) assigned by the producer or importer to every batch of renewable fuel produced or imported," the EPA stated in the final ruling issued in May. "The RIN shows that a certain volume of renewable fuel was produced or imported. Each year, the refiners, blenders and importers obligated to meet the renewable volume requirement must acquire sufficient RINs to demonstrate compliance with their volume obligation. RINs can be traded, thereby functioning as the credits envisioned in the [Energy Policy Act of 2005]."

Each 38-character RIN stays with the batch of fuel as it is transported. This trading program will allow renewable fuels to be used where they are most economical while providing a flexible means for obligated parties to comply with the standard, according to the EPA.

When the RFS goes into effect in September, the trading of renewable fuel is considered a regulated activity. RINs must be generated for all renewable fuel produced or imported on or after this date. Producers and importers of renewable fuel can also generate RINs for product in inventory on the start date. At that time, recordkeeping and reporting requirements also begin, with the first report due to the EPA on Nov. 1, 2007.

"Owning RINs, and engaging in any activities regarding RINs, is prohibited as of Sept. 1, 2007, unless the party has registered and received EPA company and facility identification numbers," the EPA said. The association also encouraged timely registration because the generation of RINs and the handling of transactions involving RINs is prohibited without a confirmed registration.

The NBB has information about the RFS available on the "Members Only" section of its Web site at www.biodiesel.org. Presentations, talking points, background information and papers are included under the federal regulatory section of the site. Details about the final ruling and links to the EPA registration forms can be found at www.epa.gov/otaq/renewablefuels.
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