EPA Clarifies Foreign Imports Get Full RINs Through End of 2027, Half-RINs Starting 2028: What It Means for Global UCO Suppliers and the US Market
Last week, the EPA issued a clarification on how foreign feedstock full RINs will be treated under the U.S. Renewable Fuel Standard (RFS) program. The short version: foreign-sourced feedstocks will continue to generate full RINs (Renewable Identification Numbers) through the end of 2027, with half-RINs applying from 2028 forward — rather than the immediate half-RIN reduction that had been floated in earlier rulemaking discussions.
This clarification is worth understanding clearly — not because it signals a shift in the direction of U.S. energy policy, but because it affects market dynamics in the near term. The underlying trajectory of U.S. policy remains toward domestic preference. Extending full RINs to foreign feedstocks indefinitely would mean directing fuel subsidy value offshore, which cuts against the current political grain. The shift to half-RINs in 2028 is a managed transition. Whether the deadline holds, moves, or becomes permanent will depend on how that plays out.
What Changed: Foreign Feedstock Full RINs Through End of 2027
Under the RFS program, blenders and obligated parties use RINs to demonstrate compliance with renewable volume obligations. The value of those RINs directly determines how attractive a feedstock is to renewable producers selling into the U.S. market. Proposed regulatory changes had threatened to cut the RIN value for foreign-sourced materials in half — a change that would have significantly reduced buyer incentives to source internationally.
The EPA’s clarification maintains foreign feedstock full RINs through the end of 2027, with half-RINs taking effect starting in 2028. For the domestic market, this means the competitive pricing pressure from imported feedstocks — UCO, tallow, and other waste fats — remains in place through the end of 2027, with a meaningful shift in import economics beginning in 2028. Domestic collectors and processors should factor this into their planning and pricing.
The broader policy direction, however, has not changed. The 2028 half-RIN transition exists precisely because policymakers want to give domestic supply infrastructure time to develop before the playing field shifts.
Understanding Z45 and LCFS: North America vs. the Rest of the World
A key distinction in the regulatory landscape: the Z45 pathway — which governs compliance documentation and verification under certain RFS and California LCFS frameworks — is a North America-only program. Foreign-origin material is not eligible for Z45, which limits how international feedstocks can participate in certain compliance pathways. This is a structural advantage for North American operators that is not affected by the 2028 RIN clarification. This includes Canada and Mexico, both of which qualify as North American origins under Z45.
Outside the Z45 pathway, non-North American suppliers can access LCFS credits (Low Carbon Fuel Standard) on a global basis, since LCFS does not carry the same geographic restriction. This means California buyers retain some flexibility in global sourcing, which has ongoing competitive implications for domestic operators.
For North American operators: Z45 eligibility is a durable competitive advantage over foreign-origin material. It matters most in the RFS compliance documentation space. Maintaining strong chain-of-custody records and compliant documentation is how that advantage is realized — and how domestic feedstock commands a premium over material that cannot use the same pathway.
What This Means for North American Operators: Route Simplified and Gantry Ops
For North American collectors, renderers, and aggregators, the competitive environment remains challenging through the end of 2027, with the shift to half-RINs for foreign feedstocks beginning in 2028. The structural advantages of domestic origin — Z45 eligibility, proximity, established relationships — are real, but they only translate into value when backed by compliant, auditable documentation.
That’s where Route Simplified comes in. Route Simplified is Reiter’s compliance and logistics software platform built specifically for the UCO and waste fats industry. It handles route management, collection documentation, feedstock tracking, and the compliance recordkeeping that buyers and auditors require to validate RIN and LCFS claims. Documentation gaps are what allow buyers to discount domestic material or look elsewhere — Route Simplified closes that gap.
Route Simplified is evolving into its next generation platform: Gantry Ops. Gantry Ops will expand on Route Simplified’s core capabilities with enhanced operational tools, improved integrations, and new features designed to support larger-scale operators and more complex supply chains. If you’re on Route Simplified today, you’re already positioned for the transition. If you haven’t yet adopted a compliant documentation platform, now is the time.
A Note on Mexico
Mexico occupies a distinct position in this landscape. As a North American origin under Z45, Mexican UCO qualifies for the same compliance pathways as U.S.-origin material. Reiter works with Mexican operators through Route Simplified, which is available in Spanish. Mexican collectors, renderers, and aggregators who want to understand how their material fits into the U.S. compliance framework can reach out directly.
The Bottom Line
The EPA’s decision to maintain foreign feedstock full RINs through the end of 2027 — with half-RINs taking effect in 2028 — is a transition timeline, not a policy endorsement of global sourcing. The underlying direction of U.S. energy policy favors domestic supply development. This window exists to allow an orderly adjustment — not to signal that the current environment is permanent.
For domestic operators, the message is clear: use this period to build scale, strengthen documentation, and deepen buyer relationships. The operators who are well-positioned when the next regulatory review arrives will be the ones who treated this window as a reason to invest — not a reason to wait.
Route Simplified — and the upcoming Gantry Ops — are the tools that give North American operators access to the full value of their material. Contact us directly to get started.