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How the Final 2026–2027 RFS Rules Change Biomass-Based Diesel and Feedstock Projections

EPA finalized higher 2026–2027 BBD obligations without adopting its proposed half-RIN cut. Here is how the final RIN volumes compare with EPA’s estimates and separate farmdoc scenarios for fuel production and feedstock demand.
From TheFinanceBase Team4 min to read
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The final Renewable Fuel Standard (RFS) raises the biomass-based diesel (BBD) compliance requirement for 2026 and 2027, but it does not include EPA’s proposed “half-RIN” cut for imported biofuel or fuel made from foreign feedstocks. EPA expects domestic plants to use both domestic and foreign feedstocks; that is different from importing finished fuel. The resulting production and feedstock figures are forecasts, not observed full-year market totals.

What the final rule requires

EPA finalized its 2026–2027 RFS “Set 2” rule on March 27, 2026; it was published in the Federal Register on April 1. The rule sets BBD obligations in Renewable Identification Numbers (RINs), the compliance credits used under the RFS. One RIN represents one ethanol-equivalent gallon of renewable fuel—not necessarily one physical gallon of biodiesel or renewable diesel.

Compliance year Final BBD requirement Small refinery exemption (SRE) reallocation Total 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

These figures are EPA’s final regulatory volumes. The reallocated SRE amounts are added to the base requirements to calculate total applicable volumes; neither column is a count of physical gallons of fuel. See EPA’s 2026 final rule table.

What “no half-RIN” means—and what it does not mean

The proposal EPA dropped

EPA did not finalize its proposal to reduce RIN value for imported biofuel or fuel made from foreign feedstocks. In this context, “no half-RIN” means that proposed treatment was not adopted. It does not mean that imports are absent from the market or that foreign-origin feedstocks receive a separate physical-volume mandate.

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Foreign feedstock is not the same as imported finished fuel

A U.S. plant can make biodiesel or renewable diesel using imported feedstock. That fuel is domestically produced even though its raw material came from abroad. Conversely, importing finished BBD is a separate supply channel. Keeping the two channels distinct is essential when interpreting EPA’s projections or comparing them with modeled import volumes.

EPA’s production and feedstock outlook

Domestic-feedstock production estimate

EPA’s final analysis projects BBD production from domestic feedstocks of 4.5 billion gallons in 2026 and 4.7 billion gallons in 2027. EPA also estimates that biodiesel and renewable diesel made from foreign feedstocks will supply approximately 25–30% of the required BBD volume. The estimates describe different feedstock origins and should not be read as a split between U.S.-made and imported finished fuel.

Scale of the production increase

EPA said biodiesel and renewable diesel production and use would need to rise by over 60% relative to 2025 to meet the final 2026–2027 volumes. That is the agency’s comparison and estimate, not a report of production already achieved.

How the February farmdoc scenario differs

A February 2026 analysis by Todd Hubbs and Scott Irwin of farmdoc daily modeled a scenario combining removal of the half-RIN proposal with higher BBD obligations, using information available before the final rule. It estimated total feedstock use of 46 billion pounds in 2026 and 61 billion pounds in 2027, compared with a modeled annual baseline of 40 billion pounds for 2023–2025.

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Measure in the February scenario 2023–2025 baseline 2026 estimate 2027 estimate
Total feedstock use 40 billion pounds per year 46 billion pounds 61 billion pounds
Domestic feedstock use 23 billion pounds 31 billion pounds 41 billion pounds

These are model outputs, not EPA commitments or observed use. The modeled domestic share rises from 23 billion pounds at baseline to 31 billion in 2026 and 41 billion in 2027, while total feedstock use grows faster because the scenario also assumes increased use of imported feedstocks.

Why its estimates are assumption-sensitive

The February model assumed 2026–2027 fuel imports would be twice their 2025 level unless domestic capacity constraints required more. It also specified operable capacity and feedstock shares, and used scenarios with 100% and 50% SRE reallocation, averaging them for some comparisons. Its result that domestic feedstock use would be about 8 billion pounds per year below the earlier half-RIN scenario is therefore a scenario comparison—not a measured market effect.

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The authors identify feedstock sourcing, relative prices, 45Z tax-credit incentives, and logistics as uncertainties. A statement by Darling Ingredients CFO Robert Day reproduced in the February article was: “So, I’ll go on record saying we support an RVO for advanced biofuels that translates to 5.25 billion gallons or 5.61 billion gallons.” Hubbs and Irwin quote Day; this is not a directly reviewed earnings-call transcript, and it is not itself an EPA requirement.

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What the later June model adds

A separate farmdoc daily analysis by Hubbs and Irwin, published June 24, 2026, modeled physical fuel supply under the final RVOs. It assumed domestic plant capacity utilization of 90% in 2026 and 95% in 2027. Its results should not be combined with the February model’s feedstock-pound estimates: the analyses address different outputs and use different assumptions.

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June 2026 model output 2026 2027
Assumed domestic plant capacity utilization 90% 95%
Implied domestic FAME biodiesel and renewable diesel production 6.10 billion gallons 6.43 billion gallons
Modeled residual supply met by imports 0.60 billion gallons 1.30 billion gallons
Modeled total BBD supply 6.70 billion gallons 7.74 billion gallons

FAME means fatty acid methyl ester, a type of biodiesel. These modeled physical-gallon supply totals are not the RIN obligations in EPA’s table. The June article’s import residual is also distinct from EPA’s estimate of fuel made using foreign feedstocks.

How to read the forecasts

Higher RVOs increase the compliance volume that obligated parties must cover, but they do not by themselves determine which plants produce the fuel, where feedstocks originate, or how much finished fuel is imported. Those outcomes depend on capacity, sourcing, prices, policy incentives, and logistics. EPA’s final Regulatory Impact Analysis and Response to Comments explain the agency’s projections and assumptions; the farmdoc articles provide independent scenario analyses.

  • For compliance: use the final RIN obligations and SRE reallocation figures, not physical-gallon production estimates.
  • For domestic processing and feedstock demand: distinguish EPA’s domestic-feedstock projections from the farmdoc models, and note each model’s assumptions.
  • For trade: separate imported feedstocks used by U.S. plants from imported finished BBD.
  • For market outcomes: treat all 2026–2027 production, import, and feedstock quantities here as requirements, agency estimates, or model projections. The cited materials do not establish full-year observed outcomes.

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