Summary
Details
- Brazil
Mandatory duties attach to entities that fall within programme-defined obligated categories once implementing rules assign targets, reporting, certification or operational controls.
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What’s Required
1) Identify which regulated roles apply: producer, importer, distributor, airline, or downstream obligated entity
Law 14,993/2024 is structured around programmes that assign responsibilities to specific parts of the value chain. A compliance approach starts by mapping the company’s role(s):
producer and importer of aviation fuel components and SAF.
producer and importer of diesel and renewable diesel (diesel verde).
natural gas producers/importers and market participants in decarbonization and biometane incentive structures.
aviation operators and fuel suppliers, depending on the implementing rules.
This matters because the law is enabling, but it is designed to become operationally mandatory via programme rules that allocate compliance duties.
2) Build programme compliance capability: eligibility, certification, chain of custody and data governance
Low-carbon fuel programmes typically rely on traceability and sustainability attributes. Even before all implementing rules are issued, companies should prepare for:
feedstock and origin documentation (especially where sustainability criteria are expected).
mass balance or book-and-claim chain-of-custody controls.
carbon intensity methodology alignment, where applicable.
segregation and product integrity controls across production, blending, transport, storage and delivery.
audit readiness for regulators and certification bodies.
These controls reduce the risk of the product being rejected for programme compliance purposes or of enforcement actions for misrepresentation.
3) Manage cross-regime interactions: RenovaBio, ANP fuel rules, aviation operational constraints
Brazil already has a mature decarbonization regime for fuels through RenovaBio (CBIOs), and fuel quality and commercialization rules under ANP. The “Combustível do Futuro” law can interact with existing obligations, creating compliance complexity:
duplicate or overlapping reporting streams.
different sustainability definitions across regimes.
interaction between programme requirements and ANP specs for fuels and blending.
contractual allocation of compliance costs between suppliers and purchasers.
Compliance teams should implement a “regime map” showing how programme obligations align with existing fuel regulations and carbon instruments, and where a single dataset can support multiple filings without inconsistencies.
4) Treat aviation SAF as a high-integrity compliance category with operational delivery constraints
SAF compliance differs from road fuels because aviation has stringent operational and safety requirements and a concentrated supply chain. A practical compliance plan should cover:
documentation of fuel specification compliance and traceability.
operational interfaces at airports and fuel farms.
contractual clauses allocating sustainability attribute ownership and claims.
controls preventing double claims, especially where SAF attributes may be monetized or reported by different parties.
Because SAF is often linked to corporate decarbonization claims, chain-of-custody and retirement of attributes become compliance-critical.
5) Prepare for transitional implementation and phased obligations
Programme-based laws often create:
phased compliance timelines
pilot phases, reporting-only phases, then binding targets.
differentiated duties for small vs large market participants.
Companies should establish a regulatory watch process for implementing decrees and ANP/MME technical rules and create internal readiness milestones: system build, data pipeline, contract updates, audit preparation, and operational procedures.
6) Strengthen governance against greenwashing and mislabeling risk
As low-carbon fuels become regulated, marketing and sustainability claims will be tested against legal definitions. Companies should implement:
claims approval workflows requiring evidence.
linkage between claims and programme-compliant documentation.
controls over third-party statements in the supply chain.
procedures for correcting claims if certification status changes.
This is particularly important for exporters, airlines, and corporates using fuels to support public targets.
Important Deadlines
Date of adoption: 8 October 2024.
Entry into force: as a federal law, effective upon publication, with operational duties depending on programme implementation rules.
Compliance milestones: defined by the implementation of ProBioQAV, PNDV and biometane-related programmes, including any phased targets, reporting start dates, certification requirements and enforcement start points.
Current Status
In force as a federal programme framework, supported by official energy transition communications that position it as a policy pillar for low-carbon fuels diversification. Companies should monitor implementing acts from MME and technical regulation updates that operationalize obligations.
Penalties for Non-Compliance
Enforcement is expected to run through:
administrative measures under fuel market regulation and programme-specific sanctions
market access controls, such as denial of programme recognition for product batches
contractual penalties and claims if supply commitments rely on programme qualification
civil and consumer enforcement exposure for misleading sustainability claims
In low-carbon fuels, the highest operational penalty is often economic: inability to market product as programme-compliant, plus corrective costs and reputational impact.
Examples of Known Violations
Typical failure modes in low-carbon fuels compliance programmes include:
traceability failures: incomplete chain-of-custody records, making the product ineligible
attribute double claiming: multiple parties claiming the same sustainability attributes
misclassification of feedstocks: poor documentation leading to sustainability eligibility disputes
data quality errors: inconsistent reporting across programme filings and existing fuel regimes
contract mismatch: contracts promise compliance attributes without allocating who bears certification and verification costs
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