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ARTICLE · 08 JUNE 2026

Section 45Z Proposed Regulations Hearing Update: Emerging Themes

The U.S. Department of Treasury and Internal Revenue Service held a three-day hearing in May 2026 to address industry concerns about proposed regulations for the Section 45Z clean fuel production tax credit.

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The U.S. Department of Treasury and Internal Revenue Service issued proposed regulations for section 45Z on Feb. 4, 2026. The proposed regulations provided detail, and, in most cases, clarity on critical provisions that help identify qualifying elements of the 45Z credit. These proposed regulations received substantial commentary from industry, resulting in Treasury and the IRS holding a three-day hearing from May 27 – May 29, 2026 to discuss the proposed regulations with constituencies ranging from think tanks and fuel producers to dairy farmers.

Section 45Z Background

Internal Revenue Code Section 45Z provides a technology-neutral clean fuel production credit for qualifying transportation fuel sold after Dec. 31, 2024 and before Jan. 1, 2028, with credit amounts tied to lifecycle greenhouse gas emissions and enhanced amounts available where prevailing wage and apprenticeship requirements are satisfied. Like all production tax credits, section 45Z credits are not subject to

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