- within Wealth Management topic(s)
As part of the regulatory framework for the Future Fuels Act (Law No. 14,933/2024), Brazil's Ministry of Mines and Energy has launched a public consultation on the draft Decree regulating the National Sustainable Aviation Fuel Program (ProBioQAV).
The proposal creates a market-based instrument aimed at decarbonizing the civil aviation sector and establishes a new environmental asset: the Sustainable Aviation Fuel Sustainability Certificate (CS-SAF). The mechanism follows a structure similar to the Decarbonization Certificate under the RenovaBio program and the Biomethane Guarantee of Origin Certificate for the biomethane market.
Under ProBioQAV, greenhouse gas emission-reduction targets will be imposed on airline operators for domestic flights, to be met through the acquisition and retirement of CS-SAFs generated by producers, importers, and blending agents. In summary:
- All sustainable aviation fuel (SAF) produced or traded in Brazil must be accompanied by a CS-SAF.
- CS-SAFs may be sold separately from the physical SAF under a book-and-claim model, in which case the delivered fuel will not carry the environmental attribute to avoid double counting.
- The system will allow CS-SAF transactions in the voluntary market, enabling any economic agent to acquire the certificates and incorporate their environmental attribute into products, processes, or emissions inventories.
- The National Agency for Petroleum, Natural Gas and Biofuels will define the criteria, methodologies, and procedures for SAF sustainability eligibility and certification, which may follow guidelines from the Carbon Offsetting and Reduction Scheme for International Aviation or updated parameters under RenovaBio.
- The National Civil Aviation Agency will oversee compliance with individual targets applicable to airline operators.
The public consultation will remain open for contributions until December 28, 2025.
The Environmental, Climate Change & Sustainability Practice of Tauil & Chequer Advogados, in association with Mayer Brown, is available for further clarifications and to support the preparation of submissions to the public consultation.
Visit us at mayerbrown.com
Mayer Brown is a global services provider comprising associated legal practices that are separate entities, including Mayer Brown LLP (Illinois, USA), Mayer Brown International LLP (England & Wales), Mayer Brown (a Hong Kong partnership) and Tauil & Chequer Advogados (a Brazilian law partnership) and non-legal service providers, which provide consultancy services (collectively, the "Mayer Brown Practices"). The Mayer Brown Practices are established in various jurisdictions and may be a legal person or a partnership. PK Wong & Nair LLC ("PKWN") is the constituent Singapore law practice of our licensed joint law venture in Singapore, Mayer Brown PK Wong & Nair Pte. Ltd. Details of the individual Mayer Brown Practices and PKWN can be found in the Legal Notices section of our website. "Mayer Brown" and the Mayer Brown logo are the trademarks of Mayer Brown.
© Copyright 2025. The Mayer Brown Practices. All rights reserved.
This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.
