Statement of Dana Brooks, President and CEO, Pet Food Institute
July 8, 2025, EPA Hearing on Proposed Renewable Fuel Standards for 2026 and 2027
Good afternoon, I am Dana Brooks, President and CEO, of the Pet Food Institute which represents the makers of the vast majority of pet food and treats manufactured in the United States for 94 million U.S. households that own a pet.
The Pet Food Institute is concerned about the significant increase in biomass-based diesel volumes in EPA’s proposed Renewable Fuel Standards for 2026 and 2027 along with the proposal to cut RIN values in half for imported renewable fuels and feedstocks.
These policies combined with the Clean Fuel Production Credit, known as 45Z, encourage biofuel refiners to compete directly with the edible fats and oils used in human and animal food as well as non-food sectors.
The 45Z tax credit is extended through 2029 and mandates to qualify for this credit, fuel must be made in the United States with feedstocks grown or produced in the U.S., Mexico or Canada.
We agree with market analysts who expect that renewable fuel demand will continue to exert upward pressure on animal fat prices, leading to significantly higher input costs for pet food manufacturing.
U.S. pet food makers use over 600 million pounds of animal fats annually. We use high-quality fats to provide essential nutrients that perform key functions in dog and cat immune and visual systems, as well as support healthy skin and coats. Manufacturers do not have the luxury of substituting fats and oils in pet food formulations.
In the last two years, 49 percent of the biomass-based diesel produced in the U.S. consumed vegetable oils, animal fats and used cooking oils. More refiners prefer to use animal fats as feedstocks due to the higher tax credits they receive based on a lower carbon intensity score.
We urge the EPA to consider the competition for limited resources for food, feed, and fuel. Since the EPA has determined it is feasible to sub-allocate RINs based on the source of fuels and feedstocks – whether that is foreign or domestic, we hope the EPA will now consider a similar sub-allocation of RINs among the types of feedstocks.
We believe that this next evolution in renewable energy production could help reduce the pressure on animal fats as refiners could use more waste-based domestic feedstocks such as used cooking oil or algae.
We ask the EPA to explore ways to assign different RIN values to each feedstock and cap the number of RINs that can be generated from animal fats for renewable diesel production.
On behalf of PFI’s members, whose 35,000 employees in 34 states provide safe food for millions of dogs and cats across the United States, we thank you for the opportunity to share our views.