Upcoming Compliance Reporting Deadlines

All Obligated Parties and Exporters of Renewable Fuels must retire RINs and submit reports for compliance year 2013 by no later than March 1, 2016.

For Obligated Parties planning to use Cellulosic Waiver Credits for compliance – EPA has indicated that in order to calculate the quantity of Cellulosic Waiver Credits a company may purchase, the company should subtract the quantity of D3 RINs that are useable for that compliance year that they own as of the date the Obligated Party retires RINs for compliance from their Cellulosic Biofuels RVO. We suggest companies take a screen shot of their RIN holdings page in EMTS prior to retirement and provide a copy of that screen shot to their attestation service provider.

Other upcoming deadlines:

• Companies wishing to assert an Affirmative Defense claim related to the Gen-X and/or Southern Resources QAP-A RINs must submit an email to EPA no later than February 28th
• 4Q15 RFS reports are to be submitted to EPA no later than March 31st
• Annual gasoline compliance reports are to be submitted to EPA no later than March 31st 

NOTE:  Companies filing annual GSF and/or RFG reports should use the Unified Report Form and must enter their sulfur and benzene credit retire and generate transactions into EMTS by March 31st

If you have any questions relating to these compliance deadlines, please contact Sandra Dunphy at Sandra.dunphy@weaver.com.