Marketers who buy and sell renewable fuel without blending it into gasoline or diesel cannot separate RINs from volumes, and thus cannot change the K code from 1 to 2. All conditions under which a party can separate RINs from volumes are set forth in regulation Section 80.1129(b).
However, a marketer can indeed decide not to transfer a particular RIN with a volume of renewable fuel so long as the end-ofquarter check described in regulation Section 80.1128(a)(5) is fulfilled.
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)