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EPA’s Final RFS Raises Biomass-Based Diesel Requirements and Projects More Supply in 2027

EPA’s final BBD requirements exceed its proposal for both years. Its 2026 analysis projects BBD supply and soybean-oil use rising by 2027, while imported feedstocks remain part of the expected mix.
From TheFinanceBase Team4 min to read
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EPA’s final Renewable Fuel Standard (RFS) sets a biomass-based diesel (BBD) requirement of 8.86 billion Renewable Identification Numbers (RINs) for 2026 and 8.95 billion for 2027. Its analysis also projects BBD supply rising from 9,961 million RINs in 2026 to 10,118 million in 2027, alongside a sharp increase in soybean-oil use by 2027. These are different measures: the first pair are compliance requirements, while the second pair are modeled supply estimates—not observed production.

What EPA’s final BBD requirements are

EPA announced the final 2026 and 2027 RFS volumes on March 27, 2026. The final BBD base requirements are 8.86 billion RINs for 2026 and 8.95 billion for 2027. EPA separately added small-refinery-exemption (SRE) reallocation volumes, which raises the total applicable BBD volumes to 9.07 billion RINs and 9.20 billion RINs, respectively. The U.S. Environmental Protection Agency’s 2026 final standards summary distinguishes the base requirement from the total applicable volume after reallocation.

The distinction matters: the base requirement and the SRE reallocation are not interchangeable figures. The first is the final BBD volume requirement; the second includes the additional volume EPA says applies after SRE reallocation.

Compliance measure 2026 2027
Final BBD base requirement 8.86 billion RINs 8.95 billion RINs
SRE reallocation added 0.21 billion RINs 0.25 billion RINs
Total applicable BBD volume 9.07 billion RINs 9.20 billion RINs

Source: U.S. Environmental Protection Agency, 2026 final standards summary. The applicable-volume figures include the SRE reallocation.

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How the final standards compare with EPA’s proposal

EPA’s proposed BBD requirements were 7.12 billion RINs for 2026 and 7.50 billion for 2027. The final base requirements are higher by 1.74 billion RINs for 2026 and 1.45 billion for 2027. These comparisons use the proposed and final base requirements, not the final applicable volumes after SRE reallocation.

Requirement 2026 2027
Proposed BBD requirement 7.12 billion RINs 7.50 billion RINs
Final BBD base requirement 8.86 billion RINs 8.95 billion RINs
Increase from proposal 1.74 billion RINs 1.45 billion RINs

Source: U.S. Environmental Protection Agency, 2026 fact sheet describing the proposal and final rule.

Why the units changed—and how to compare with earlier years

Through 2025, EPA specified the BBD requirement in physical gallons. In the final Set 2 rule, EPA expressed the 2026 and 2027 requirements in RINs, like the other RFS categories. For comparisons with earlier BBD standards, EPA converted pre-2026 values using 1.6 RINs per gallon. A RIN figure is therefore not a physical-gallons figure; comparisons across the unit change need to account for that conversion.

The final rule sets standards for cellulosic biofuel, BBD, advanced biofuel, and total renewable fuel. BBD is one category within the broader RFS, not the entire program. EPA also says the rule reallocates 70% of granted SRE volumes from 2023–2025.

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What EPA projects for BBD supply in 2026 and 2027

EPA’s 2026 final Regulatory Impact Analysis models total BBD supply at 9,961 million RINs in 2026 and 10,118 million RINs in 2027. That is an increase of 157 million modeled RINs between the two years. EPA breaks the modeled supply into biodiesel and renewable diesel and estimates contributions from soybean oil, fats, oils and greases (FOG), corn oil, and canola oil.

EPA modeled measure 2026 2027
Total BBD supply 9,961 million RINs 10,118 million RINs

Source: U.S. Environmental Protection Agency, 2026 final Regulatory Impact Analysis. These are modeled supply projections for the rule analysis, not reported production results.

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Compared with the final total applicable BBD volumes, the modeled supply is higher by 891 million RINs in 2026 and 918 million in 2027. Those differences are arithmetic comparisons between EPA’s modeled total supply and applicable-volume figures; they do not establish realized production, compliance outcomes, or a guaranteed surplus.

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Why soybean-oil use is projected to rise by 2027

EPA estimates that soybean-oil use for BBD will rise from approximately 1.37 billion gallons in 2025 to approximately 3.98 billion gallons in 2027. The agency attributes the projected increase to expected expansion of soybean crushing in the United States. The 2027 quantity is an EPA estimate published in 2026, not a measured outcome.

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The rise in soybean-oil use is one reason the year-to-year pattern can be described as backloaded toward 2027: EPA’s model places substantially more soybean oil in BBD production by that year. It is not EPA’s formal label for the rule, and the term should not be taken to mean the agency predicts that all production growth will occur in 2027.

Domestic and imported feedstocks both remain part of the picture

EPA says it expects about 70–75% of feedstocks used to make BBD in 2026 and 2027 to be domestic, with 25–30% imported. The agency acknowledges that domestic feedstocks alone will likely be inadequate for the final volumes. Its modeled feedstock mix includes domestic soybean oil, FOG, and corn oil, alongside imported FOG and canola oil.

Feedstock or source share What EPA’s 2026 analysis says
Domestic share of BBD feedstocks About 70–75% in 2026 and 2027
Imported share of BBD feedstocks About 25–30% in 2026 and 2027
Modeled domestic feedstocks Soybean oil, FOG, and corn oil
Modeled imported feedstocks FOG and canola oil

Source: U.S. Environmental Protection Agency, 2026 response to comments and final Regulatory Impact Analysis. The shares are agency expectations for 2026–2027, not observed supply shares.

How to read the “backloaded” pattern

The annual figures support a limited, specific use of “backloaded”: EPA’s modeled total BBD supply increases from 2026 to 2027, and its soybean-oil estimate rises considerably between 2025 and 2027. At the same time, the final base requirement increases only from 8.86 billion to 8.95 billion RINs across 2026–2027. The word describes the modeled year-to-year pattern; it is not an EPA term and does not turn the projections into forecasts of actual production.

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  • Compliance obligation: the final BBD requirement is 8.86 billion RINs in 2026 and 8.95 billion in 2027; SRE reallocation raises total applicable volumes to 9.07 billion and 9.20 billion.
  • Modeled supply: EPA estimates 9,961 million RINs in 2026 and 10,118 million in 2027, rather than reporting measured output.
  • Feedstock implication: soybean-oil use is projected to be higher by 2027, but EPA expects imported feedstocks to remain part of the mix.

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