As an ethanol producer or importer, you may assign RINs to the product you own on September 1, 2007. As far as how to handle the facility identification number fields in the RIN, you will want to consistently document and assign the other 50,000 RINs to one of your registered facilities as of September 1, 2007.

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)