Brazilian SAF Routes: Why Only Three Now Clear Europe
On 12 August 2026 President Lula signed Decree 13,094. Brazil now has rules for the aviation fuel part of its Fuel of the Future law, two years after the law itself passed. Most of the coverage read this as Brazil opening for business. It is not that simple. Do all Brazilian SAF production routes clear for European legislation?
The decree seems to build a home market for Brazilian SAF rather than an export channel. And the fuel Brazil can make most easily is the fuel Europe will not count as green. So the useful question is not what Brazil decided. It is which Brazilian SAF routes pass the European test. Only three do, and the reason has little to do with anything Brazil decided.
What Brazil built
The decree sets a target for airlines and creates a certificate to prove they met it.
The target sits in Article 10 of Law 14,993. Brazilian airlines must cut the emissions of their domestic flights by 1% from 1 January 2027. The cut rises to 2% in 2029, then by a point a year, until it reaches 10% in 2037.
Brazil calls that certificate the CS-SAF. Every batch of Brazilian SAF has to carry one. It records the crop, the process, the plant and the carbon figure, so a buyer can trace what they hold. Airlines hand these in to ANAC each January to show they met the target. ANP and ANAC write the detailed rules, and they have until 18 December 2026 to publish them.
Where Brazilian SAF routes meet the European rulebook
A holder can sell the CS-SAF on its own. Article 28 lets the paper move without the fuel. Article 30 then makes the seller warn the buyer of the bare fuel, in writing, that what they bought is ordinary fossil jet fuel with no green claim attached.
Under ReFuelEU Aviation the duty sits on fuel suppliers, and it is measured on the aviation fuel they supply at Union airports. Paper alone is worth nothing, because the rule counts physical supply rather than claims. The fuel must also pass the tests in Article 29 of the Renewable Energy Directive, certified under a voluntary scheme the Commission has recognised.
Brazil built its system on CORSIA and on its own RenovaBio tool instead. The two do not talk to each other. So Brazilian SAF routes aimed at Europe need a second and separate set of proof, and the CS-SAF is worth nothing in Rotterdam.
The rule that shuts out Brazil’s easiest route
Europe does not accept fuel made from food and feed crops. The Renewable Energy Directive defines those as starch, sugar or oil crops grown on farmland as a main crop. Sugarcane is a sugar crop. Jet fuel made from sugarcane ethanol therefore does not count as SAF in Europe at all. That closes off the largest available source of Brazilian SAF before the paperwork even starts.
So Brazil’s best card is the one Europe will not accept. The country has abundant low-cost ethanol and a working route from alcohol to jet fuel. Inside Brazil that fuel meets the new target, since ANAC works to the Brazilian rulebook. Shipped to Amsterdam it is just kerosene.
Brazilian airlines spent the week after the decree complaining that they get no tax relief. Their bigger problem is quieter. The route that would have made compliance cheap is the route Europe has already closed.
Which Brazilian SAF routes qualify
Three Brazilian SAF routes still qualify in Europe, though each carries a catch.
Used cooking oil and animal fats work. This is the HEFA route, and it makes most of the world’s SAF today. But the catch is supply. The Commission confirms that ReFuelEU sets no cap on this route, so the limit is physical rather than legal. There is only so much waste oil, demand already outruns it, and fraud in the trade keeps auditors busy.
E-fuels work as well. These come from green hydrogen and captured carbon, and Europe wants them enough to set a separate target: 1.2% of jet fuel from 2030 and 2% from 2032. Here the catch is cost, since these plants only work where power is cheap. These plants need cheap renewable power at scale, so the electricity price decides the business case.
The third of the Brazilian SAF routes runs on cellulosic material, which covers straw, husks, wood residues and grasses. Europe puts these in Part A of Annex IX, its top tier, with no ceiling on how much can count. The catch is that almost nobody has built one at scale.
Where the grass route sits
Grass holds little starch and no sugar or oil, so the exclusion that stops sugarcane leaves it alone. The Renewable Energy Directive goes further and names grassy energy crops with low starch in its own definition of cellulosic material, listing ryegrass, switchgrass, miscanthus and giant cane. Purpose-grown grass therefore sits in Part A, so Brazilian SAF routes built on it face no ceiling in Europe at all.
Europe applies a second test, this one to the land. It bars fuel crops from forest, peat and species-rich grassland. Brazil has worn-out cattle pasture instead. Embrapa counts 28 million hectares of planted pasture degraded badly enough to be worth replanting. Grass grown there raises no land question, because the ground is already cleared and already farmed.
The front end of the process is old. Farms have digested biomass into gas for decades, and turning that gas into methanol is ordinary industrial chemistry. Turning methanol into jet fuel is the newest step in the chain.
None of that makes the route easy. The methanol-to-jet step is not yet written into the ASTM fuel standard. It has cleared the first stage of testing and is proposed as an addition to the existing alcohol-to-jet annex, which is the quick path, but nobody has signed it off. So the route clears the eligibility problem that stops ethanol. It does not clear the carbon question or the fuel standard.
How to check Brazilian SAF routes before you buy
The decree helps builders in a way its drafters did not advertise. Article 3 offers incentives inside export processing zones, which exist to serve foreign markets, and priority status for infrastructure bonds under Law 12,431, which is open to any qualifying project.
If you are buying from Brazilian SAF routes, four questions do most of the work. Ask which Commission-recognised scheme certifies the producer, because a Brazilian certificate will not serve. Ask what the crop is, and whether it counts as a sugar, starch or oil crop, since that answer alone settles eligibility. Check where the barrel physically lands. Then ask what the fuel earns at home, because from January 2027 Brazilian airlines are bidding for the same litres.
For a developer the map of Brazilian SAF routes is now drawn. Brazil’s cheap ethanol serves Brazil, and only Brazil. Reaching Europe means waste oil, e-fuels or a crop nobody eats. Each of those carries its own constraint, and none of the three is easy. But Brussels has already settled the eligibility question for Brazilian SAF, not Brasilia.
If you work in aviation, shipping, project finance, or the energy transition and want to understand what investment-grade green fuel project development looks like in practice, contact us.
