In a letter sent today to U.S. EPA Administrator Michael Regan, the Renewable Fuels Association asked for an update on the agency’s investigation of certain biofuel feedstock imports and urged the adoption of more stringent feedstock verification requirements for imported used cooking oil and tallow.

“The recent surge in imports of questionable used cooking oil (UCO) and tallow for biomass-based diesel (BBD) production is suppressing demand and values for domestically produced feedstocks like distillers corn oil and soybean oil, as well as the crops from which those oils are derived,” wrote RFA President and CEO Geoff Cooper, noting that monthly tallow and UCO imports combined have jumped twelvefold since January 2021. 

“Today, nearly one out of every six gallons of U.S.-produced BBD is made from imported UCO or tallow—most of which comes from China and Brazil, two countries that maintain punitive import tariffs on U.S. biofuels.”

In early August, EPA confirmed that it was conducting audits of supply chain documentation for certain imported feedstocks, including UCO, used to produce renewable fuel and generate credits under the Renewable Fuel Standard. Since then, there has been no word from the agency about the outcome of the audits.

“In the event that EPA has completed its investigation, we respectfully ask that the Agency publicly share its findings and information regarding any corrective actions being taken,” Cooper wrote. “If the audits are not yet complete, we ask that the Agency share an update with the public on its progress and an estimated timeline for completion.”

Cooper stressed RFA’s concerns that current regulations, especially recordkeeping requirements, are overly lax and “are insufficient to assure the legitimacy of certain imported waste oils, fats, and greases.” RFA called on EPA to engage a standards developing organization to develop test methods to conclusively and quickly differentiate various fats, oils, and greases, just as EPA requires for the differentiation of co-processed starch and cellulosic feedstock from in situ ethanol fermentation. He concluded:

“Without action by EPA to tighten its verification and recordkeeping requirements, the deluge of questionable imports of UCO and tallow not only threaten to inflict further economic harm on U.S. farmers and biofuel producers, but also to undermine the integrity of the RFS program.”