2026 Preview: Renewable Identification Number Credit Targets Marked by Uncertainty
U.S. Renewable Identification Number credit markets were marked by uncertainty in 2025 and that appears likely to continue into the new year.
The unpredictability in the market includes questions on the future of tax credit programs designed to spur biofuels production, the Trump administration’s policies toward the Renewable Fuel Standard and how long trade wars will affect feedstock prices.
The U.S. biofuels industry, according to one longtime participant, is an inch deep and stretches for miles. And RIN credits impact all of it.
The largest uncertainty facing RIN markets in 2025 was the EPA’s schedule for completing its next round of blending targets, known as the Renewable Volume Obligations–which will cover 2026 and 2027.
The agency is tasked with establishing targets for an upcoming compliance year by the end of the preceding November. EPA, however, often misses that deadline and that was again the case in 2025, in part because of an extended government shutdown this fall.
Without concrete figures to work with, market participants and biofuel producers have been forced to play something of a guessing game to determine what RIN demand could look like in 2026.
Another uncertainty facing the coming RVOs is the number of small refineries that were granted exemption from past compliance years, after having persuaded the government that RFS compliance would inflict “disproportionate economic harm” on their businesses.
EPA in August addressed its backlog of small refinery exemption requests by approving 63 and partially greenlighting another 77. Weeks after the dust settled, the agency said some of the gallons of biofuels associated with those exemptions would be reallocated to the coming set of targets and that it would consider divvying up the volumes in different ways.
Biofuel industry officials said anything less than a 100% reallocation would be unacceptable, because it would cut into their mandated volumes. And the oil industry has been pushing for no reallocation, saying such an approach would be the only legal way to proceed.
The agency could decide on a reallocation ratio of 50%, a compromise number that would leave both sides equally unhappy.
Further complicating the picture is the continuing effort to bring E15 to retail pumps, something that could be used as a bargaining chip in deciding the reallocation questions, some sources said.
The U.S. Court of Appeals for the District of Columbia Circuit in early December gave EPA one week to provide an update on the status of its work, and seven days later, the agency said it expected to wrap things up by the end of the first quarter.
Whatever targets are announced, an increase in RIN price volatility is almost guaranteed. In June 2023, the last time targets were announced for 2023, 2024 and 2025, prices for ethanol-related D6 and biomass-based diesel D4 RIN fell by more than 10cts in a single day. In that same session, cellulosic biofuel D3 RIN values jumped nearly 50cts.
At the start of December, the market began to value 2025 D6 and D4 RINs at parity. OPIS assessments for those two credit categories finished Dec. 15 at $1.04/RIN, flat to each other for a 12th-straight session.
In 2024, current-year D4 and D6 RINs spent more than eight months locked into an unprecedented parity streak that stretched from April to New Year’s Eve. Many saw that coming, thanks to a shortfall of D6 RINs and an oversupply of D4 RINs, along with the fact that RFS obligated parties are allowed to use D4s toward the D6 portion of their compliance obligation. As early as 2023, some market participants predicted the two credit categories would remain at or near parity well into 2026.
That prediction remained intact as late as December.
“We can’t blend enough ethanol physically at 15 billion gal/year,” one RINs trader told OPIS recently, referring to the D6 target for the 2025 compliance year. “So, the only way you reach that mandate is through D4 production.”
D6 RIN generation has approached that 15-billion-RIN mark in recent years, with 14.83 billion D6 RINs generated in 2023 and 14.89 billion generated in 2024, according to government data. But the latest EPA numbers suggest a slowdown, with just 12.2 billion D6 RINs generated over the first 10 months of 2025.
In addition, EPA’s data clearly shows an oversupply of D4 RINs. A total of 9.16 billion D4 RINs were generated in 2024, up nearly 15% from 2023’s 7.97 billion RIN total. Those year-end totals dwarf the RVOs of 2.82 billion D4 RINs in 2023 and 3.04 billion RINs in 2024.
But D4 generation slowed considerably in 2025. The latest data show only 5.84 billion D4 RINs were created through October, well above the 2025 RVO of 3.35 billion RINs, but down 22% from the 2024 pace.
Despite an implied shortage of D4 RINs, some analysts don’t expect prices to rise much in 2026 because of the amount of 2024 D4 RINs still available.
Over the last year, prices for 2024 D6 and D4 RINs–which expire on March 31 or June 1 of next year, depending on when EPA announces its next targets–have rarely been separated by more than 1ct.
In the first half of this year, the premium that 2025 D4 RINs held over their D6 counterparts averaged nearly 6cts. But that spread never rose above 3.5cts in the fourth quarter, eventually vanishing into the current parity streak.
On the forward RFS compliance curve, buying interest for 2026 D6 and D4 RINs picked up halfway through 2025. In the fourth quarter, 2026 D4 RIN prices traded at about a 5ct premium to D6 credits.
OPIS assessments from Dec. 15 put the 2026 D6 and D4 credits at $1.06 and $1.1125/RIN, respectively, a 5.25ct difference.
Relationships between 2026 and 2025 RINs have been hard to pin down as the new year approaches. In the first half of December, 2026 D6 credits have traded at a 2ct to 4ct premium over 2025 credits, while 2026 D4 RINs have been between 6.5cts and 8.5cts above 2025 D4 RINs.
RIN credit prices in 2026, one market source said recently “are a bit all over the place,” adding yet another uncertainty to the 2025 list.
Reporting by Aaron Alford, aalford@opisnet.com; Editing by Jordan Godwin, jgodwin@opisnet.com and Jeffrey Barber, jbarber@opisnet.com