The Trump administration’s Environmental Protection Agency has proposed record-high biofuel blending targets for 2026 and 2027, setting the next phase of the Renewable Fuel Standard on a steeper growth path. The agency frames the plan as a way to strengthen U.S. energy security and support rural economies, but scientists and policy analysts warn it could shift pressure onto forests and other carbon‑rich ecosystems abroad. Their concern is that higher U.S. crop demand for fuels will ripple through global markets and accelerate rainforest loss.
Record RFS targets and a domestic tilt
The Environmental Protection Agency says its new Renewable Fuel Standard proposal for 2026 and 2027 would establish the highest volume requirements in the program’s history, with explicit growth targets for renewable fuel categories according to an EPA announcement. That proposal describes how the Trump administration aims to expand production of domestic fuels while tightening rules on what qualifies for tradable compliance credits known as Renewable Identification Numbers, or RINs.
As part of those design choices, the proposal would reduce the RIN value assigned to foreign-produced biofuels and feedstocks, effectively penalizing imports relative to U.S. output according to the same EPA description. The agency also moves to remove electricity, often referred to as eRINs, from the list of eligible renewable fuel pathways, which shifts more of the compliance burden back toward liquid fuels derived from crops and waste oils.
From Set Rule baseline to Set 2 escalation
The new proposal builds on the earlier Renewable Fuel Standard “Set Rule” that locked in volume requirements for 2023, 2024 and 2025 according to the Final Renewable Fuels Standards Rule. That rule provides the immediate baseline for assessing how aggressive the 2026 and 2027 targets are, since it marked the first time EPA set volumes beyond levels written directly into statute.
In that earlier action, EPA issued a Regulatory Impact Analysis to examine the economic and environmental effects of the 2023 to 2025 volumes, and it also released a model comparison technical document, according to the same EPA rulemaking record. Critics of the new Set 2 proposal argue that any step up from these baseline volumes must be judged against the agency’s own prior assessment of land-use and emissions impacts.
Scientific warning on land-use change
The core of the rainforest concern comes from the way biofuel mandates influence global land use. In a landmark peer‑reviewed study, Timothy Searchinger and co‑authors found that diverting U.S. croplands to biofuel production increases greenhouse gas emissions through emissions from land‑use change according to research published in the journal Science and indexed at PubMed. The analysis concluded that when existing cropland grows fuel instead of food, higher prices encourage expansion of agriculture into forests and grasslands elsewhere.
That Science paper, which carries the digital object identifier 10.1126/science.1151861, quantified how biofuel mandates can raise crop prices and induce conversion of forest and grassland, leading to large carbon emissions and long payback times. The authors’ findings are often summarized as indirect land‑use change, or ILUC, and they have become a touchstone for experts who worry that higher U.S. mandates will indirectly drive deforestation in regions such as the Amazon and Southeast Asia even if the additional clearing does not occur on U.S. soil.
EPA’s own lifecycle accounting framework
EPA has formally acknowledged that land‑use change is part of the climate equation for biofuels. In its Renewable Fuel Standard (RFS2) Final Rule, the agency states that lifecycle greenhouse gas accounting for qualifying fuels includes emissions from land‑use change according to the RFS2 final rule. That rule serves as the canonical hub for program structure and links to a Final Regulatory Impact Analysis and other lifecycle greenhouse gas analysis materials.
The RFS2 docket, identified as EPA‑HQ‑OAR‑2019‑0168 on regulations.gov, contains the technical work that underpins those lifecycle judgments. Analysts who are skeptical of higher 2026 and 2027 volumes argue that EPA’s own framework shows how market‑driven land conversion can erase or delay the climate benefits that crop‑based fuels are supposed to provide.
Europe’s ILUC risk categories as a warning sign
Regulators outside the United States have already moved to codify indirect land‑use change risks in law. The European Union’s Commission Delegated Regulation (EU) 2019/807 sets out criteria for what it calls high ILUC‑risk feedstocks and establishes a certification system for low ILUC‑risk production according to the official text published on EUR‑Lex. The regulation contains a formal policy determination that some biofuel feedstocks are associated with significant expansion into land that stores large amounts of carbon, such as tropical forests and peatlands.
By defining high ILUC‑risk feedstocks and offering a pathway for low ILUC‑risk certification, the European framework shows one way regulators can respond when science links biofuel demand to forest loss according to the same EU regulation. Experts watching the Trump administration’s proposal say the contrast is stark: while Europe has built ILUC risk into eligibility rules, the U.S. proposal focuses more on favoring domestic production than on differentiating feedstocks by their deforestation footprint.
Renewable diesel and global feedstock pressure
The recent surge in U.S. renewable diesel production has already reshaped global trade in vegetable oils and waste‑based feedstocks, providing a real‑world example of how policy can move markets. An analysis by the U.S. Department of Agriculture’s Foreign Agricultural Service finds that rapid growth in renewable diesel output is drastically affecting trade flows for feedstocks such as canola oil, soybean oil, used cooking oil and tallow according to a report on USDA’s FAS site. The study notes that U.S. demand is drawing in more canola oil imports and tightening soybean oil markets while intensifying competition for lower‑carbon waste oils.
For rainforest regions, the concern is that as U.S. refiners compete harder for used cooking oil and animal fats, other fuel producers could fall back on cheaper virgin oils, including those linked to deforestation. Analysts point to the USDA findings as evidence that higher RFS targets, combined with a domestic bias in RIN values, can send strong signals through global supply chains.
Domestic focus, global consequences
The Trump administration presents the new RFS proposal as a way to strengthen U.S. energy security and support rural America according to the White House, which has promoted the program’s role in domestic fuel production. The reduced RIN value for foreign feedstocks, by design, channels more of the mandate’s economic benefit to U.S. farmers and biofuel producers, aligning with long‑standing political goals in corn and soybean states.
Experts warn that this domestic focus does not insulate the policy from global effects. The Science study by Searchinger and colleagues shows that even when biofuel expansion is confined to existing cropland, higher commodity prices can trigger forest and grassland conversion elsewhere according to the peer‑reviewed analysis. In practice, that means more soy or palm expansion in countries where environmental safeguards are weaker, even if U.S. fields do not move into forests directly.
Critique of prevailing assumptions
Supporters of higher biofuel targets often assume that any gallon of renewable fuel blended into gasoline or diesel automatically cuts emissions compared with fossil fuel. The combination of EPA’s own lifecycle accounting, the Science ILUC findings and the European Union’s high‑risk feedstock categories challenges that assumption by showing that land‑use change can erase the carbon advantage for years or decades according to EPA’s lifecycle framework and the EU ILUC rules. Critics argue that current coverage of the Trump proposal often treats higher volumes as climate progress without asking whether the specific feedstocks and sourcing patterns meet the standard implied by these scientific and regulatory benchmarks.
From a reader’s perspective, the stakes go beyond abstract carbon accounting. Fuel buyers, car owners and taxpayers are being asked to support a policy architecture that could either cut emissions or quietly shift them offshore. The latest publicly available lifecycle and ILUC analyses are more than a decade old in the case of the Science paper and date back to the RFS2 rulemaking for EPA’s core modeling, which means the debate is unfolding with limited fresh data according to the records compiled in the EPA biofuels assessment.
What is at stake for rainforests
Rainforest nations are not named in the Trump administration’s RFS proposal, yet the economic signals that flow from higher U.S. mandates and domestic‑favoring RIN rules will be felt in places where land is still being cleared. The European Union’s decision to label some feedstocks as high ILUC‑risk based on their association with expansion into high‑carbon‑stock land according to EU criteria suggests that similar scrutiny could fall on any supply chain that responds to U.S. demand.
As policymakers weigh the Trump administration’s proposal, the central question is whether the RFS can be aligned with the scientific evidence on land‑use change rather than cutting against it. The EPA’s own RFS2 framework shows that the agency has tools to account for global land impacts, and the USDA’s renewable diesel analysis shows that feedstock markets respond quickly to policy signals according to federal trade data. Without tighter safeguards on which fuels qualify and how they are sourced, experts warn that record‑high U.S. biofuel targets risk driving the very rainforest loss that climate policy is supposed to prevent.
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*This article was researched with the help of AI, with human editors creating the final content.
