Not necessarily. Obligated parties can only separate RINs they generated for renewable fuel they produced or imported up to the level of their RVO. They are not allowed to separate additional RINs that they generated. However, obligated parties must separate all RINs from renewable fuel that they own if they did not generate those RINs. See regulation Sections 80.1129(b)(1) and (b)(6).
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)