The EPA exempted 1.76 billion Renewable Identification Numbers for small refineries in 2025, granting full exemptions to 18 refineries and partial exemptions to 11 others, while pledging to reallocate the difference into 2026-2027 obligations to protect renewable fuel standards.
- EPA granted full exemptions to 18 small refineries, partial exemptions at 50% to 11 refineries, denied 3 petitions, and deemed 2 ineligible under the 2025 Renewable Fuel Standards program
- The 1.76 billion RINs exempted exceeded the agency's initial estimate of 990 million RINs due to increased petitions and changed financial circumstances
- EPA will reallocate 100% of exempted volumes into 2026-2027 Renewable Volume Obligations to maintain renewable fuel market integrity
- Compliance deadline extended by 30 days to October 1, 2026 to allow proper market adjustment for additional RINs
- Industry groups remain divided: renewable fuel advocates question refinery hardship claims while supporting reallocation, citing record refinery earnings
The U.S. Environmental Protection Agency announced decisions on 34 small refinery exemption petitions under the Renewable Fuel Standards program for 2025, exempting 1.76 billion compliance credits known as Renewable Identification Numbers.
Working with the U.S. Department of Energy, EPA reviewed information from each petitioning small refinery and evaluated the requests according to the Clean Air Act and case law.
The agency granted full exemptions to 18 small refineries, partial exemptions at 50% to 11 refineries, denied three petitions and deemed two ineligible.
EPA will propose to reallocate 100% of the difference between projected and actual exempted volumes for 2025 into the 2026 and 2027 Renewable Volume Obligations before the end of October 2026.
The agency will also announce a direct final rule extending the 2025 RVO compliance date by 30 days to October 1, 2026. This extension will allow the market to account for the additional RINs properly.
EPA had estimated that 990 million RINs would be exempted in 2025 based on its methodology using a three-year average. The agency exempted more RINs than estimated because more small refineries requested exemptions and financial circumstances changed.
Industry groups expressed disappointment with the volume of exemptions while praising the reallocation plan.
“While we continue to believe most of the SREs issued today are completely unjustified, we are somewhat encouraged that EPA is taking steps to minimize the damage through reallocation,” said Geoff Cooper, president and CEO of the Renewable Fuels Association.
Emily Skor, CEO of Growth Energy, questioned whether refiners met the legal threshold for exemptions.
“Our position hasn’t changed—SREs should only be granted when refiners can prove disproportionate economic hardship,” Skor said. “It’s difficult to see how these refiners have met this threshold when they’re simultaneously reporting sky-high and, in some cases, record-setting earnings.”
Jed Bower, president of the National Corn Growers Association, said reallocation is necessary to protect farmers and consumers.
“While we are disheartened by the high number of SREs that are being granted to exempt small refineries from meeting federal blending requirements, we are thankful that the Trump administration is taking action to offset this development by pledging to reallocate these RINs,” Bower said.
Devin Mogler, president and CEO of the National Oilseed Processors Association, said Congress played a critical role in securing the reallocation commitment.
“We remain disappointed by the sheer volume of these refinery exemptions and the uncertainty they have injected back into the market,” Mogler said. “But restoring waived gallons to the established RFS volumes is critical to sustaining domestic growth, creating stronger markets for American farmers, and reducing our reliance on China.”
Kurt Kovarik, vice president of federal affairs at Clean Fuels Alliance America, said biodiesel and renewable diesel producers have been working to meet record RFS volumes.
“We’re hopeful that today’s action won’t reverse the progress we’ve made and that our industry can maintain faith in the RFS program,” Kovarik said.
DOE is evaluating how it has used its 2011 disproportionate economic harm methodology and what information is needed for future small refinery petitions to account for current market circumstances in this new phase of the RFS program.
EPA noted concerns about inaccurate reporting on the agency’s RFS actions that have contributed to significant market movements and RIN market volatility. The agency continues working with the Commodity Futures Trading Commission to ensure compliance with federal laws and protect the integrity of the RIN market.
