Portuguese 
The revision of RenovaBio outlines specific rules for distributors during their first two years, adjusts targets for existing operators, and may lead to the loss of authorization in cases of repeated non-compliance, with recommended implementation starting January 1, 2027.
The entry of a new distributor poses a timing challenge. It begins selling fuel in the middle of an annual cycle, but the decarbonization program needs to assign a proportional obligation and define when credits should be retired.
To address this alignment, the board of the ANP approved on September 4 the Regulatory Impact Analysis and a public consultation lasting 45 days. The proposal modifies Resolution No. 791/2019, the operational foundation for individual targets.
According to the official announcement from the ANP, the agency recommends that the new resolution come into effect on January 1, 2027, allowing for system adjustments and credit purchasing planning.
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RenovaBio Revision Addresses the First Two Years
In the first year of operation, the new distributor will need to partially demonstrate compliance with the target throughout the year. In the second year, partial compliance will be evaluated on a semi-annual basis. Afterward, the agent will enter the regular rhythm of the program.
This mechanism prevents two distortions. An annual full obligation could impose demands on individuals who only operated for a few months; a complete absence of a target would create a temporary advantage over companies that buy and retire Decarbonization Credits.
CBIOs are assets issued based on the efficient production of biofuels. Fossil fuel distributors receive individual targets and must acquire credits in the market, retiring them to confirm compliance.
Therefore, the timing of the obligation impacts cash flow and commercial strategy. Buying credits as the deadline approaches can leave companies vulnerable to the market’s supply and pricing at that moment. Year-long planning helps distribute risk.
The draft will also detail the schedule for publishing targets and compliance verification. For a new company, knowing when the ANP calculates the volume is as important as understanding the formula since systems and treasury depend on this timeline.
The change arises from Law No. 15.082/2024 and Decree No. 12.437/2025, which established treatment for the initial years of new distributors. The agency is now transforming legal direction into executable procedures.
New Competitor Redistributes Obligations
When a new agent gains market share, it takes responsibility for part of the fuel sold. The proposal includes proportional adjustments in the targets of distributors already in the market, reflecting this change in volume distribution.
Without correction, existing agents could continue carrying a burden calculated before the new competitor entered. The updated design seeks to maintain the obligation tied to effective marketing behavior.
The revision also brings RenovaBio closer to the authorization process. If the distributor fails to meet the target for more than one fiscal year, the non-compliance can explicitly appear among the reasons for losing the operating license.
This is the toughest point of the package. A financial sanction impacts the results; revocation halts the business. Therefore, meeting the target becomes part of operational continuity, not just a separate environmental obligation.
The rule needs to distinguish between occasional delays, disputes, and repeated non-compliance. The administrative process must preserve the right to defense and clarity of data used in calculations, as the consequences can remove a company from the supply chain.
At the same time, indefinite tolerance shifts costs onto compliant parties. Regular distributors purchase CBIOs, organize documentation, and tie up resources. Competing with agents who ignore the targets undermines the economic incentive of the program.
We see a change in maturity here. RenovaBio stops treating new entrants as exceptions without a track and creates a path from the start of sales to full verification in the second year.
January 2027 Becomes the Sector Reference
The validity on the first day of the year facilitates alignment with the target cycle. It also allows ANP to adapt procedures and for distributors to incorporate the purchase and retirement of CBIOs into the 2027 budget.
Until then, public consultations and hearings may adjust the draft. Industry entities participated in prior studies and meetings, but the open stage allows testing details with agents of different sizes and models.
For producers of ethanol, biodiesel, and other biofuels, a predictable target system sustains demand for credits linked to efficiency. For distributors, it represents a regulatory cost that needs to be managed without disruption in supply.
Consumers do not purchase CBIOs directly, but they may feel the impact of decisions in the supply chain. The influence on final prices depends on competition, margin, credit cost, and the ability to pass through costs. There is no automatic relationship between a target and a fuel price adjustment.
Additionally, merely establishing a calendar is not enough. The quality of data on sales, transparency of targets, and functioning of the credit market will be crucial for the rule to be verifiable and for companies to plan without surprises.
The proposal offers a roadmap: partial obligation in the first year, semi-annual verification in the second, adjustments for existing agents, and sanctions for repeated non-compliance. The sector will now discuss whether the timelines fit into real operations.
If the final text maintains proportionality and oversight, the entry of new competitors could occur without creating a gap in climate policy. This is the balance that the 45-day consultation will need to demonstrate.
There is also a governance consequence. The board, commercial directorate, and environmental area will need to share the same calendar, as the volume sold creates future obligations. The goal will no longer be a matter restricted to the regulatory sector but will start to affect budgeting, risk, and growth strategy.
The transition until January allows time to test systems and contracts. Distributors planning to enter the market in 2027 will need to consider the obligation from the first projection, without the benefit of an initial grace period for targets.
Do you think the new rule balances competition and decarbonization or puts too much pressure on emerging distributors?
