The EPA’s proposal to drop “eRINs” – Renewable Identification Numbers tied to renewable electricity — from the Renewable Fuel Standard (RFS) has certainly caught the attention of the biofuel and clean‑energy community. Though it might look like a minor tweak, this change could reshape how electric transportation pathways and biogas fit into the RFS. Here at RINSTAR, we’ve been following the story closely and have previously reported on the proposal.
Understanding eRINs and Their Proposed Role
To understand why the removal of eRINs matters, it helps to look back at what they were originally intended to do in 2022. The idea behind eRINs came about as the EPA looked for ways to include the growing electric vehicle sector within the RFS framework. The plan was to generate RINs when qualified biogas—like that from landfills, wastewater treatment plants, or agricultural waste—was used to produce renewable electricity, which would then power electric vehicles (EVs). Under the original proposal, electric vehicle manufacturers (OEMs) would have been the main eRIN generators, based on how much renewable electricity their fleets consumed. The goal was to encourage both more biogas production and broader EV adoption, in line with the RFS’s mission to cut greenhouse gas emissions and strengthen energy security.
The EPA’s Shift: Why eRINs Were Pulled
Even with strong stakeholder interest, the passage of the BRRR, and growing investments in RNG and biogas, the EPA, under the Trump Administration, is now considering removing eRINs from the RFS program. In its latest rule setting RFS volume requirements for 2026 and 2027, the agency explained that this shift is based on its reading of Congressional intent. According to the EPA, the RFS, as outlined in the Clean Air Act, was originally designed to focus on liquid renewable fuels with no clear mention of electricity.
The agency believes including electricity may stretch the original goals and scope of the program, which aimed to support rural economies and liquid biofuel production. They also pointed to the complexity of the proposed eRIN structure, the mixed feedback from stakeholders, and the need for more time to sort through the details. While eRINs had been considered and even given a proposed start date of January 1, 2024, the EPA has never actually authorized their generation—making this a significant, but not entirely unexpected, policy turn.
Impacts on Electric Pathways and Decarbonization
The removal of eRINs has several implications for the trajectory of electric pathways in decarbonizing transportation:
- Reduced Incentive for Biogas-to-Electricity: One of the main goals of eRINs was to create a market boost for turning biogas into renewable electricity for use in transportation. Without eRINs, there’s less financial motivation for producers to send that renewable electricity specifically into the transportation sector, which could make it harder for biogas to compete in the RFS marketplace.
- The conscious uncoupling of RFS and EV Adoption: While the RFS continues to play a major role in supporting renewable liquid fuels, removing eRINs means it won’t directly encourage electric vehicle (EV) adoption or the use of renewable electricity in EVs. That said, other policies, like federal tax incentives and state-level programs, will still help move EV adoption forward.
- Uncertainty for Future “Power-to-X” Fuels: As we look ahead, there’s growing excitement about “power-to-X” fuels—where renewable electricity is used to create synthetic options like hydrogen, ammonia, or sustainable aviation fuels. The eRIN discussion brought attention to how (or if) the RFS might eventually include these newer technologies. With this latest move, it looks like any future expansion into these areas might need fresh legislation rather than changes within the current RFS framework.
RFS Credibility and Future Direction
Beyond the direct impact on electric pathways, the eRINs chain of events also reveals some longstanding tensions in the RFS:
- Balancing Congressional Intent with Today’s Energy Needs: The EPA’s focus on “Congressional intent” brings up an ongoing challenge—how to reconcile the original goals of the RFS, written back in 2005 and 2007 with today’s fast-moving world of renewable energy technology. Some critics worry that sticking too closely to the original language could limit the RFS’s ability to stay relevant and impactful in a more diverse and innovative energy landscape.
- The EPA’s Role in Shaping the Program: The discussion around eRINs also highlights just how much influence the EPA has in shaping the RFS. While the agency sets annual renewable volume obligations (RVOs), its interpretations—like what qualifies as a “renewable fuel”—can significantly affect the market. The decision to remove eRINs suggests that major changes to the RFS may need to come directly from Congress, rather than through regulatory updates alone.
- Staying Focused on Liquid Fuels: Ultimately, removing eRINs signals that the RFS will continue to center around liquid biofuels. This means we’ll likely see future investment and innovation focused on fuels like corn ethanol, biodiesel, and renewable diesel, rather than expanding the program to cover broader forms of renewable energy used in transportation.
As the renewable fuels landscape continues to evolve, understanding the implications of regulatory changes like the removal of eRINs is more important than ever. While the EPA’s decision marks a return to the RFS’s traditional focus on liquid fuels, it also raises broader questions about how federal policy will adapt to emerging technologies and decarbonization strategies. At RINSTAR, we’re committed to helping stakeholders navigate these changes with clarity and confidence. Whether you’re a producer, blender, or investor in renewable energy, our team is here to provide insights, support compliance, and guide you through the shifting policy environment. Stay connected with RINSTAR as we continue to track developments.
How RINSTAR Can Support You
With over 15 years of experience in Renewable Fuel Standard (RFS) compliance, RINSTAR has guided clients through shifting regulations, policy uncertainty, and evolving market demands. Our platform is designed to streamline RIN tracking, inventory control, and regulatory reporting—giving you the clarity and confidence to stay compliant and competitive.
👉 Explore how RINSTAR simplifies RFS compliance
Stay Ahead of the Curve
The removal of eRINs signals a pivotal moment for the renewable fuels industry. As policies evolve, staying informed is key. Subscribe to our newsletter and follow our blog for timely updates on:
- RFS regulatory developments
- Emerging fuel pathways
- Compliance best practices
- Market trends impacting biofuels and RNG
Need Help Navigating the Changes?
If you have questions about how these regulatory shifts may impact your operations, we’re here to help. Reach out to us at services@cfch.com or schedule a personalized RINSTAR demo today.