No, a refinery that only inputs unfinished petroleum products would not meet the definition of refinery in §98.390 and would not be required to report under subpart MM. However, if you import or export petroleum products or NGLs at an amount equal to or greater than 25,000 metric tons of CO2, you are subject to reporting as an importer or exporter under subpart MM. Note that all refineries are subject to reporting under subpart Y (regardless of what materials they input) and possibly other subparts (e.g., subpart C).