Anyone can participate in the RIN trading program, subject to the requirement that the party first register with the EPA and then adhere to other regulatory requirements, including submitting required reports (such as quarterly reports on RINs held).
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)