No. PTDs are not required when transferring unassigned RINs. However, PTDs are required whenever there is a transfer of ownership of a renewable fuel. Where the fuel is being transferred with assigned RINs, then the PTD must include information relating to the RINs. See section 80.1153 of the regulation. If the renewable fuel is being transferred without the RINs, then the PTD must state "no RINs transferred."

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)