Renewable fuel producers and importers may generate RINs for renewable fuel they own on September 1, 2007 that was produced or imported earlier, and must generate RINs for renewable fuel produced or imported on or after September 1, 2007. Thus at the beginning of the program, it is possible that some volumes of renewable fuel being transferred by a renewable fuel producer or importer may not have assigned RINs. However, this will not be the case in the longer term, since all renewable fuel imported or produced must have assigned RINs.
Question and Answer was originally posted at http://www.epa.gov/otaq/renewablefuels/420f07041a.pdf
Regulation Section 80.1126(d)(1), which says "must," seems in conflict with Section 80.1126(d)(2) which says "may". Is the correct reading that any volume of renewable fuel that leaves a producer's gate on or after 9/1/07 MUST have RINs assigned?
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