No. The EPA has no process to “invalidate” RINs. Rather, the EPA alleges that RINs are not valid according to the standards in 40 C.F.R. §§ 80.1131 or 80.1431.
As we stated in our March 2012 Interim Enforcement Response Policy:
The EPA intends to notify the regulated community that it has alleged that RINs are invalid. Information will be posted on the EPA web site when:
- the agency has developed what it determines is sufficient proof to warrant a public allegation and
- determined that such notification will not unduly impair ongoing investigations.
The fact that EPA has not made a public statement about the validity of particular RINs is not, and should not be taken to be evidence that those RINs are valid.