Brazil Signs SAF Mandate, Adopts World's First Policy-Based Book-and-Claim System

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August 13, 2026

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by Gabriela Brumatti, Vinicius Damazio, Monique Murer, and Ana Paula Candil (S&P Global) ProBioQAV establishes SAF certification, book-and-claim mechanism; ANP, Anac given 240 days to issue implementing regulations; Government also establishes regulatory framework for CCUS

Brazil signed a decree on Aug. 12 regulating its National Sustainable Aviation Fuel Program, or ProBioQAV, establishing the rules for the country's SAF emissions-reduction mandate and creating what the government says is the world's first book-and-claim mechanism incorporated into public policy.

The SAF decree was one of four regulations signed by President Luiz Inácio Lula da Silva and Mines and Energy Minister Alexandre Silveira covering different areas of Brazil's energy transition. The other measures regulate carbon capture, utilization and storage, or CCUS, low-carbon hydrogen and the opening of the electricity market to low-voltage consumers.

The ProBioQAV regulation establishes rules covering SAF production, certification, commercialization and traceability, as well as compliance with greenhouse gas emissions-reduction targets for Brazil's domestic aviation sector.

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Among the most significant provisions is the creation of the SAF Sustainability Certificate, or CS-SAF, based on a book-and-claim methodology.

The mechanism allows the environmental attribute associated with SAF to be traded separately from the physical fuel, potentially allowing SAF to be supplied where logistics and production economics are most favorable while its emissions-reduction attributes are transferred to another participant.

According to the government, the mechanism is designed to improve SAF's logistical viability, facilitate its use across Brazilian airports and provide a system for registering, tracing and verifying emissions reductions. Brazil will become the first country to adopt book-and-claim as the basis of a public policy for the sector, the Mines and Energy Ministry said.

The announcement confirms comments made earlier on Aug. 12 by Laís Forti Thomaz, chief of staff of the Ministry of Mines and Energy's National Secretariat for Petroleum, Natural Gas and Biofuels, during an energy industry event in São Paulo state.

"We are going to be the first country to have book-and-claim in a normative act," Thomaz said. "That is already settled; we managed to include it in the decree."

Thomaz also said the government was working with the Finance Ministry to establish a dedicated Mercosur Common Nomenclature, or NCM, classification for SAF, while participating in international discussions aimed at "greening the Harmonized System."

"SAF has to have differentiated tax treatment because it uses renewable biomass, and it has to receive that differentiation internationally as well," she said.

Brazil's oil regulator, ANP, and civil aviation regulator, Anac, will have 240 days to issue the complementary rules necessary to make ProBioQAV operational.

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CCUS framework advances

A separate decree signed on Aug. 12 establishes conditions for carbon capture, pipeline transportation and geological storage activities in Brazil, regulating provisions of the 2024 Fuel of the Future law and creating a regulatory framework for CCS and CCUS projects.

The framework places the ANP in charge of authorizing activities through two stages: research and evaluation of potential storage areas, followed by operations. It also establishes requirements covering monitoring and the closure of storage projects.

The Mines and Energy Ministry, with support from state-owned energy research company EPE, will also develop a national infrastructure plan identifying and guiding the development of carbon capture, transportation and geological storage areas. The plan will be reviewed every two years.

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The CCUS framework could have particular relevance for Brazil's biofuels industry as producers explore carbon capture as an additional pathway to reduce the lifecycle carbon intensity of renewable fuels.

The government also signed regulations implementing Brazil's low-carbon hydrogen policy and opening the free electricity market to low-voltage consumers.

Separately, Brazil was confirmed this week as co-chair of the Council of the Global Biofuels Alliance alongside India. Brazil will also join Italy and Kenya on the organization's Executive Committee. The GBA, founded in 2023, comprises 34 countries and 14 international organizations and aims to expand biofuel production and consumption, market development, technical cooperation and sustainability initiatives. READ MORE

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Brazil publishes regulations for ProBioQAV, the country’s SAF mandate program (Ethanol Producer Magazine)
Brazil SAF rules leave market racing to resolve key issues before 2027 mandate (S&P Global)

Excerpt from S&P Global: Brazil's new sustainable aviation fuel decree has established the framework for the country's first SAF mandate, but key market rules remain undefined less than five months before the program is scheduled to begin in 2027.

Questions remain over certification, feedstock eligibility, pricing and financing, while oil regulator ANP and civil aviation regulator Anac have until Dec. 18 to issue complementary rules, leaving the industry a narrow window to adapt before the mandate, announced Aug. 13, takes effect in January.

The Fuel of the Future law requires airlines to reduce aviation greenhouse gas emissions by 1% in 2027 through SAF use, with the target increasing gradually in subsequent years.

Market participants said much of the framework was in line with expectations, with the decree establishing the broader architecture of the program while leaving implementation details to subsequent regulation.

Certification and feedstocks

One issue under scrutiny is how Brazil's certification system will interact with the Carbon Offsetting and Reduction Scheme for International Aviation, or CORSIA, as its mandatory phase also begins in 2027.

The decree allows producers to certify SAF either through the national system to be developed by ANP or under CORSIA-approved schemes. CORSIA-certified SAF will automatically qualify under the Brazilian system, but the regulation does not establish whether Brazilian CS-SAF certificates will similarly support CORSIA Eligible Fuel claims.

According to a SAF market source, aligning Brazil's certification with CORSIA could provide greater market predictability, although traceability remains a challenge for Brazilian soy. The source said a less stringent domestic certification could, on the other hand, broaden the pool of feedstocks eligible to supply domestic SAF demand.

Brazil's pool of CORSIA-certified soybean feedstocks remains limited.

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Book-and-claim raises pricing questions

The book-and-claim structure also introduces a new pricing dynamic. Under the decree, CS-SAF can be traded independently from the physical fuel until the certificate is retired. Once separated, the purchaser of the physical SAF cannot claim the associated emissions reduction.

Although most of the decree was anticipated by the market, some participants were surprised by the inclusion of book-and-claim in the national policy. Market players told Platts, part of S&P Global Energy, they are now assessing how the system could split SAF value between the physical molecule and its environmental attribute.

The structure could streamline compliance logistics because Brazil's mandate is based on annual emissions reductions rather than requiring each airline to physically blend a fixed percentage of SAF. Physical SAF could therefore be supplied where logistics are most efficient while airlines acquire certificates separately.

That flexibility could be particularly relevant in Brazil, where long-distance fuel transportation can significantly add to delivered costs.

Costs remain key concern

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José Magalhães Fernandes, Latin America president at SAF technology provider Honeywell, said at an industry event in São Paulo state Aug. 12 that advanced fuel refineries projects were waiting for greater clarity over Brazil's tax framework.

Fernandes said a robust legal and tax framework would be needed for Brazil to fulfill its potential to become what he described as "the OPEC of biofuels."

SAF also lacks a dedicated international Harmonized System classification, complicating differentiated taxation and tariff treatment.

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For airlines, costs remain central to the implementation debate. The Brazilian Airlines Association, or Abear, told Platts that large-scale SAF adoption would be viable only "if cost neutrality is guaranteed." READ MORE