Ethanol imported for use as motor vehicle fuel would typically be downloaded from a ship into on-shore tankage and then denatured. (Ethanol shipped to the United States from other countries is not typically denatured prior to or during shipment.) Importers should generate RINs for imported ethanol when the denaturant is added at the off-loading tankage. Thus, the facility number used to create these RINs would be the tankage facility where the denaturant is added. See also question 2.2.
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)