“One Big Beautiful Bill” Passed with Alterations to 45Z
On July 4, 2025, President Trump signed the “One Big Beautiful Bill Act” (OBBB), which originally started as House Bill H.R.1. This budget reconciliation bill included many notable changes to the Inflation Reduction Act of 2022 (IRA), including cancellation of most renewable energy incentives and environmental provisions and changes to the Clean Fuel Production Credit (CFPC), called 45Z after the section in the IRA. All changes in the act related to 45Z go in to effect on January 1, 2026.
There were two main changes to the bill that impact 45Z between the House approval and final enaction. Firstly, in the final version of the bill, the CFPC expiration is extended by two years, from December 31, 2027 to December 31, 2029, as opposed to the 4-year extension originally approved by the House. Secondly, the special credit rate for sustainable aviation fuel (SAF) was eliminated and negative emissions were explicitly excluded from consideration in credit calculation for all fuels except for animal manure-based RNG, meaning that the tax credit value is capped at $1 per gallon for all eligible liquid fuels, including SAF.
The OBBB also disallows specified foreign entities or foreign-influenced entities, currently including only current foreign adversaries of the US, from claiming 45Z tax credits. Additionally, renewable natural gas (RNG) producers will now have separate pathways for dairy, swine and poultry manure in order to maximize potential credit generation.
The “Big Beautiful Bill” also includes several provisions designed to support domestic production of crop-based feedstocks for low carbon fuels. The first is that while the IRA allowed for tax credit generation of all foreign feedstocks except for used cooking oil (UCO), the new act would restrict credit generation only to fuel made from feedstocks produced in the U.S., Mexico, or Canada. This will be a boon to domestic farmers as it is likely to push up the demand, and therefore cost, of North American produced soybean oil, canola oil, UCO and tallow.
Additionally, the proposed act explicitly disallows the consideration of indirect land use change from the calculated carbon intensity (CI) as part of the lifecycle analysis (LCA). Given that the credit value is based on how far below a baseline the fuel’s calculated CI is, a double-digit reduction in the CI for crop-based fuels would significantly increase the tax credit value for these fuels. This will be a huge win for corn ethanol, and soybean and canola oil based renewable diesel and biodiesel and thereby further incentivize the production of these feedstocks. This will also provide significant incentive to increase soybean crush capacity within the United States, which has been steadily growing in recent years.
At TRICORD, we have been monitoring the progression of changes to the IRA generally and 45Z specifically and have been keeping up with the latest news. We have experience calculating facility CI values using the Argonne GREET model, among others, and have helped renewable fuels producers to navigate this ever-changing landscape.
If you need support understanding the IRA rules and opportunities, please reach out to our renewable fuels team leader Hannah Losey, P.E. at Hannah.Losey@tricordconsulting.com.