Insights, regulatory updates, and best practices.
TThe U.S. Environmental Protection Agency has finalized sweeping renewable fuel requirements for the next two years, setting volume mandates that officials say are the largest in the 20-year history of the Renewable Fuel Standard program. The rule, known as "Set 2," was announced at a White House agriculture event and is positioned by the Trump administration as a cornerstone of its domestic energy and farm policy agenda.
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For years, RNG producers and their commercial partners operated under a single, relatively familiar regulatory framework: 40 CFR Part 80 Subpart M, the general RFS rules. The Biogas Regulatory Reform Rule (BRRR) changed that calculus. EPA has now layered in Subpart E—a dedicated ruleset specifically covering biogas-derived renewable fuel—introducing new requirements for RNG producers, RNG RIN separators, pathway transfer documents (PTDs), recordkeeping, attest engagements, quality assurance programs (QAPs), and the treatment of potentially invalid RINs.
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Under the LCFS, certain feedstocks qualify for a reduced carbon intensity (CI) value because they are waste materials, residues, or by-products of other commercial or industrial processes. These are called Specified Source Feedstocks, and they can significantly increase the credit value of a fuel pathway when properly documented and verified.
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RNG volumes under the Renewable Fuel Standard (RFS) are not “operational KPIs”; they are the quantitative basis for RIN generation, transfer, and downstream compliance, and EPA describes RINs as the “currency” of the program. For biogas/RNG pathways, the regulations place reliable, continuous measurement (or approved alternatives), and auditable records at the center of eligibility and RIN integrity. This is where data historians fail often, creating gaps in the data and as such adds to headache, manpower, and cost to detect the gaps and apply the proper course of action to fill/substitute the data gap. As such it is important to have systems in place that provide proper monitoring and action.
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ISCC certification audits verify that organisations meet international sustainability and carbon certification requirements across three core pillars: traceability, mass balance, and GHG emissions calculations. Traceability ensures certified material can be followed from intake to dispatch, mass balance guarantees that sustainability claims never exceed verified certified inputs, and GHG methodology confirms that emission reduction claims are defensible and supported by verifiable records. Organisations that invest in robust documentation, consistent reconciliations, and clearly evidenced calculation methodologies are best positioned to achieve and maintain ISCC certification.
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On February 3, 2026, the U.S. Department of the Treasury and the Internal Revenue Service released proposed regulations for the clean fuel production tax credit under IRC section 45Z, which were published in the Federal Register the following day. The proposals clarify how producers demonstrate eligibility, calculate the credit amount, and substantiate emissions rates and "qualified sales". It also introduces safe harbors designed to reduce audit risk on those issues.
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