Brazil’s CS-SAF certificate: how the new aviation fuel mechanism works and what remains unresolved

Why it matters: Sustainable aviation fuel is the primary lever airlines have to comply with Brazil’s new emission-reduction mandate, yet the country has only one commercial-scale producer (Petrobras, via coprocessing at a single delivery point, Galeão Airport in Rio de Janeiro) and the final regulations from ANAC and ANP are due by December 18, just 13 days before the obligation kicks in. The gap between ambition and operational readiness makes the design of the CS-SAF certificate, and the book-and-claim mechanism it enables, a decisive factor in whether the program launches smoothly or creates compliance chaos.

What the book-and-claim mechanism changes for Brazilian airlines

The CS-SAF certificate is not a carbon credit. It does not represent a fixed quantity of avoided CO2. Its value depends on the carbon intensity of the specific SAF batch, which varies by feedstock and production process. What makes it operationally significant is the book-and-claim provision: an airline can purchase the environmental attribute of SAF produced and delivered at one location while burning conventional jet fuel at another. In practice, an airline operating out of Manaus can buy the emission reduction associated with SAF delivered at Galeão in Rio de Janeiro, burn regular kerosene in its aircraft, and still count the reduction toward its compliance target. The airline that physically received the SAF in Rio, in turn, cannot register that same reduction. This separation of the physical fuel from its environmental attribute is designed to solve a real logistical bottleneck. With Petrobras as the sole commercial SAF producer and Galeão as the only delivery point, requiring physical SAF use at every airport would make compliance impossible for most routes. Book-and-claim turns a geographic constraint into a tradeable system.

What is still undecided and what needs to happen

Several critical elements remain open. ANAC and ANP have not yet published their final regulations. The public consultation on ANAC’s proposed rules closed on October 1, but the final text is still pending. The December 18 deadline for publication leaves a narrow window for operators to adapt systems, negotiate SAF supply contracts and understand certificate pricing before the January 2027 start date. The rules for CS-SAF issuance (by producers or ANP-authorized distributors), retirement (when presented to ANAC for compliance) and potential secondary trading are outlined in the ProBioQAV framework, but the operational details of a certificate market, including registry infrastructure, verification protocols and pricing transparency, are not yet defined. The article notes that the CS-SAF has potential to become a traded asset across markets, which could help finance SAF expansion in Brazil, but this depends on regulatory adjustments that have not been made.

Who benefits and who faces pressure

Petrobras and Vibra (its distribution partner) hold a structural advantage as the only current commercial SAF supply chain in the country. Any airline needing certificates must, for now, source them from this single pipeline. Airlines with operations concentrated at or near Galeão have a logistical edge in physically receiving SAF, while airlines with dispersed regional networks depend entirely on book-and-claim to comply without prohibitive transport costs. The 10,000-tonne threshold for the obligation protects smaller operators but concentrates compliance costs on the 13 largest, which include the three major carriers. For SAF producers planning new capacity, the timeline creates both opportunity (guaranteed demand from 2027) and risk (regulatory uncertainty just months before the mandate). The absence of competitive SAF supply means certificate prices will likely reflect Petrobras’s production costs and margins, at least initially, with no market mechanism to drive prices down until new producers enter.

via Reset