When the Clock Is Ticking, but the Rules Aren’t Set: Clean Fuels Conference 2026 delegates assess a Wonderland of market opportunity and policy uncertainty

If the clean fuels industry is living through an Alice-in-Wonderland moment, it’s not because things feel fanciful. It’s because the rules keep changing shape just as the clock gets louder.

That was the unspoken theme running through the Clean Fuels Conference this year, where delegates heard repeated variations on the same question: Are we on a storybook cruise — or strapped into a wild ride? The answer, depending on the panel, was usually some version of both.

What made the moment feel surreal wasn’t uncertainty alone. It was scale. The industry may be staring at some of the largest mandated volumes in its history — at the same time it waits, once again, for the rules that determine how, when, and whether those volumes can be met.

A Wild Ride Toward Historic Volumes

The clearest headline came during the federal policy outlook session. After years of incrementalism, the numbers on the table are no longer modest. Clean Fuels leadership, aligned with petroleum stakeholders, originally coalesced around a unified request of 5.25 billion gallons. The response from the Environmental Protection Agency landed higher: 5.61 billion gallons. Panelist Anthony Reed described the proposal as “historic increases,” representing a two-billion-gallon jump over three years.

Kurt Kovarik, Vice President of Federal Affairs, captured the room’s disbelief with a line that rippled through the audience: “Sometimes I think I’m dreaming… but it’s reality.”

The industry has spent years arguing that volumes needed to grow to meet climate and energy security goals. Now, improbably, it may get more than it asked for. And yet — this is Wonderland — the ride doesn’t move until the operator flips the switch.

The Waiting Game

Despite optimism on volumes, the industry remains stuck in a holding pattern. The EPA has missed its statutory deadline, and key decisions remain unresolved. Kovarik estimated that once the White House signals final decisions on Small Refinery Exemptions (SREs) and import accounting, the rule could land within six to eight weeks. All signs point to a final rule in February or early March — but only after those signals are sent.

Until then, the industry waits with engines idling.

Two Mysteries Still Unresolved: SREs and 45Z

Two regulatory choke points continue to define the risk profile.

First: SRE reallocation. The industry is pushing for 100 percent reallocation of exempted volumes. Kate Shenk presented data showing that failure to do so could depress soybean prices by 20 to 40 cents per bushel — a politically resonant figure in rural America and a reminder that accounting decisions ripple outward.

Second: the 45Z tax credit. While the “One Big Beautiful Bill” extended the credit, Treasury guidance has yet to arrive. Tim Urban described it as imminent — “any moment now” — but cautioned that once released, the rulemaking process will be complex and will require immediate, detailed industry engagement. In other words: the math may work on paper, but only if the volumes are honored — and the incentives align — in the real world. Which is where gravity reasserts itself.

Feedstock Frenzy: “Boom. It’s Done.”

If policy uncertainty sets the mood, feedstocks define the stakes.

The Feedstock Frenzy session exposed the growing tension between volatile global trade and rising domestic capability. Moderated by Alan Weber, the panel brought together voices spanning the supply chain — Restaurant Technologies, StoneX, Corteva, and Fastmarkets — and delivered one consistent message: optionality disappears fast. Ryan Standard offered the session’s most memorable line while describing how tariffs can sever trade flows overnight: “You think this is a business that’s going to continue for a couple of years. Fifty percent tariff. Boom. It’s done.”

Tallow once destined for U.S. markets is rerouted instantly — to Europe, to Singapore — and even when specific tariffs fade, Standard warned that “general uncertainty” lingers. The result, he said, is a market where many participants are simply “afraid to trade.” That anxiety is most acute around Chinese used cooking oil. The panel stressed that the true enemy isn’t competition, but fraudulent blending — virgin oils masquerading as waste to game carbon intensity scores. The fix, they argued, is traceability down to the restaurant level.

And yet, amid the turbulence, the domestic outlook was strikingly confident. One panelist estimated that 4.25 to 4.5 billion gallons of the coming mandate could be met domestically — very easily — without major price ripples. The constraint is not feedstock scarcity so much as timing.

Innovation will have to do the heavy lifting. Chad Edwards highlighted Corteva’s collaboration with Bunge and Chevron to develop winter canola as a rotational crop in the Mid-South — a promising pathway, but one governed by biology, not bureaucracy. These are long cycles of investment, he reminded the room, and they only work with predictable markets. The structural signal was unmistakable: imports may have helped suppress prices, but integrity concerns and the architecture of the 45Z credit are quietly shifting advantage back toward traceable, North American feedstocks.

The Obligation Beneath the Opportunity: We Gotta Hit it

Which brings the industry back to the question echoing through every session — not whether the volumes are possible, but whether the rules arrive in time to build them responsibly. Anthony Reed put it plainly: “No pressure… but if we get the RVO that we’re asking for, we gotta hit it.” After a year of under-generation driven by uncertainty, 2026 becomes the year where ambition meets execution. The ride may finally be moving — but the safety bar isn’t fully locked yet.

In Wonderland, clocks tick differently. In clean fuels, they don’t.