The following is a two-part question: a. We are a petroleum refiner and recognize that we are an obligated party under the regulation. We are considering importing ethanol that has not been denatured. We will hold title to the un-denatured ethanol. Title
See More Frequent Questions about Fuels Registration, Reporting, and Compliance Help. A. Un-denatured ethanol is not a renewable fuel. See 80.1101(d)(3). Under the described scenario, the party to whom custody is transferred and who denatures the ethanol would be producer of the renewable fuel. B. Under the described scenario, RINs…