In the world of the RFS, accuracy and accountability are everything. Every RIN represents not just a credit but a compliance commitment. To ensure transparency and protect program integrity, the EPA requires rigorous third-party reviews and audits at multiple stages. From engineering reviews to annual attest engagements and voluntary Quality Assurance Plans (QAPs), these checks help keep the renewable fuel market reliable and fair.
Engineering Reviews (§80.1450)
Before a renewable fuel facility can generate a single RIN, it must undergo an engineering review performed by an independent professional engineer (PE). This review verifies that the producer’s feedstocks, production methods, and resulting fuel type align with an EPA-approved pathway as outlined in 40 CFR 80.1450(b)(2).
The engineer conducts an on-site inspection and reviews technical documentation to confirm that the facility can physically produce the fuel it claims. This review must be renewed every three years or sooner if the facility makes significant changes to feedstocks or production processes.
Annual Attest Engagements (§80.1464)
Once production begins, renewable fuel producers, importers, obligated parties, and exporters must complete annual attest engagements. These third-party audits (performed by a Certified Public Accountant (CPA) or Certified Internal Auditor) verify that what was reported to the EPA accurately reflects what occurred at the facility.
During the review, auditors verify RIN generation and transaction data by cross-referencing them with supporting documentation such as contracts, invoices, and production records. The final report is submitted to the EPA by June 1 of the following year and details any discrepancies found, in accordance with 40 CFR §80.1464
The Quality Assurance Program (QAP)
Even with mandatory reviews and attestations, the EPA recognized that RIN fraud and clerical errors could still occur. To address this, the Quality Assurance Program (QAP) was created as an optional but powerful safeguard.
Under a QAP, producers can work with an independent, EPA-approved auditor to apply ongoing, quarterly oversight of their operations. Auditors review everything from feedstock sourcing and fuel processing to RIN generation and shipment verification. RINs verified under this program are designated as Q-RINs.
For buyers, Q-RINs offer a valuable advantage. If a Q-RIN is later found to be invalid, downstream parties that purchased it in good faith are shielded from liability under the affirmative defense outlined in §80.1473. This protection makes Q-RINs a preferred option for obligated parties seeking compliance certainty.
The Auditors
Third-party auditors play a critical role in maintaining trust within the RFS program. To ensure their independence, the EPA enforces strict rules under §80.1471. Auditors cannot be owned or controlled by the company they audit, have any financial interest in the outcome, or trade RINs themselves. They are also barred from seeking future employment with audited companies during their engagement.
If an auditor identifies potentially invalid RINs, they must notify both the EPA and the producer within five business days. Failing to do so, or failing to maintain proper audit standards, can expose the auditor to regulatory penalties.
The RFS compliance ecosystem relies on trust, verification, and accountability at every step. From initial engineering reviews to attest engagements and QAP audits, each safeguard helps protect the integrity of RINs and the broader renewable fuel market.
At RINSTAR, we understand that managing documentation and staying current with EPA requirements can be complex. That’s why our platform simplifies the entire process. We organize your RIN data, support documentation, and gather RIN transactional history in one secure, easy-to-navigate system. Whether you’re preparing for your next attest engagement or maintaining a QAP, RINSTAR ensures you’re audit-ready and compliant every step of the way.
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