EPA finalises the RFS for 2026–2027: 1.36 and 1.43 billion RINs in the cellulosic category

The US Environmental Protection Agency (EPA) signed on 27 March 2026 the final Renewable Fuel Standard regulation for 2026–2027 (the so-called Set 2). For the biogas sector the key figure is the volume of cellulosic fuels (D3), which include RNG from biogas: 1.36 billion RINs in 2026 and 1.43 billion RINs in 2027, that is more than in the June 2025 proposal (1.30 and 1.36 billion RINs).

From proposal to regulation

The EPA issued the draft rules on 13 June 2025. The final version raised not only the cellulosic volumes but above all the obligations for biomass-based diesel (BBD): according to the EPA table 8.86 billion RINs in 2026 and 8.95 billion in 2027, and after taking into account the reallocation of small refinery exemptions — 9.07 and 9.20 billion RINs. Analysts describe them as the largest BBD commitments in the history of the programme. The values proposed in June 2025 were, according to the EPA, 7.12 and 7.50 billion RINs. The final volumes include a 70% reallocation of small refinery exemptions granted for 2023–2025; farmdoc daily describes the combined BBD volumes (9.07 and 9.20 billion RINs) as the largest in RFS history and about 70% higher than in 2025.

What about the production shortfall

In the same regulation the EPA partially waived the cellulosic requirement for 2025 because of a shortfall in cellulosic fuel production (the 2025 volume after the change: 1.21 billion RINs; 1.19 billion in the proposal). The regulation was published on 1 April 2026. Such waivers (cellulosic waivers) are nothing new in the RFS — they show the risk that volumes set above real production capacity do not translate into full utilisation.

Industry reactions

Some RNG and biogas organisations argue that the final cellulosic volumes still exceed real production capacity. Biofuel producers and farmers, on the other hand, welcomed the higher BBD obligations, which increase demand for vegetable oils.

Significance for RNG

Because most D3 RINs are generated from RNG from landfill gas and agricultural biogas, their price depends on volumes, waivers and real supply. Higher volumes favour investment plans, but the risk of production shortfalls and further waivers remains. To profitability calculations one should add the 45Z credit and the credits of state clean fuel programmes.

What this means for Poland and Europe

The American system shows how much depends on a single parameter — the RIN volume — and on whether the market believes it will be delivered. In the EU the prices of renewable transport fuels are shaped by the RED III targets and national support schemes; following the US example, however, it is worth monitoring whether targets are getting ahead of biomethane production capacity.