It may be the case that some ethanol blended into gasoline at the beginning of the program will not have assigned RINs. However, the RVO is determined annually, not quarterly or monthly, and in general ethanol purchased after September 1, 2007 will have assigned RINs.
Obligated parties can also acquire RINs in the first few months of 2008 that can be used to demonstrate compliance with their 2007 RVO.
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)