For Obligated Parties or Renewable Fuel Exporters wishing to retire 2010 RFS2 RINs now to replace possibly invalid RINs (other than Clean Green Fuel RINs) used for 2010 compliance - please note the following:
You cannot remove or delete 2010 RFS2 RINs already used for 2010 compliance, however you can retire additional 2010 RFS2 RINs to cover volumes of RINs that you feel might be invalid. Here's what EPA recommends:
- In EMTS, under Retire - Other, use code 130
- Indicate the volume of RINs you are retiring and the original producer of the RINs that you used for 2010 compliance that you are replacing. For multiple producers, retire RINs in separate groups.
- KEEP IN MIND THAT ONCE YOU RETIRE EXTRA 2010 RINs (FOR 2010 COMPLIANCE), YOU CANNOT "UNRETIRE" THEM IF EPA DOES NOT DECLARE THE ORIGINAL RINs USED TO BE INVALID.
Questions? Call Sandra Dunphy at 832-320-3218 or email: Sandra.Dunphy@WeaverLLP.com