The U.S. Environmental Protection Agency (EPA) finalized Renewable Fuel Standard (RFS) volume requirements for 2026 and 2027 on March 27, 2026. The “Set 2” rule establishes higher total renewable fuel obligations than EPA’s earlier proposal, sets category-specific requirements, and reallocates part of certain small refinery exemptions (SREs) granted for 2023–2025.

The final volumes give obligated parties and renewable fuel producers a clearer compliance framework for the next two years. But the figures are not the only development affecting RIN buyers and sellers. In August 2026, EPA granted additional SREs for the 2025 compliance year and said it would propose reallocating the difference between projected and actual 2025 exemptions into the 2026 and 2027 obligations. As of October 13, 2026, that further reallocation remains a proposal to come, rather than a change already included in the final Set 2 volumes. US EPA

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What the final volumes require

The RFS requires specified volumes of renewable fuel to be used in the U.S. transportation fuel supply. EPA expresses the 2026 and 2027 requirements in RINs. One RIN is equivalent to one ethanol-equivalent gallon of renewable fuel. The obligations are arranged in four categories: cellulosic biofuel, biomass-based diesel, advanced biofuel and total renewable fuel. US EPA

The final rule also expresses biomass-based diesel requirements in RINs rather than physical gallons. EPA notes that earlier biomass-based diesel requirements were established in gallons and converted them for comparison using a conversion factor of 1.6 RINs per gallon. This change makes the category consistent with the other volume requirements in the final table. epa.gov

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The final rule differs from the earlier proposal

EPA’s final total renewable fuel requirements are 25.82 billion RINs for 2026 and 25.98 billion for 2027, before SRE reallocations. The earlier proposed volumes were 24.02 billion and 24.46 billion RINs, respectively. Once the final reallocation amounts are included, the total applicable volumes rise to 26.81 billion RINs in 2026 and 27.02 billion in 2027. US EPA

The final rule includes a 70% reallocation of SRE volumes from 2023–2025. EPA described this approach as balancing renewable fuel demand with the aim of maintaining a functioning credit market. The resulting reallocation is reflected in the final table: 0.99 billion RINs for 2026 and 1.04 billion for 2027 in the total renewable fuel category. US EPA

For market participants, it is useful to keep the underlying volume requirement separate from the SRE reallocation. The first is the final category target set by EPA; the second reflects how EPA accounted for specified exemptions when calculating the total applicable volume. Both numbers matter, but they describe different parts of the final rule.

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A further SRE proposal could change the picture

On August 31, 2026, EPA announced decisions on 34 petitions for 2025 SREs. It granted full exemptions to 18 petitions, partial 50% exemptions to 11, denied three, and found two ineligible. EPA said those decisions exempted 1.76 billion RINs for 29 small refineries. US EPA

EPA also said that the Set 2 rule had projected 990 million RINs in 2025 SREs. Because the actual exemptions granted exceeded that projection, EPA plans to propose reallocating 100% of the difference into the 2026 and 2027 Renewable Volume Obligations (RVOs). The agency said it expected to issue that proposal before the end of October 2026. At the time of writing, the additional reallocation had not been finalized. US EPA

This distinction is important for buyers and sellers evaluating the 2026 and 2027 obligations. The final Set 2 table remains the enacted starting point. The later EPA announcement identifies a planned proposal that could increase the 2026–27 obligations if adopted, but its precise volumes and timing cannot be treated as final until EPA completes the rulemaking.

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What the standards may mean for RIN demand

RINs demonstrate compliance with the RFS. Obligated parties use them to meet their annual obligations, while qualifying renewable fuel production and imports generate RINs under the applicable EPA rules. The RFS volume requirements therefore shape the compliance framework in which parties assess their RIN positions.

EPA characterizes the 2026–27 volumes as the highest in the program’s history and estimates that biodiesel and renewable diesel production and use will need to increase by more than 60% compared with 2025 volumes to meet the new levels. That is an agency estimate of the scale of increased supply needed; it is not a guarantee that production will reach that level or that a particular RIN category will be available in any specified quantity. US EPA

For sellers, the final category requirements show the regulatory demand EPA has established. The actual RINs generated will depend on qualifying fuel production and other program rules. For buyers, the category structure matters because an obligation in one category may not be met by any RIN without regard to its type. Market participants need to confirm the relevant category and program requirements when assessing what credits can be used for compliance.

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Other provisions in the final rule

The Set 2 rule removes renewable electricity as a qualifying renewable fuel under the RFS, ending the eRIN approach in the program. EPA said the provisions were removed because it determined renewable electricity did not meet the Clean Air Act definition of transportation fuel and the eRIN system could not be implemented under the program. US EPA

The rule also addresses imported fuels and feedstocks, but the timing matters. EPA did not finalize the proposed provisions that would reduce the number of RINs generated for imported biofuels or fuels produced using imported feedstocks. It said it intended to address those provisions in a future action, with a change beginning in 2028. That means the Set 2 rule’s 2026 and 2027 RIN volumes should not be described as already applying a final import-related RIN reduction. epa.gov

EPA also partially waived the 2025 cellulosic biofuel volume requirement and revised the corresponding percentage standard because of a shortfall in cellulosic biofuel production. This is a separate action affecting the 2025 compliance year, rather than a reduction to the final 2026 or 2027 cellulosic volumes. US EPA

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Compliance dates remain part of the market context

EPA extended the 2025 RFS compliance reporting deadline to October 1, 2026, following its 2025 SRE decisions. The deadline has now passed. EPA’s current deadlines page lists March 31, 2027, as the 2026 compliance reporting deadline, while the 2027 deadline is tied to the next quarterly reporting deadline after the 2028 standards take effect. US EPA

These dates are relevant to how obligated parties manage reporting and compliance, but they do not change the final volumes by themselves. Buyers and sellers should distinguish the annual RVO, the compliance reporting deadline, and any separate EPA action on exemptions or reallocation.

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What buyers and sellers should monitor

For the 2026 and 2027 RFS years, the final Set 2 standards establish the current volume framework. The total applicable renewable fuel volumes are 26.81 billion RINs in 2026 and 27.02 billion in 2027, including the SRE reallocation already finalized. EPA’s August 2026 announcement adds a further development: a proposal to reallocate the difference between projected and actual 2025 SRE volumes into those same years.

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Market participants should therefore follow EPA’s rulemaking notices and final actions, and keep the following distinctions clear:

• The final category volume requirement is not the same as the total applicable volume after SRE reallocation.

• The additional reallocation announced in August 2026 is pending a proposal and subsequent agency action.

• RIN generation depends on qualifying fuel and program rules; EPA’s volume targets do not guarantee a particular supply outcome.

• The eRIN provisions have been removed, while the import-related provisions discussed by EPA are intended for a future action beginning in 2028.

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These points provide a factual basis for discussing the compliance framework with counterparties and assessing which RIN categories are relevant to a company’s position. For support navigating RIN markets and compliance developments, visit AFS Commodities’ RINs page.