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Repair Windows errors before they cause bigger problemsFix Now →Scan for outdated or missing drivers - takes under a minuteDriver Scan →Clear out junk files and repair common Windows errorsFree Scan →EPA’s final applicable biomass-based diesel (BBD) volumes are 9.07 billion RINs for 2026 and 9.20 billion for 2027. Those are regulatory compliance volumes, not forecasts of how many D4 RINs the market must generate. In a separate balance-sheet analysis, Todd Hubbs and Scott Irwin estimate required net D4 generation of 10.99 billion in 2026 and 11.89 billion in 2027, partly because projected D6 shortfalls add demand for D4 credits.
What EPA set for 2026 and 2027
EPA’s final Renewable Fuel Standard (RFS) rule sets the BBD obligation. The base BBD requirements are lower than the final applicable volumes because EPA adds reallocated small refinery exemption (SRE) volumes. EPA reports the figures below in billion RINs; its table notes that one RIN represents one ethanol-equivalent gallon of renewable fuel.
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| Compliance year | Base BBD requirement | SRE reallocation | Final applicable BBD volume |
|---|---|---|---|
| 2026 | 8.86 billion RINs | 0.21 billion RINs | 9.07 billion RINs |
| 2027 | 8.95 billion RINs | 0.25 billion RINs | 9.20 billion RINs |
The final rule reallocates 70 percent of relevant actual exempted obligations for 2023 and 2024, plus projected exempted obligations for 2025. The reallocation is already reflected in the applicable totals above; it should not be added a second time.
Why modeled D4 generation is higher than the BBD RVO
A BBD RVO and a modeled estimate of net D4 RIN generation answer different questions. The RVO is EPA’s applicable regulatory volume. The D4 figures below are Hubbs and Irwin’s estimates of the net D4 generation needed in their balance-sheet analysis, which accounts for demand across the RIN categories they model.
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| Year | Required net D4 generation estimated by Hubbs and Irwin | Change from 2025 baseline |
|---|---|---|
| 2025 | 7.10 billion | Baseline |
| 2026 | 10.99 billion | 55% above 2025 |
| 2027 | 11.89 billion | 67% above 2025 |
These are the authors’ model results, not observed generation or a new EPA forecast. The modeled increase reflects the larger BBD obligation as well as an estimated D6 ethanol-RIN deficit. Under the balance they analyze, that deficit draws an estimated 1.42 billion D4 RINs into conventional compliance in 2026 and 1.41 billion in 2027. This describes the modeled effect of the D6 shortfall; it is not a claim that D4 RINs are legally interchangeable in every compliance circumstance.
How the D6 pull fits into the demand estimates
Hubbs and Irwin estimate combined D4, D5 and D6 demand of 11.75 billion gallons in 2026 and 11.89 billion in 2027. They also estimate required net D4 generation of 10.99 billion and 11.89 billion, respectively. These are distinct outputs from their accounting framework: do not add the D6 draw or the combined-demand totals to the net D4 figures as if they were separate, additional requirements.
EPA’s policy announcement offers a separate measure of the scale of the challenge: the agency estimates that biodiesel and renewable diesel production and use will need to rise by over 60 percent compared with 2025 levels to meet the 2026–2027 volumes. That is an agency estimate of needed growth, not a report of production already achieved.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.What the RIN bank suggests—and what it cannot prove
Hubbs and Irwin begin their balance-sheet analysis with 2.43 billion gallons of banked D4 and D5 RINs at the end of 2024. Their projection finds that this initial buffer is effectively exhausted by the start of 2027 under their assumptions. In their analysis, that leaves little or no banked-credit cushion against the projected demand.
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This is a model-dependent conclusion, not an EPA finding, a guarantee of a physical fuel shortage, or proof that compliance will fail. The result depends on the authors’ assumptions about generation, demand, credit availability and the accounting period. Actual supply and compliance outcomes can differ.
What could change the supply picture
Whether producers and importers can supply enough qualifying fuel depends on more than the RVO totals. EPA’s March 2026 Regulatory Impact Analysis considers domestic production, imports and exports, future capacity, qualifying feedstock availability, competing uses for those feedstocks, incentives, tariffs, foreign biofuel policies, logistics and broader market conditions. EPA cautions that historical trends alone are not enough to project future supply.
- Capacity and feedstocks: New or available production capacity matters only if it can obtain qualifying inputs, including when those inputs face competing demand.
- Trade and policy: Imports, exports, tariffs and foreign policies can affect how much fuel is available to the U.S. market.
- Incentives and market conditions: Tax credits and other incentives, logistics and wider market factors can affect production and delivery.
Another policy change has a later start date: EPA’s half-RIN treatment for foreign fuels and feedstocks begins in 2028. It is not a direct adjustment to the 2026 or 2027 volume figures discussed here.
Quick Recap
How to read the headline numbers
- 9.07 billion in 2026 and 9.20 billion in 2027: EPA’s final applicable BBD volumes, including SRE reallocation.
- 10.99 billion in 2026 and 11.89 billion in 2027: Hubbs and Irwin’s modeled estimates of required net D4 generation.
- 1.42 billion and 1.41 billion: Their estimates of D4 RINs drawn into conventional compliance by projected D6 shortfalls in 2026 and 2027.
- 2.43 billion gallons: Their reported D4/D5 bank at year-end 2024, which their model finds effectively exhausted by the start of 2027.
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