No, as long as the blender actually blends the renewable fuel into gasoline or diesel. In that case, the blender would be required to separate the assigned RINs from the blended renewable fuel, and could then transfer the RINs to any party without simultaneously transferring a volume of renewable fuel. See regulation Sections 80.1128(a)(3) and 80.1129(b)(2).

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)