Understanding New Mexico CTFP Transactions Reporting

The New Mexico Environment Department Clean Transportation Fuel Program (NMED CTFP) officially went into effect on April 1, 2026.  This program aims to decrease the carbon intensity of transportation fuels used in New Mexico below a 2018 baseline by 20% by 2030 and 30% by 2040.  Like similar programs in California, Oregon and Washington, the program creates a marketplace where deficits generated from selling fuels with higher lifecycle emissions (such as fossil gasoline and diesel) are offset by credits generated from low carbon fuels (LCFs).  Covered entities currently participating in the New Mexico fuel market were required to submit their program registration applications by May 15, 2026.

Entities marketing fuels in New Mexico must have a clear understanding of which specific activities are regulated under the CTFP to accurately account for their program obligation.  Under the CTFP, a “regulated party” is defined as any person or entity that produces, imports or dispenses transportation fuel for use in New Mexico.  If your operations involve importing, producing, or selling regulated fuels such as gasoline, diesel, and renewable blends for use in New Mexico, you are subject to the program’s requirements and must track and report these transactions on a quarterly and annual basis.  The only exemption to this rule are companies who dispense fuel to end consumers only (i.e. gas stations).  In this case, the fuel importer is the obligated party under the program.

To manage program participation, NMED created the Clean Transportation Fuels Program Application, Reporting, and Compliance System (CTFP-ARCS), which serves as the official online portal for registration and quarterly transaction reporting.  Regulated parties must log their covered activities in CTFP-ARCS using specific transaction types to accurately determine their obligated volumes and calculate their total credits and deficits generated each quarter.  The transaction types and obligation impact under the CTFP are defined as follows, with a positive obligation impact indicating that the transaction increases a party’s deficit generating fuel volume balance when transacting fossil fuels and increases a party’s credit generating fuel volume balance when transacting renewable fuels.

• Produced in New Mexico: A regulated party produced a transportation fuel at a facility located in NM.  This activity is obligation positive.
• Produced for import into New Mexico: A regulated party imported a fuel produced out-of-state that was intended for import into NM.  This activity is obligation positive.
• Imported within the bulk system: A regulated party imported fuel into NM and placed it into the bulk system (refineries, pipelines, vessels, and terminals).  This applies to above-the-rack transactions.  This activity is obligation positive.
• Imported outside the bulk system: A regulated party imported fuel into NM and delivered it outside the bulk system.  This applies to below-the-rack transactions.  This activity is obligation positive.
• Purchased/Sold with obligation: A regulated party purchased or sold a fuel along with its compliance obligation or associated credits above-the-rack.   This activity is obligation positive for the buyer, and negative for the seller.
• Purchased/Sold without obligation: A fuel was sold above-the-rack with the compliance obligation or credits retained by the seller.  This activity is obligation neutral.
• Position holder sale without obligation: Fuel was sold below-the-rack without a transfer of the compliance obligation.  This activity is obligation neutral.
• Position holder sale for export: Fuel was sold below-the-rack to a person that exported it.  This activity is obligation negative.
• Purchased below the rack for export: A regulated party purchased fuel below-the-rack to export it.  This activity is obligation positive.
• Exported: Fuel that was initially reported under the CTFP but was later exported out of NM.  This activity is obligation negative.

The first quarterly report covering fuel transactions from April 1 – June 30, 2026, must be submitted in to ARCS by August 14, 2026.

At TRICORD, we have been closely monitoring the development of the NMED CTFP and have been in direct communication with NMED officials to understand reporting intricacies.  We were closely involved in the original rulemaking of the CTFP and have helped many fuel producers and importers understand this new program.  We have extensive experience navigating all U.S. state low carbon fuels programs and can provide expert assistance in managing your compliance strategy, determining correct transaction types, and fulfilling your reporting requirements in ARCS. 

If you need support understanding the NMED CTFP and how it applies to your operations, please reach out to our low carbon fuels team leader Hannah Losey, P.E. at Hannah.Losey@tricordconsulting.com.