The EPA’s finalized “Set 2” rule under the Renewable Fuel Standard is doing something rare in U.S. biofuel policy: it is not just stabilizing the market, it could jolt it.
With blending mandates for 2026 and 2027 set at historic highs, including a more than 60% jump over 2025 levels for biomass-based diesel, the rule is already being read across the industry as a catalyst for a new expansion cycle — one that could ripple from fuel producers back to soybean fields, livestock operations and emerging oilseed crops.
A Demand Shock, But By Design
“It sure feels like it,” says Matt Upmeyer, director of feedstock sourcing and strategy at Montana Renewables, when asked whether the policy signals the next biofuel boom. “We received a strong RVO, adding about 2 billion gallons of biomass-based diesel demand, and that’s a huge increase. And certainly feedstock demand is growing as well. That 2 billion of biomass-based diesel represents about 15 billion lb. of feedstock for the biodiesel and renewable diesel producers. And that really translates directly back to farm and agriculture growth as well.”
From Underperformance to Full Throttle
For an industry coming off a sharp downturn, where biodiesel production fell significantly in 2025 and facilities idled or slowed, the scale of the mandate is not just notable — it is corrective.
“I mean, I think it is realistic,” Upmeyer says of the aggressive growth targets. “The industry is poised to meet that demand. We’ve got capacity. The renewable industry, which is both biodiesel and renewable diesel, has a combined capacity of probably around 7 billion gallons. So meeting that mandate, I don’t think is a problem.”
But meeting it will require a fundamental reshuffling of how feedstocks move through the system.
“We will definitely see some changes and shifts in the feedstock flows,” he says. “We talked a little bit about the soybean oil increase and the production of soybean oil through crush. I think also you’re going to see the tallow industry and choice white grease, the hog industry, as well as poultry fat — all of those are going to find their way into the renewable diesel and biodiesel in a greater way. I think we’ll maximize all of the available low-CI feedstocks, including distillers corn oil. And then from there, obviously, the demand will be filled with soy.”
That expansion does not stop at just soybeans. Upmeyer says there are other crops that stand to benefit from this newly released RFS.
“I think that as we expand the amount of biomass-based diesel we produce, we’re going to start looking to other feedstocks as well. So canola, there’s a fair amount of canola grown in the United States, and certainly our neighbors to the north are large canola producers,” Upmeyer says. “I think that will become an integral part of what we do. And then there’s other low-CI feedstocks that are sort of on the cusp, things like camelina and different things like that will get attracted new attention right now to see how they may fit into the future mandates and production.”
If you look at the past year, biodiesel and renewable diesel facilities reportedly shut down or ran well below capacity in 2025, which led to a one-third drop in U.S. biodiesel production compared to 2024.
When asked if these new RVOs from EPA will reverse that trend and give them enough confidence to bring that production back online, Upmeyer says it should.
“The biodiesel industry got hit hard. Their production costs are higher than renewable diesel, and so they certainly felt that when we had a lower RVO under the Set 1 rule. I think we’re getting close to a point where these plants will start back up. Margins have improved dramatically.”
He adds nuance to that recovery, noting cost pressures still linger.
“Biodiesel producers have a slightly different process than renewable diesel,” he says. “They take fats, oils and greases, combine them with methanol and catalysts to make biodiesel. And methanol costs have shot up, right? So I think the marginal producers on biodiesel are still probably not super inclined to start up, but certainly the integrated biodiesel plants will be running hard. And I do believe that even the marginal biodiesel players will get a chance to restart those assets in the near term.”
A Policy Twist: The Half-RIN Question
One of the most debated elements of the rule — the proposed “half-RIN” provision for 2028 — adds another layer of complexity, particularly for feedstock sourcing and trade.
“We just couldn’t get our heads around the administrative burden that might be associated with a half-RIN,” Upmeyer says. “How do you account for feedstocks coming in from some Canadian origin, some domestic, some from foreign sources? So I think there was an administrative burden that was certainly problematic.”
“This is certainly in line with the administration’s desire to maintain energy independence in the U.S. and to have a U.S.-based and U.S.-centric market for our crop inputs and fuels,” he says. “So I think there were a lot of things that went into this. But at the end of the day, it’s still on the table for 2028. I don’t think there’s clear guidance yet, but it certainly left that door open to address this issue in the Set 3 rule.”
A Win for Agriculture
When asked if he would classify this is a “win for U.S. agriculture,” Upmeyer said the immediate impact of the record-high blending mandates for 2026 and 2027 is already clear to those closest to the supply chain.
“I think it’s a great win,” Upmeyer says. “Again, we’re really underpinning the demand for soybeans and crush. We’ve got a strong demand for the rendered products that come from the beef industry and hog industry. So, I think this is a win for agriculture and for the renewable fuels industry. We certainly applaud the administration’s commitment to energy independence, to the renewable space and ultimately to agriculture.”
