Key Insights
➤ Petition counts stayed relatively stable, but approval rates changed. Annual petitions ranged from 26 to 44 during 2011–2025. Approval rates among decided petitions were roughly one in three during 2013–2015 and ranged from 70% to 97% from 2016 onward.
➤ The 2025 exemptions were the largest since 2017. EPA exempted approximately 1.76 billion Renewable Identification Numbers (RINs) across 29 small refineries for the 2025 compliance year. This represented 7.95% of the projected 2025 obligation, the second-highest share on record.
➤ Exempted credits do not directly measure lost biofuel demand. Blending for 2025 had already occurred. The exemptions reduce the number of compliance credits refiners must retire; they do not directly measure biofuel that went unblended or crops that went unpurchased. More credits may remain available for later compliance, subject to carryover limits.
➤ Reallocation helps determine the effect on future demand. The final Set 2 rule already reallocates about 693 million RINs of 2025 exemptions to 2026–2027. If EPA’s announced plan to reallocate an additional 770 million RINs is finalized as described, the total would reach approximately 1.46 billion RINs, or 83% of the 2025 exempted volume.
➤ Each exemption now represents a larger fuel volume. After accounting for partial exemptions and changes in RFS standards, the gasoline and diesel volume represented by an average full-exemption equivalent increased from about 244 million gallons in 2013 to 570 million in 2025. Exemption volumes and reallocation therefore need to be considered together when assessing potential effects on corn, soybean oil, and other biofuel feedstock markets.
Recommended Citation: Khashi Ghorbani and Matthew Gammans (2026). Small Refinery Exemptions under the Renewable Fuel Standard: Historical Trends and the 2026 Decisions. ARPC White Paper 2026–10. Agricultural Risk Policy Center, North Dakota State University. October 21, 2026. https://doi.org/10.22004/ag.econ.414543