NATSO Testifies on EPA’s Proposed 2026 and 2027 Renewable Volume Obligations
NATSO testified before the Environmental Protection Agency (EPA) July 8 that fuel retailers view the proposed 2026 and 2027 renewable volume obligations (RVOS) as a positive signal for biofuel investments but cautioned against creating winners and losers, which could lead to unintended market consequences.
EPA in June 2025 issued its proposed renewable volume obligations for 2026 and 2027 under the Renewable Fuel Standard (RFS). EPA has proposed to require 24.02 billion Renewable Identification Numbers (RINs) of renewable fuel in 2026, and 24.46 billion RINs in 2027. EPA is also proposing to partially waive the 2025 mandate for cellulosic biofuel.
EPA Proposes 2026 and 2027 Renewable Volume Obligations
The RFS prompts truck stops, travel centers and fuel retailers to incorporate biofuels into their diesel supply as a means of lowering prices for consumers and gaining market share. NATSO’s members constitute approximately 90 percent of retail sales of diesel fuel in the United States, including virtually all retail sales of biodiesel and renewable diesel fuels that are incentivized under the RFS.
“We support this trajectory and are grateful that the Agency appears to be keeping the RFS program on track for continued positive growth in the years ahead,” NATSO testified at the July 8 public hearing. “As surrogates for the consumer, we are always mindful of the impact that the RFS will have on our customers.”
NATSO cautioned that as drafted the RVO proposal would provide less benefit to importers of finished biofuel and feedstocks, leading to higher fuel costs and emissions in the coastal markets that are served by these products. NATSO also encouraged the agency to reject small refinery exemption petitions because all refiners, regardless of size, embed the RVO costs into their crack spread.
NATSO further encouraged EPA to either obligate petroleum jet fuel under the RFS or preclude renewable jet fuel from generating renewable identification number (RIN) credits. Producers of renewable jet fuel generate RINS for every gallon they produce, but petroleum jet fuel producers do not acquire an RVO. This imbalance results in fewer gallons of biofuel being produced and at a higher cost for consumers.
NATSO will file comments on the proposed rule by August 8, 2025.
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