This limit applies only to obligated parties. Under regulation Section 80.1127(a)(2), no more than 20% of the gallon-RINs used by an obligated party to meet its RVO can be previous-year RINs (having a YYYY code that is one year earlier than the year for which the RIN is being used to show compliance with an RVO).

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)