EPA’s Proposed RFS Rules are Refreshingly “Bold” and “Pragmatic”
On June 17, 2025, EPA published its proposed rule changes to the Renewable Fuel Standard (RFS). Public comments are due on August 8, 2025, and with the changes EPA “seeks to get the RFS program back on track by establishing renewable fuel volumes for 2027 by the statutory deadline” which indicates that they plan to finalize the rule by November 30, 2025.
In addition to proposing the applicable volumes and percentage standards for 2026 and 2027 for cellulosic biofuel, biomass-based diesel (BBD), advanced biofuel, and total renewable fuel, EPA also proposes several regulatory changes to better align the RFS with the administration’s policy and streamlining objectives. The following three directional changes appear to return the RFS to its roots as a “liquid fuels” mandate.
First, EPA affirms its ongoing support for the RFS program by proposing an impressive 67% annual increase in the volume of BBD in 2026 and an additional 4.5% increase in 2027, finally acknowledging the much increased domestic and foreign supply of renewable diesel over the last several years.
Second, EPA proposes to reduce the number of Renewable Identification Numbers (RINs) generated for imported renewable fuel and renewable fuel produced from foreign feedstocks. By doing so, EPA refocuses the RFS to its statutory goals of increasing energy independence and energy security. The increased volume requirements, coupled with a new restriction of 50% less RINs generation for imported renewable fuel and feedstocks, reflect the significant growth potential for renewable fuel production in the U.S. using domestic feedstocks, particularly within the BBD category. Recognizing the significant impact of the import fuel/feedstock RINs restriction for 2026 and 2027 BBD volumes as 1.27 and 1.28 RINs per gallon respectively, down from 1.6 RINs per gallon in 2025, EPA’s projections indicate an implicit 25% upside for domestic BBD renewable fuel and feedstocks. Even for the other three renewable fuel categories listed above, this new restriction for import fuel and feedstocks is likely to create modest growth opportunities for domestic production and feedstocks.
Third, EPA is removing renewable electricity as a qualifying fuel under the RFS, once again confirming its primary role as a liquid fuels mandate.
In addition to the three major changes listed above, EPA proposes a few more that will streamline and simplify the regulations, such as:
- Converting the BBD volume requirement from physical gallons to RINs, consistent with the other three renewable fuel categories;
- Finalizing the equivalence values of renewable diesel at 1.6, renewable naphtha at 1.4, and renewable jet fuel at 1.6 which fairly settles previous discussions regarding the fossil-derived hydrogen content in such hydrotreated fuels;
- Approving a partial waiver of the 2025 cellulosic biofuel volume requirement;
- Updating existing renewable fuel pathways and adding new ones;
- Establishing enhanced regulatory controls to ensure the authenticity of domestic feedstocks not impacted by the new 50% RIN reduction requirement for foreign feedstocks; and,
- Projecting a range of percentage standards for 2026 and 2027 based on the maximum potential small refinery exempted volume of gasoline and diesel (G+D) of 18 billion gallons.
At TRICORD, we closely monitor the progression of all low carbon fuels regulations on behalf of our clients, including the EPA RFS, Canada CFR, State LCFS programs. If you need support understanding or analyzing any of these regulatory programs and associated opportunities, please reach out to our low carbon fuels team leaders Hannah Losey, P.E. at Hannah.Losey@TRICORDconsulting.com and Deepak Garg, P.E. at Deepak.Garg@TRICORDconsulting.com.
