If X Company takes ownership of ethanol along with assigned RINs, it would be required to register with the EPA and would be subject to the recordkeeping, reporting, product transfer document and attest engagement requirements of regulation Sections 80.1151(d), 80.1152(c), 80/1153 and 80.1164(c).

The tracking required under the RFS rule involves only transfers of title (ownership), not transfers of custody. If X Company never takes ownership of ethanol with assigned RINs and does not participate in other ways in the RFS program (for example, through the purchase and sale of unassigned RINs), it would not be required to register with, or report to, EPA under the RFS program.

Question and Answer was originally posted at: Questions and Answers on the Renewable Fuel Standard Program (PDF) (55 pp, 221 K, EPA420-F-07-041a, August 2007, About PDF)