Fuel Only Sales Record Keeping and Compliance

Are you selling neat fuel without RINs downstream? If so, are you keeping up with RFS compliance requirements? If the company you are selling the neat fuel to is going to blend into transportation, heating oil, or jet fuel (the blender on record), a “fuel only” product transfer document should be sent to that party indicating that only fuel was transferred to the other party, no RINs. After the transaction, your company’s fuel volume inventory has decreased, but the RIN volume remains the same – changing your account’s ratio of RINs to fuel volume. If your company is a blender on record and blends other volumes of fuel, the RINs may be separated up to a 2.5 ratio at the time of each blend. If your company does not blend volumes of renewable fuel to be able to separate these additional RINs, then the RINs can be assigned to another downstream partner at a higher ratio. Example: biodiesel transactions typically are sent at a 1.5 ratio (8000 gal/12,000 RINs), you can send up to 2.5 RINs with one load: 8000 gal/20,000 RINs. 

If the neat fuel you are sending downstream will be “designated” as transportation, heating oil, or jet fuel or used “as is” without RINs, then your company may separate the RINs upon selling the fuel.

The Alternative Fuels Council RIN management system provides fuel only PTD generation and record keeping for these types of scenarios to help keep you organized and in compliance.