The 45Z Clean Fuel Production Credit can reward a lower carbon intensity (CI) score earned in the field. That score only has value if the documentation makes it through every change of ownership between the farm and the plant, and then holds up to the credit buyer’s review. Treasury’s Notice 2026-53 ties reduced-CI claims to USDA’s chain-of-custody and verification standards in 7 CFR Part 2100, and final regulations are still pending. So for elevators, merchandisers, and ethanol plants, this is now a practical question, not a theoretical one.

One question is still open across the market: who keeps the mass balance books, and where? A new article from the Clean Fuel Credit Consortium (CFCC) works through the rule text and how commercial grain actually trades, and offers a clear reading.

Chain of custody isn’t about where the grain sits. It’s about who holds title.

Three Takeaways for Grain Companies

1. The books follow the owner, not the bin.

   Part 2100’s chain-of-custody requirements apply to every party that “produces, processes, or takes ownership” of scored grain. A paper trader that takes title keeps mass balance books and is audited on them. A broker who never takes title keeps none.

2. One balance per entity, not per location.

   Scored bushels bought plus opening stock must equal scored bushels sold plus closing stock, by CI, over periods of no more than three months. The rule’s recordkeeping subpart never uses a site or facility as the unit of accounting.

3. The paper trail travels with every sale.

   Each sale carries three documents: proof the seller was verified, the farm’s Biofuel Feedstock Report, and a signed attestation of amount and CI. A unique field identifier on every report is the market’s most direct control against double counting.

Solentra is a member of the Clean Fuel Credit Consortium. We’re sharing this article because its question, where 45Z records live as grain changes hands, runs through the contracts, ledgers, and audits grain companies deal with every day. The reading is the Consortium’s own, and it is open for industry comment.

When the final rules land, will your records show exactly which scored bushels you owned, and when?

USDA, Treasury, and the IRS have not reviewed or endorsed the Consortium’s article or protocol.