Resubmitting or correcting reports

• Correcting Compliance Reports Submitted Through the DCFuel Application
• Submitting Transaction Error Reports in EMTS
• Process for Submitting RFS Remedial Actions in EMTS
  • Situation 1: Transfer of Assigned RINs to Incorrect Party
  • Situation 2: Transfer of Assigned RINs With No Transfer of Renewable Fuel
  • Situation 3: Missed Separation
  • Situation 4: Under-Generation of RINs
  • Situation 5: Over-Generation of RINs
  • Situation 6: Missed Generation of a RIN Batch
• Process for Submitting Sulfur and Benzene ABT Credit Remedial Actions in EMTS
  • Situation 1: Over-Generated Credits
  • Situation 2: Under-Generated Credits
  • Situation 3: Missed Credit Generation Reporting Deadline
  • Situation 4: Over-Retired Credits
  • Situation 5: Under-Retired Credits
  • Situation 6: Missed Credit Retirement Deadline

If users need assistance with navigating EMTS, please review the Renewable Fuel Standard EMTS User’s Guide (pdf) (4.1 MB, January 2025, EPA-420-B-25-003) or the EMTS Fuels ABT User’s Guide (pdf) (2.4 MB, May 2018, EPA-420-B-18-027).

Correcting Compliance Reports Submitted Through the DCFuel Application

After identifying the impacted report line for resubmission and making any necessary changes, follow these steps:

1. Find the “Report Type” (typically field #2) on the form template and change the field value from “O” (for “original”) to “R” (for “resubmission”).
2. Find the “Report Date” field (typically field #4) on the form template and update the report date to the date of resubmission
3. Optional entry: If the form template has a comments field, enter any clarifying information for recordkeeping purposes.
4. Upload the updated file into the DCFuel Application.

Submitting Transaction Error Reports in EMTS

Utilize the EMTS Transaction Error Report to report discrepancies between EMTS and your organization’s internal record-keeping system. Generally, transaction errors do not impact the number or types of Renewable Identification Numbers (remedial actions) and capture discrepancies around metadata and other supporting information (e.g., Product Transfer Documents, Bills of Lading, etc). Report any transaction error immediately following entry of the transaction, but no later than six months after the end of the compliance year.

Starting with Quarter 2 of 2026, EMTS users are no longer required to download a PDF copy for a separate submission into DCFuel. After the EMTS user enters the transaction error report directly into EMTS, the next step is to sign the submission using the existing “copy of record” functionality.

Transaction errors can be entered any number of times. Additionally, users have the option to bulk upload transaction error reports using the  EMTS Transaction Error Upload Template (xlsx) (619.8 KB, January 2017) .

Remedial Actions in EMTS

Guidance for Remedial Actions for RINs under the Renewable Fuel Standard.

Situation 1:  Transfer of Assigned RINs to Incorrect Party

Party A intends to transfer a volume of renewable fuel with assigned RINs to Party B. However, the volume of renewable fuel is transferred to Party C, while the assigned RINs are transferred in EMTS to Party B under the expectation that the fuel went to Party B.

Problem:

The regulations specify that "an assigned RIN cannot be transferred without simultaneously transferring a volume of renewable fuel to the same party" (see section 80.1428(a)(3)). Additionally, the regulations state that "no person shall: transfer to any person a RIN with a K code of 1 without transferring an appropriate volume of renewable fuel to the same person on the same day" (see section 80.1460(b)(4)). Consequently, a transfer of assigned RINs without a volume of fuel constitutes a violation under EPA regulations, and Party B may not retain the assigned RINs. To correct errors of this nature, the parties should follow the procedures outlined below.

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• Party B may transfer equivalent RINs back to Party A in EMTS and on a PTD. The PTD must include the statement "Remedial Action - No volume of renewable fuel actually transferred" and the following transfer elements:
  • RIN D Code.
  • RIN year.
  • RIN assignment.
  • Volume of renewable fuel transferred.
  • RIN price.
  • Transfer Date.
  • PTD Number (if desired).
  • Reason Code: Improper Trading Partner (30).
• In addition, Party A must submit a buy transaction (or confirmation) with the same RIN and transaction elements.
• Party A may sell appropriate RINs to Party C using a PTD that refers the original transfer of renewable fuel. Party A may transfer these RINs to Party C after or prior to receiving the RINs back from Party B.
• All parties must maintain documentation and records for this situation and remedial action, including but not limited to:
  • The transactional information for the improper transaction.
  • Remedial action buy/sell transactional information.
  • PTDs.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.

Situation 2: Transfer of Assigned RINs With No Transfer of Renewable Fuel

Party B accepts assigned RINs from Party A, but no renewable fuel is transferred to Party B.

Problem:

Regulations specify that "an assigned RIN cannot be transferred to another person without simultaneously transferring a volume of renewable fuel or renewable natural gas to that same person." See 80.1428(a)(2). Additionally, the regulations state that "[n]o person shall transfer to any person a RIN with a K code of 1 without transferring an appropriate volume of renewable fuel to the same person on the same day." See 80.1460(b)(4). Therefore, a transfer of assigned RINs without a volume of fuel constitutes a violation under EPA regulations, and Party B may not retain the assigned RINs. To correct errors of this nature, the parties should follow the procedures outlined below.

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• Party B may transfer equivalent RINs to Party A in EMTS and on a PTD.
• The RIN and transaction elements that must exactly match the original improper trade are:
  • RIN D Code.
  • RIN year.
  • RIN assignment.
  • Volume of renewable fuel transferred.
  • RIN price.
• The PTD must include the statement “Remedial Action - No volume of renewable fuel actually transferred”, and the new transfer elements are:
  • Transfer Date.
  • PTD Number (if desired).
  • Reason Code: Remedial Action Incorrect Trade (80).
• In addition, Party A must submit a buy transaction (or confirmation) with the same RIN and transaction elements.
• All parties must maintain documentation and records for this situation and remedial action, including but not limited to:
  • Transactional information for the improper transaction.
  • Remedial action buy/sell transactional information.
  • PTDs.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.

Situation 3: Missed Separation

Starting in July 2026, industry users can now process “missed separations” directly in EMTS using the standard remedial action workflow and no longer need to combine the missed separation onto a follow-on transaction.

Situation 4: Under-Generation of RINs

A party has generated a batch of RINs pursuant to 80.1426 but discovers within 10 business days of the RIN generation that they generated too few RINs.

Problem:

The regulations at 80.1426(f) require that the number of RINs be calculated using specific equations and correct values. Therefore, the party did not appropriately generate RINs per 80.1426 due to incorrect calculation of the number of RINs that should be generated for a batch of renewable fuel. To correct errors of this nature, the parties should follow the procedures outlined below.

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• The party may generate the appropriate number of RINs to make up the difference between the initial generation and the number of RINs that should have been generated. This remedial action does not allow parties to generate whole batches that were never generated.
• All RINs generated per this remedial action must have a unique Batch Number Text in EMTS. Be aware that Batch Number Text must be 20 characters or fewer.
• All parties must maintain documentation and records related to this situation and remedial action, including but not limited to:
  • Transactional information for the improper transaction.
  • Remedial action generation transactional information.
  • Product transfer documents.
• Certain fuel types may also require additional information.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.

Situation 5: Over-Generation of RINs

A RIN generator produces too many RINs for a volume of fuel for causes such as:

• Broken meter,
• Prohibited acts act under § 80.1460(b).
• Incorrect volumes or temperature correction error, or
• Multiple RIN batch generation (different batch numbers, but two batch-RIN generations for one actual batch of renewable fuel).

Problem:

Pursuant to 80.1431(a)(1)(ii) and (ix), improperly generated RINs are invalid.

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• If the RIN generator still owns the RIN batch, the RIN generator should not sell or transfer any of the RINs associated with the batch and should instead retire them as invalid RINs.
• If the RIN generator transferred the RIN batch, parties should notify any purchasers or transferees that received the RINs prior to discovering the over-generation and then retire the RINs under the reason code “Remedial Action – Retirement pursuant to 80.1431(c)” (retire reason code 110).

Situation 6: Missed Generation of a RIN Batch

A party has produced or imported a batch of renewable fuel but fails to submit the RIN batch generation information to EPA via EMTS within five business days of the RIN assignment.

Problem:

The regulations at 80.1452(b) require that each time a party assigns RINs to a batch of renewable fuel, they submit information to EPA via EMTS within five business days.

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• Certain fuel types may also require additional information.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.

EPA reserves the right to initiate an enforcement action for any of the situations described above. Remedial actions under EMTS do not constitute self-disclosures under the EPA’s policy Incentives for Self-Policing: Discovery, Disclosure, Correction and Prevention of Violations; Notice, 65 Fed. Reg. 19618 (April 11, 2000).

Guidance for Remedial Actions for ABT Credits Under the Benzene and Sulfur ABT Credit Trading Programs

Situation 1:Over-Generated Credits

A gasoline manufacturer generates more benzene or sulfur credits than allowed under 1090.725.

Problem:

The generated credits are invalid under 1090.735 and must not be used to achieve compliance.

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• Gasoline manufacturers that generate invalid benzene or sulfur credits must follow the requirements of 1090.735.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.
• In addition to answering the required submission detail questions, fuel manufacturers must update their compliance report to accurately reflect the results of any remedial action taken.

Situation 2: Under-Generated Credits

A gasoline manufacturer fails to generate sufficient benzene or sulfur credits using the specific equations and values outlined in section 1090.725.

Problem:

Benzene and sulfur credits must be accurately calculated using the prescribed equations and correct values. The gasoline manufacturer responsible for generating these credits should undertake the following remedial action.

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.
• In addition to answering the required submission detail questions, gasoline manufacturers must update their compliance report to accurately reflect the results of any remedial action taken.

Situation 3: Missed Credit Generation Reporting Deadline

A gasoline manufacturer does not submit reports on generated credits by the compliance deadline as required by 1090.905.

Problem:

Gasoline manufacturers are required to submit benzene and sulfur credit generation reports by March 31 for the preceding compliance period (e.g., reports covering the calendar year 2026 must be submitted to EPA no later than March 31, 2027).

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.
• In addition to answering the required submission detail questions, gasoline manufacturers must update their compliance report to accurately reflect the results of any remedial action taken.

Situation 4: Over-Retired Credits

A gasoline manufacturer retires more credits than required for compliance as specified in 1090.720(a).

Problem:

If a gasoline manufacturer retired more credits than are required for compliance, the gasoline manufacturer should take the following remedial action.

Remedial Action:

The gasoline manufacturer is required to immediately contact EPA Fuels Program Support via email to provide details regarding the over-retirement of credits. If necessary, the gasoline manufacturer must also resubmit compliance reports through CDX. The EPA will evaluate such remedial action requests on a case-by-case basis. The email to EPA Fuels Program Support must include the following information:

• EPA company ID.
• Compliance period.
• Original EMTS Transaction ID.
• Number of credits that were over-retired.
• Type of credits that were over-retired, specifying Benzene or Sulfur.
• Credit year of the credits that were over-retired.
• Number of times the credits were traded.
• An explanation of how the over-retirement of credits occurred.
• Confirmation that the revised compliance reports were resubmitted through CDX.
• Steps taken to prevent future occurrences of this violation.

Situation 5: Under-Retired Credits

A gasoline manufacturer retires fewer credits than required for compliance as provided in 1090.720(a).

Problem:

Failure to retire sufficient benzene or sulfur credits to meet the applicable standard under 1090 Subpart C is a violation. If a gasoline manufacturer retired fewer credits than are required for compliance, the fuel manufacturer should take the following remedial action.

Remedial Action:

• Action in EMTS can be taken without prior EPA approval.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.
• In addition to answering the required submission detail questions, gasoline manufacturers must update their compliance report to accurately reflect the results of any remedial action taken.

Situation 6: Missed Credit Retirement Deadline

A gasoline manufacturer does not retire benzene or sulfur credits prior to the compliance deadline as required under 1090.720.

Problem:

Gasoline manufacturers are required to retire properly generated benzene and sulfur credits for compliance by March 31 for the preceding compliance period (e.g., credits covering the 2026 compliance period must be submitted to EPA no later than March 31, 2027). If a fuel manufacturer has missed the compliance deadline for retiring credits, the fuel manufacturer should take the following remedial action.

Remedial Action:

• The gasoline manufacturer can choose to take a deficit if there was no prior year deficit or can enter the initial information into EMTS to begin the remedial action process.
• The Legacy Helpdesk items that were previously required when contacting EPA to initiate the remedial action process have been transferred into EMTS, including the “Explanation of Violation and Preventative Measures.” In the field in EMTS, provide a concise description of the violation and corrective action that is no longer than 1000 characters. If the remedial action was initiated before July 15, 2026, please include the JIRA ticket ID in this text box as well.
• In addition to answering the required submission detail questions, fuel manufacturers must update their compliance report to accurately reflect the results of any remedial action taken.