This page provides instructions for letters that a company may use for submitting specific registration requests for Fuel Programs. These registration actions cannot be entered in EPA’s Central Data Exchange (CDX) Fuel Programs registration system (OTAQREG).

• General instructions
• Letter to terminate a delegated user or agent company association
• Letter to deactivate a company's registration in Fuel Programs
• Written statement for quarterly upward RIN delegation

General instructions

• Letters must be on company letterhead and have the wet ink signature of the Responsible Corporate Officer when applicable.
• Send all paperwork to: EPA's Fuel Programs Mailing Addresses
• These procedures are not inclusive of all registration situations; other registration actions may require additional documentation.
• Prior to shipment, you may scan your completed registration materials and attach the electronic copies with shipment tracking information in an email to Fuel Programs Support: FuelsProgramSupport@epa.gov.

Letter to terminate a delegated user or agent company association

Letter from RCO

1. Fuel Programs staff can edit only Fuels Programs registrations. Please contact the CDX helpdesk for help editing other EPA programs.
2. To request an immediate termination (e.g., a compromised account), the RCO should notify the EPA by sending the hardcopy letter and then sending a scanned copy of the signed letter in an email with the subject "EMERGENCY EMPLOYEE REMOVAL" to Fuel Programs Support: FuelsProgramSupport@epa.gov.
3. In the letter, please state:
   • "I am requesting that EPA remove the user association in CDX OTAQREG for [insert user name and user CDX ID] with [Company name and Company ID] and lock the user's EMTS and/or DCFUEL access (if applicable). Please remove this user's access to the following program services: [Names of all CDX program services for which access should be removed.] user currently uses or has used on my company's behalf."

Letter from user

1. A user may submit a letter to terminate his or her association with a company.
2. In the letter, please state:
   • "I am requesting that EPA remove the user association in CDX OTAQREG for [insert user name and user CDX ID] with [Company name and Company ID]. Please remove my access to the following program services: [Names of all CDX program services for which access should be removed.] I understand that the Fuels Programs staff will not contact CDX on my behalf and it is my responsibility to contact any other CDX application I currently use or have used on this company's behalf."

Note: To cancel the CDX account entirely, the user should contact the CDX Helpdesk: helpdesk@epacdx.net. Do not cancel the CDX User Account without first terminating the company association in OTAQREG.

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Letter to deactivate a company's registration in Fuel Programs

• Before deactivating a company, please take note of the reporting and recordkeeping requirements as provided in Title 40 CFR Part 80. 
• Please note, once a company is no longer active in OTAQREG, EMTS and DCFUEL, the company’s RINs will not be accessible for transactions. Additionally, reports will not be available for document retrieval by associated CDX user accounts.
• Deactivated companies cannot own RINs. The company will need to transfer any RINs the company owns to another company or wait for those RINs to expire per Title 40 CFR 80.1428(c): RIN expiration. Except as provided in § 80.1427(a)(7), a RIN is valid for compliance during the calendar year in which it was generated, or the following calendar year. Any RIN that is not used for compliance purposes for the calendar year in which it was generated, or for the following calendar year, will be considered an expired RIN. Pursuant to § 80.1431(a), an expired RIN will be considered an invalid RIN and cannot be used for compliance purposes.
• Please be aware that waiting for the RINs to expire may result in additional reporting obligations (including quarterly reports and attest engagements) as opposed to the alternative of transferring RINs to another company.
• Specific reporting instructions for the Renewable Fuel Standard:
  • Per Title 40 CFR Part 80 Subpart M Section 80.1451, any party that generates or owns RINs in a calendar quarter must report to EPA for that quarter. How to report quarterly and annually for the Renewable Fuel Standard.
  • Per Title 40 CFR Part 80 Subpart M Section 80.1464, if a party owned RINs during a compliance year, an attest engagement is required under RFS2 regulations. For more information on attest engagements, please refer to the following web page: How to report Attest Engagements
• In the letter, please state:
  • Company name and company ID;
  • Responsible Corporate Officer's name and title (If the Responsible Corporate Officer information does not match the CDX OTAQREG system, please include the prior RCO's name and the date when the change occurred);
  • The request to no longer be registered in the EPA Fuel Program(s);
  • That the entity is no longer conducting regulated business activities that require reporting, the dates that regulated activities ceased, and reports submitted [quarter, reporting year and report form names]; 
  • When any additional required documents (e.g., attest engagement) were, or will be, submitted. If applicable, please include any change in ownership information along with the contact information of the new owner; and
  • Effective date for the company registration to become inactive.

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Written Statement for Quarterly Upward RIN Delegation

The following letters are for blenders and delegated parties registered for upward delegation per Title 40 CFR 80.1440.

Letter for Delegating Party 

I, «Insert RCO name», «Insert RCO Title», of «Insert Company Name and EPA ID» as a registered small blender under Title 40 CFR 80.1440, delegate RIN-related responsibilities to «Insert Delegated Company Name and EPA ID» for «Insert Reporting Quarter and Reporting Compliance Year». Both parties understand their individual responsibilities as they relate to the provisions of Title 40 CFR 80.1440.

By signing this statement, I «Insert RCO name» certify the truthfulness and accuracy of the information in this delegation letter and I accept full responsibility for the information that «Insert Delegated Company Name» submits on my behalf to the Environmental Protection Agency. In the event that I terminate this relationship I will notify the EPA within 30 days. In the event my duties cease as Responsible Corporate Officer, so does this delegation and the new Responsible Corporate Officer must establish his/her own delegation for «Insert Delegating Company Name».

Letter for Delegated Party

I, «Insert RCO name>>, «Insert RCO Title», of «Insert Company Name and EPA ID» as a registered RIN Owner under Title 40 CFR 80.1440 accept delegation of  RIN-related responsibilities from «Insert Delegating Company Name and EPA ID» for «Insert Reporting Quarter and Reporting Compliance Year». Both parties understand their individual responsibilities as they relate to the provisions of Title 40 CFR 80.1440.

By signing this statement, I «Insert RCO name» certify the truthfulness and accuracy of the information in this delegation letter and I accept full responsibility to submit information to the Environmental Protection Agency on the behalf of «Insert Delegated Company Name». In the event that I terminate this relationship I will notify the EPA within 30 days. In the event my duties cease as Responsible Corporate Officer, so does this delegation and the new Responsible Corporate Officer must establish his/her own delegation for «Insert Delegated Company Name».

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