Part III - Administrative, Procedural, and Miscellaneous

Section 45Z Clean Fuel Production Credit; Emissions Rates; Request for Comments

Notice 2025-11

SECTION 1. PURPOSE

This notice provides initial guidance on emissions rates under § 45Z(b)(1)(B) of

the Internal Revenue Code (Code) 1 for the clean fuel production credit determined

under § 45Z (§ 45Z credit). This notice also requests comments from the public related

to emissions rates for the § 45Z credit to assist the Department of the Treasury

(Treasury Department) and the Internal Revenue Service (IRS) in developing additional

guidance. See also Notice 2025-10, this Bulletin, that describes forthcoming proposed

regulations that the Treasury Department and the IRS intend to issue that would

address definitions, emissions rates, credit eligibility, calculation of the credit amount,

registration, certification, claim filing, and required recordkeeping.

The Treasury Department and the IRS developed this notice and Notice 2025-10

in consultation with the Department of Energy (DOE), the Environmental Protection

Agency (EPA), the United States Department of Agriculture, and other federal agencies.

1
Unless otherwise specified, all references to “section” or “§” are references to sections of the Code.
SECTION 2. BACKGROUND

.01 In general. Section 45Z, added to the Code by § 13704 of Public Law 117-

169, 136 Stat. 1818, 1997 (August 16, 2022), commonly known as the Inflation

Reduction Act of 2022, provides an income tax credit for clean transportation fuel

produced domestically after December 31, 2024, and sold by December 31, 2027. The

§ 45Z credit is a general business credit under § 38.

A taxpayer must meet several requirements to be eligible to claim the § 45Z

credit. Generally, a taxpayer must: (1) produce a transportation fuel that has a lifecycle

greenhouse gas emissions rate (emissions rate) of not greater than 50 kilograms (kg) of

carbon dioxide equivalent based on relative global warming potential (CO2e) per million

British thermal units (mmBTU) and that satisfies certain suitability and coprocessing

requirements; (2) produce the fuel in the United States at a qualified facility; (3) be

registered as a producer of clean fuel under § 4101 at the time of production; and (4)

sell the fuel to an unrelated person in a qualifying manner during the taxable year. See

§ 45Z(a)(1) & (4), (d)(4)-(5)(A), and (f)(1). A taxpayer producing a transportation fuel

that is sustainable aviation fuel (SAF transportation fuel) must also provide unrelated

party certification demonstrating compliance with certain requirements. See

§ 45Z(f)(1)(A)(i)(II).

For purposes of § 38, the § 45Z credit is an amount equal to the product of (A)

the applicable amount per gallon (or gallon equivalent) with respect to any

transportation fuel which is produced by the taxpayer at a qualified facility and sold in

the manner described in § 45Z(a)(4) during the taxable year and (B) the emissions

factor for such fuel as determined under § 45Z(b). See § 45Z(a)(1).

-2-
 For a fuel to be eligible for the § 45Z credit, one requirement is that it must have

an emissions rate that is not greater than 50 kg of CO2e per mmBTU. See

§ 45Z(d)(5)(A)(ii). This is the baseline emissions rate. The amount of the credit is

based on the transportation fuel’s emissions factor, which is a calculation of the fuel’s

emissions rate against the baseline emissions rate. See § 45Z(b)(1)(A)(i).

.02 Emissions factor. The emissions factor for a transportation fuel is the

quotient of 50 kilograms of CO2e per mmBTU, minus the emissions rate for such fuel,

divided by 50 kilograms of CO2e per mmBTU. See § 45Z(b)(1)(A)(i). Expressed

mathematically, the calculation is as follows: Emissions factor = (50 kg of CO2e per

mmBTU - emissions rate in kg of CO2e per mmBTU) ÷ 50 kg of CO2e per mmBTU.

Under § 45Z(b)(2), if any amount determined under § 45Z(b)(1)(A) is not a

multiple of 0.1, such amount must be rounded to the nearest multiple of 0.1.

.03 Applicable amount. Section 45Z(a)(2) and (3) provide the applicable

amounts for transportation fuels. Section 45Z(c)(1) provides that for calendar years

beginning after 2024, the applicable amounts in § 45Z(a)(2) and (3) must each be

adjusted by multiplying such amount by the inflation adjustment factor for the calendar

year in which the sale of the transportation fuel occurs. Section 45Z(c)(2) provides that

the inflation adjustment factor for the § 45Z credit is the inflation adjustment factor

determined and published by the Secretary of the Treasury or her delegate (Secretary)

pursuant to § 45Y(c), determined by substituting “calendar year 2022” for “calendar year

1992” in § 45Y(c)(3). 2 The Treasury Department and the IRS intend to provide

2
Accordingly, the inflation adjustment factor for purposes of § 45Z means, with respect to a calendar
year, a fraction the numerator of which is the GDP implicit price deflator for the preceding calendar year

-3-
guidance on the inflation adjustment factor for the 2025 calendar year at a later time.

Such guidance will be published in the Internal Revenue Bulletin.

04. Emissions rates. Section 45Z divides transportation fuel into two categories:

non-SAF transportation fuel and SAF transportation fuel. Section 45Z(b)(1)(B)(ii) and

(iii) provides the methods for determining emissions rates for non-SAF transportation

fuel and SAF transportation fuel.

Section 45Z(b)(1)(B)(i) directs the Secretary, subject to § 45Z(b)(1)(B)(ii) and (iii),

to annually publish a table that sets forth the emissions rates for similar types and

categories of transportation fuels based on the amount of lifecycle greenhouse gas

emissions 3 as described in § 211(o)(1)(H) of the Clean Air Act (42 U.S.C. 7545(o)(1)(H))

as in effect on August 16, 2022 (CAA) 4 for such fuels, expressed as kg of CO2e per

mmBTU. This notice contains the initial table that sets forth such emissions rates for

purposes of the § 45Z credit. See section 4.05 of this notice and the appendix to this

notice.

Regarding the determination of emissions rates, § 45Z(b)(1)(B)(ii) provides that

in the case of non-SAF transportation fuel, the lifecycle greenhouse gas emissions of

and the denominator of which is the GDP implicit price deflator for the calendar year 2022. In this
context, the term “GDP implicit price deflator” means the most recent revision of the implicit price deflator
for the gross domestic product as computed and published by the Department of Commerce before
March 15 of the calendar year. See § 45Y(c)(3).
3
Section § 211(o)(1)(H) of the Clean Air Act defines the term “lifecycle greenhouse gas emissions” as
“the aggregate quantity of greenhouse gas emissions (including direct emissions and significant indirect
emissions such as significant emissions from land use changes), as determined by the [EPA]
Administrator, related to the full fuel lifecycle, including all stages of fuel and feedstock production and
distribution, from feedstock generation or extraction through the distribution and delivery and use of the
finished fuel to the ultimate consumer, where the mass values for all greenhouse gases are adjusted to
account for their relative global warming potential.” See also 42 U.S.C. 7602(a).
4
This notice cites to the CAA as added by § 1501(a)(2) of the Energy Policy Act of 2005, Public Law 109-
58, 119 Stat. 594, 1067 (2005) and amended by § 202(a)(1) of the Energy Independence and Security
Act of 2007, Public Law 110-140, 121 Stat. 1492, 1521-22 (2007).
-4-
such fuel must be based on the most recent determinations under the Greenhouse

gases, Regulated Emissions, and Energy use in Transportation model developed by the

Argonne National Laboratory (ANL), or a successor model as determined by the

Secretary.

Section 45Z(b)(1)(B)(iii) provides that for SAF transportation fuel, the lifecycle

greenhouse gas emissions of such fuel is determined in accordance with (I) the most

recent Carbon Offsetting and Reduction Scheme for International Aviation (CORSIA)

which has been adopted by the International Civil Aviation Organization (ICAO) with the

agreement of the United States or (II) any methodology similar to the most recent

CORSIA that satisfies the criteria under § 211(o)(1)(H) of the CAA.

Section 3 of this notice provides background on the methodologies used to

determine emissions rates.

Section 4 of this notice instructs taxpayers how to calculate emissions rates

using either (1) determinations under the most recent version of the 45ZCF-GREET

model or (2) determinations from fuel pathways approved under the most recent

CORSIA Default Life Cycle Emissions Values for CORSIA Eligible Fuels lifecycle

approach (CORSIA Default) or the most recent CORSIA Methodology for Calculating

Actual Life Cycle Emissions Values lifecycle approach (CORSIA Actual).

Section 45Z(b)(1)(D) provides that in the case of any transportation fuel for which

an emissions rate has not been established under § 45Z(b)(1)(B), a taxpayer producing

such fuel may file a petition with the Secretary for determination of the emissions rate

with respect to such fuel, also known as a provisional emissions rate (PER). See

section 4.05 and 4.06 of this notice.

-5-
SECTION 3. ALLOWED METHODOLOGIES FOR DETERMINING EMISSIONS

RATES

.01 CORSIA Program. Emissions rates for SAF transportation fuels are

determined under the CORSIA program based on the modeling of the fuel lifecycle,

including all stages of fuel and feedstock production through to the end use of the

finished fuel, to calculate and reduce greenhouse gas emissions from international

aviation. In 2016, ICAO adopted CORSIA, which is set out in Annex 16 - Environmental

Protection: Carbon Offsetting and Reduction Scheme for International Aviation

(CORSIA) (2018), https://elibrary.icao.int/home/product-details/229739.

Using the CORSIA program, there are two ways of obtaining the lifecycle

emissions value of a SAF transportation fuel: (1) CORSIA Default and (2) CORSIA

Actual. Additional information about CORSIA Default and CORSIA Actual is available

at https://www.icao.int/environmental-protection/CORSIA/Pages/CORSIA-Eligible-

Fuels.aspx.

.02 45ZCF-GREET model.

Administration of the § 45Z credit requires a determination of the emissions rates

of different types and categories of fuels consistently and accurately, including fuels

made from different pathways and primary feedstocks (as provided in the emissions

rate table). ANL developed, and the DOE published, the 45ZCF-GREET model to

determine emissions rates for the § 45Z credit that also meets three key parameters: (1)

user-friendliness and consistency, (2) technical robustness of the pathways

represented, and (3) consistency with the other requirements of § 45Z.

-6-
 The first version of the 45ZCF-GREET model, anticipated to be released on

January 10, 2025, is available at https://www.energy.gov/eere/greet. The first version of

the 45ZCF-GREET model includes the most commonly used types and categories of

fuel that are anticipated to meet the eligibility requirements to claim the § 45Z credit.

Additional types and categories of fuel may be added in future versions of the 45ZCF-

GREET model. See the 45ZCF-GREET User Manual 5 for additional background.

SECTION 4. DETERMINATION OF EMISSIONS RATES

.01 Most recent determinations under the 45ZCF-GREET model. Taxpayers

must use the most recent determinations under the 45ZCF-GREET model for non-SAF

and SAF transportation fuels. The term “the most recent determinations” means

determinations under the latest version of the 45ZCF-GREET model (described in

section 3.02 of this notice) that is publicly available on the first day of the taxable year in

which the transportation fuel for which the taxpayer is claiming the § 45Z credit was

produced. See also Notice 2025-10.

If a version of the 45ZCF-GREET model adds a type or category of fuel after the

first day of a taxable year, taxpayers must use such version of the 45ZCF-GREET

model for the new type or category of fuel for the entire taxable year. Additionally, if an

updated version of the 45ZCF-GREET model becomes publicly available after the first

day of the taxable year of production (but still within such taxable year), then the

taxpayer may, in its discretion, treat such updated version as the most recent version of

the 45ZCF-GREET model.

5
The 45ZCF-GREET User Manual, along with the 45ZCF-GREET model, is available at:
https://www.energy.gov/eere/greet.
-7-
 .02 Most recent version of CORSIA Default or CORSIA Actual. For purposes of

§ 45Z(b)(1)(B)(iii)(I), the term “most recent” means the latest version of CORSIA Default

or CORSIA Actual (described in section 3.01 of this notice) that is publicly available on

the first day of the taxable year in which the SAF transportation fuel for which the

taxpayer is claiming the § 45Z credit was produced. Additionally, if an updated version

of CORSIA Default or CORSIA Actual becomes publicly available after the first day of

the taxable year of production (but still within such taxable year), then the taxpayer may,

in its discretion, treat such updated version as the most recent version of CORSIA

Default or CORSIA Actual.

At the time of publication of this notice, the most recently published versions of

CORSIA Default (Sixth Edition, October 2024) and CORSIA Actual (Fifth Edition,

October 2024) are both available at: https://www.icao.int/environmental-

protection/CORSIA/Pages/CORSIA-Eligible-Fuels.aspx

.03 Determining emissions rates for non-SAF transportation fuels. If an

emissions rate for a non-SAF transportation fuel is established under § 45Z(b)(1)(B)(i)

(which means that the type and category of non-SAF transportation fuel is established

in the most recent determinations under the emissions rate table), a taxpayer producing

such type and category of fuel must use the most recent determinations under the

emissions rate table to determine the fuel’s emissions rate. See section 4.06 of this

notice if the non-SAF transportation fuel is not established in the most recent

determinations under the 45ZCF-GREET model.

.04 Determining emissions rates for SAF transportation fuel. If an emissions rate

for a SAF transportation fuel is established under § 45Z(b)(1)(B)(i) (which means that

-8-
the type and category of SAF transportation fuel is established in the most recent

determinations under the emissions rate table), a taxpayer producing such type and

category of fuel must determine the SAF emissions rate pursuant to (1) an analysis

using the most recent version of CORSIA Default or CORSIA Actual (see section 4.02

of this notice or (2) an analysis using the most recent determinations under the

45ZCF-GREET model (see section 4.01 of this notice). For a given SAF transportation

fuel, a taxpayer must use the same methodology for determining the emissions

associated with all stages of fuel feedstock production and distribution.

If the Treasury Department and the IRS conclude that an additional methodology

qualifies under § 45Z(b)(1)(B)(iii)(II), instructions for how to use such methodology will

be provided in additional guidance.

See section 4.06 of this notice if a type or category of SAF transportation fuel is

not established in the most recent version of CORSIA Default or CORSIA Actual.

.05 Initial emissions rate table. The initial emissions rate table required by

§ 45Z(b)(1)(B)(i) is provided in the appendix of this notice. Each emissions rate

determined under section 4 of this notice must be determined by calculating the lifecycle

greenhouse gas emissions (as defined in § 211(o)(1)(H) of the CAA) for such type and

category of fuel and must be expressed in kg of CO2e per mmBTU.

When calculating the emissions rate for purposes of determining the amount of

the § 45Z credit, the taxpayer must accurately enter all information requested for the

allowed methodology and must follow the publicly available instructions provided by the

relevant authority (the DOE or ICAO). For example, a taxpayer calculating an

emissions rate using the most recent determinations under the 45ZCF-GREET model

-9-
must enter all information requested within the interface of the 45ZCF-GREET model

and must follow the instructions in the most recent version of the 45ZCF-GREET User

Manual.

.06 Provisional emissions rate (PER). Section 45Z(b)(1)(D) provides that for any

transportation fuel for which an emissions rate has not been established under

§ 45Z(b)(1)(B), meaning a type or category of fuel that is not established in the most

recent determinations under the 45ZCF-GREET model (for non-SAF transportation fuel)

or that is not established in the most recent determinations under the 45ZCF-GREET

model or the most recent version of CORSIA Default or CORSIA Actual (for SAF

transportation fuel), a taxpayer producing such type or category of fuel may file a

petition with the Secretary for determination of a PER. A taxpayer requesting a PER is

referred to as an “applicant.”

The Treasury Department and the IRS intend to provide guidance related to the

PER petition process, including the process for obtaining an emissions value from the

DOE that an applicant will use to request a PER determination, at a later time. The IRS

will not accept requests for PER determinations for the § 45Z credit, and the DOE will

not issue emissions values, until after such guidance is published. For purposes of the

§ 45Z PER process, an emissions value is a value obtained from the DOE setting forth

the DOE’s analytical assessment of the lifecycle greenhouse gas emissions rate

associated with the production of a type of transportation fuel using a particular primary

feedstock and pathway.

.07 New emissions rates (including PER) apply on January 1, 2025. The

emissions rate for any new type or category of fuel established on the applicable

- 10 -
emissions rate table or determined through the PER process will apply on January 1,

2025, regardless of when the Treasury Department and the IRS publish guidance

establishing an emissions rate or PER.

SECTION 5. DEFINITIONS AND ADDITIONAL GUIDANCE

Terms used in this notice have the same meaning as in § 45Z and in the

appendix to Notice 2025-10. For additional guidance regarding the § 45Z credit, see

Notice 2025-10.

SECTION 6. REQUEST FOR COMMENTS

.01 General request for comments. The Treasury Department and the IRS

generally request comments about all aspects of this notice.

.02 Specific request for comments. The Treasury Department and the IRS

specifically request comments on how the fuel pathways approved under the EPA’s

Renewable Fuel Standards Program (RFS) could be adapted for purposes of the

emissions rate table if the Treasury Department and the EPA were to determine that the

RFS program is a methodology “similar” to CORSIA that also satisfies the criteria under

§ 211(o)(1)(H) of the CAA (as required by § 45Z(b)(1)(B)(iii)(II)).

SECTION 7. SUBMISSION OF COMMENTS

Written comments should be submitted by April 10, 2025. The subject line for

the comments should include a reference to Notice 2025-11. Comments may be

submitted in one of two ways:

(1) electronically via the Federal eRulemaking Portal at

http://www.regulations.gov (type IRS-2025-0002 in the search field on the

regulations.gov homepage to find this notice and submit comments); or

- 11 -
 (2) by mail to: Internal Revenue Service, CC:PA:01:PR (Notice 2025-11), Room

5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.

All commenters are strongly encouraged to submit comments electronically. The

Treasury Department and the IRS will publish for public availability any comment

submitted electronically, or on paper, to its public docket on www.regulations.gov.

SECTION 8. EFFECTIVE DATE

This notice is effective January 10, 2025.

SECTION 9. DRAFTING INFORMATION

The principal author of this notice is Camille Edwards Bennehoff of the Office of

Associate Chief Counsel (Passthroughs & Special Industries). For questions regarding

this notice, contact Ms. Edwards Bennehoff at (202) 317-6855 (not a toll-free number).

- 12 -
 Appendix
Section 45Z Emissions Rate Table
For Use For Fuel Produced After 12/31/2024
Category of Fuel Determination of
Emissions Rate
Type of Fuel (calculated to be
Pathway Primary feedstock
expressed in kg of
CO2e/mmBTU)
U.S. corn starch
U.S. sorghum grain
Fermentation Brazilian sugarcane (for
use as feedstock for SAF-
Calculate using the most
Alcohol-to-Jet (ATJ) only)
recent determinations
Ethanol under the 45ZCF-GREET
model (see section 4.01 of
Hydrolysis and U.S. corn stover this notice).
Fermentation

U.S. soybean oil

U.S./Canadian canola
Biodiesel Transesterification
oil/rapeseed oil

U.S. used cooking oil

(UCO)

Tallow Calculate using the most

U.S. distillers corn oil recent determinations
(DCO) under the 45ZCF-GREET
model (see section 4.01 of
U.S. carinata oil this notice).
(intermediate crop)

U.S. camelina oil

(intermediate crop)

U.S. pennycress oil

(intermediate crop)

U.S. soybean oil

Hydroprocessed
U.S./Canadian canola
Renewable Diesel esters and fatty Calculate using the most
oil/rapeseed oil
acids (HEFA) recent determinations
under the 45ZCF-GREET
U.S. UCO
model (see section 4.01 of
this notice).
Tallow
U.S. DCO
 U.S. carinata oil
(intermediate crop)

U.S. camelina oil

(intermediate crop)

U.S. pennycress oil

(intermediate crop)

Ethanol (from
ATJ fermentation pathways
listed above)

Gasification and
Fischer-Tropsch U.S. corn stover

U.S. wastewater sludge Calculate using the most

Anaerobic U.S. animal manures recent determinations
Renewable Natural
Digestion and under the 45ZCF-GREET
Gas
Biogas Upgrading U.S. landfill gas model (see section 4.01 of
this notice).
U.S. soybean oil
U.S./Canadian
Propane HEFA
canola/rapeseed oil
U.S. UCO

Calculate using the most

Tallow recent determinations
U.S. DCO under the 45ZCF-GREET
model (see section 4.01 of
U.S. carinata oil this notice).
(intermediate crop)
U.S. camelina oil
(intermediate crop)
U.S. pennycress oil
(intermediate crop)

U.S. soybean oil

U.S. /Canadian
Naphtha HEFA
Canola/rapeseed oil
U.S. UCO
Calculate using the most
Tallow recent determinations
U.S. DCO under the 45ZCF-GREET
model (see section 4.01 of
U.S. carinata oil
this notice).
(intermediate crop)
U.S. camelina oil
(intermediate crop)
U.S. pennycress oil
(intermediate crop)

-2-
 Calculate well-to-gate
emissions using the most
recent determinations
under the 45VH2-GREET
Various, as
model; then calculate the
defined in the Various, as defined in the
full well-to-wheel emissions
user manual for user manual for the most
Hydrogen using the most recent
the most recent recent 45VH2-GREET
determinations under the
45VH2-GREET model
45ZCF-GREET model (see
model*
section 4.01 of this notice).
See the 45ZCF-GREET
User Manual for additional
instructions.
Sustainable Aviation U.S. soybean oil
HEFA
Fuel (SAF)
U.S./Canadian
canola/rapeseed oil
U.S. UCO

Tallow
U.S. DCO Calculate using one of the
following: 1) the most
U.S. carinata oil recent determinations
(intermediate crop) under the 45ZCF-GREET
model (see section 4.01 of
U.S. camelina oil this notice) or 2) the most
(intermediate crop) recent version of CORSIA
Default or CORSIA Actual
U.S. pennycress oil (see section 4.02 of this
(intermediate crop) notice).

Ethanol (from
fermentation pathways
ATJ
above)

Gasification and
U.S. corn stover
Fischer-Tropsch

Any pathway
established in Any feedstock for a
CORSIA Default pathway established in Calculate using the most
or CORSIA Actual CORSIA Default or recent version of CORSIA
for a CORSIA Actual for a Default or CORSIA Actual
transportation fuel transportation fuel that is (see section 4.02 of this
that is SAF that is SAF that is not notice).
not represented represented above.
above.

*The 45VH2-GREET model and the 45VH2-GREET User Manual are both available at
https://www.energy.gov/eere/greet.

-3-