CARB Provides Additional Clarity on LCFS Amendments

July 21, 2026

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by Erin Krueger (Ethanol Producer Magazine) The California Air Resources Board on July 14 provided additional clarity on its 2025 Low Carbon Fuel Standard amendments with the release of a new 13-page frequently asked questions (FAQ) document. The agency said the FAQs will continue to be updated periodically.

California’s LCFS has been in effect since 2011. The technology-neutral program is designed to reduce the lifecycle greenhouse gas (GHG) emissions of transportation fuels within the state.

CARB in November 2024 approved updates to the LCFS that aim to reduce the carbon intensity (CI) of the state’s transportation fuel by 30% by 2030 and 90% by 2045. The amendments also included a variety of technical changes to the LCFS program.

Implementation of the approved amendments was delayed due to regulatory clarity issues, but became effective in July 2025.

The new FAQ document relates to the implementation of the amendments that were approved in late 2024 and entered into force last year. The document provides additional guidance on 37 specific issues, including those related to attestation letters, shapefiles, demonstration of sustainability requirements, sustainability requirements for corn stover and corn fiber, CARB-approved certification systems, and missing data.

The FAQ confirms that corn stover is a specified source feedstock and is not subject to sustainability requirements included in the LCFS amendments. Corn stover is, however, subject to specified source feedstock requirements. Likewise, corn fiber is considered a byproduct feedstock and is not subject to sustainability requirements, but is subject to the specified source feedstock requirements.

The FAQ also confirms that biomass does not need to be separately stored and transported to meet the amendments’ sustainability requirements. “Conformance can be demonstrated by mass balance,” CARB said in the FAQ. “For example, if 10 tons of biomass that meets all sustainability requirements was placed in a silo containing 100 tons of biomass that do not meet the sustainability requirements, up to 10 tons of biomass can be removed from that silo and used as either a feedstock or process energy for an approved pathway.”

For the mass balance approach, the FAQ also addresses questions over what time periods the balancing can occur. “Mass balancing time periods for sustainable biomass feedstocks used to produce transportation fuels must match the quarterly fuel transactions reporting period for fuel reporting entities (see LCFS Guidance 19-08),” CARB explained. “For supply chain entities that are farms or first gathering points, the mass balance period may be the calendar year. All eligible biomass-derived fuel reported must be trued-up with biomass meeting the requirements of section 95488.9(g) by the end of the mass balance period.”

The American Soybean Association welcomed release of the updated guidance, noting it represents an important step toward providing the regulatory certainty needed to support U.S. soybean farmers and the renewable fuels industry.

"This updated guidance provides much-needed clarity for farmers and the biofuels supply chain," said Scott Metzger, ASA President and Ohio soybean farmer. "Clear, practical rules help ensure soybean farmers can continue supplying the renewable fuels market with confidence. We appreciate CARB's efforts to provide the certainty needed to support continued investment in low-carbon fuels." READ MORE

Related articles

CARB: California LCFS amendments take effect on July 1 (Ethanol Producer Magazine)
CARB Guidance Brings Regulatory Clarity for Soy-Based Biofuels (American Soybean Association/Morning Ag Clips)
NOPA Welcomes LCFS Sustainability Guardrails Protocols from CARB (National Oilseed Processors Association)

Excerpt from American Soybean Association/Morning Ag Clips: Approach provides a more practical path to compliance -- The American Soybean Association welcomes the California Air Resources Board’s (CARB) release of updated implementation guidance for the Low Carbon Fuel Standard (LCFS) Sustainability Guardrails, an important step toward providing the regulatory certainty needed to support U.S. soybean farmers and the renewable fuels industry.

“This updated guidance provides much-needed clarity for farmers and the biofuels supply chain,” said Scott Metzger, ASA President and Ohio soybean farmer. “Clear, practical rules help ensure soybean farmers can continue supplying the renewable fuels market with confidence. We appreciate CARB’s efforts to provide the certainty needed to support continued investment in low-carbon fuels.”

The updated guidance answers several implementation questions raised by ASA, through the Biomass-Based Diesel Initiative, and other stakeholders by confirming that fuel producers can demonstrate compliance using practical supply chain documentation and mass balance accounting, rather than tracing soybeans back to individual fields. The approach provides a more practical path to compliance while maintaining the LCFS’s strong sustainability standards. READ MORE

Excerpt from National Oilseed Processors Association: Today the National Oilseed Processors Association (NOPA) welcomed the release of the latest “FAQ” guidance from the California Air Resources Board (CARB). This release provides the first example of an acceptable compliance pathway under the Low Carbon Fuel Standard (LCFS) Sustainability Guardrails, an important step toward providing regulatory certainty and market access for the biomass-based diesel value chain while supporting domestic feedstock production and American farmers.

“California has continued to lower their tailpipe and carbon emissions through the expanded use of soy-based biofuels,” said Devin Mogler, President & CEO at NOPA. “We have worked collaboratively with CARB over the past year to find a practical, science-based approach for the soy and biomass-based diesel value chain to meet the guardrails that recognizes the realities of agricultural production and commodity markets while maintaining the integrity of California’s sustainability objectives. We appreciate CARB’s collaborative engagement with NOPA and our partner stakeholders throughout this process to provide the certainty needed to support continued investment in low-carbon biofuels derived from American feedstock.”

The updated guidance provides farmers, processors, and refiners within the soy and biomass-based diesel value chain with a workable compliance framework that ensures soybean oil can continue to be utilized to produce advanced biofuels. The approach provides a practical means of demonstrating compliance with Sustainability Guardrails requirements while continuing to uphold the LCFS’s robust environmental and sustainability standards that have achieved unprecedented emissions reductions. Oilseed-derived feedstocks, including soybean oil, play a critical role in reducing greenhouse gas emissions in California and beyond. Thanks to this guidance, soy-derived feedstocks can continue contributing to the state’s climate goals while creating economic opportunities throughout the American agricultural economy.

NOPA looks forward to continuing its engagement with CARB and industry partners as implementation moves forward and remains committed to advancing policies that support California’s climate objectives, strengthen domestic supply chains, and create lasting opportunities for American farmers and rural communities.

About NOPA:

Organized in 1930, the National Oilseed Processors Association (NOPA) represents the U.S. soybean, canola, flaxseed, safflower seed, and sunflower seed-crushing industries. NOPA’s membership is engaged in the processing of oilseeds for meal and oil that are utilized in the manufacturing of food, feed, renewable fuels, and industrial products. NOPA’s 20 member companies operate 73 softseed and soybean solvent extraction plants across 20 states, crushing over 98% of all soybeans processed in the United States, the equivalent to more than 2 billion bushels annually. More information at www.NOPA.org. READ MORE