Key Takeaways:

The EPA has proposed reallocating 770 million RINs associated with Small Refinery Exemptions (SREs), either splitting the volume equally between 2026 and 2027 or assigning the full amount to 2027. The agency granted exemptions covering 1.76 billion RINs for 2025, substantially exceeding its original projection of 990 million RINs. Combined with previously accounted-for volumes, the proposal would bring total reallocation to approximately 1.46 billion RINs, or 83 percent of all exemptions granted, leaving 297 million RINs still not allocated. The timing of the additional obligations could influence RIN prices and biofuel demand, although the decision to reallocate the additional volumes is likely more consequential than which...