New Legal Framework: Updates and deadlines
On December 11, 2024 , Law No. 15,042/2024 (PL 182/2024) was enacted , establishing the Brazilian Emissions Trading System (SBCE) . The 5-phase schedule, expected to come into effect by the end of 2028 , is as follows.
The regulation (Decree + National Action Plan) with specific sectors and metrics should be released by the end of 2026 .
What is a Carbon Inventory?
A carbon inventory, also known as a greenhouse gas (GHG) emissions inventory, is a process of assessing and quantifying GHG emissions associated with an activity, economic sector, organization, or geographic region.
This inventory is essential for measuring and monitoring emissions of gases such as carbon dioxide (CO₂), methane (CH₄), and nitrous oxide (N₂O), allowing measures to be taken to reduce them.
Transportation: who is included?
Currently, there is still no specific SBCE legislation for transportation, but there are already complementary environmental regulations:
a) Hazardous products
- IBAMA Instruction 5/2012 requires authorization for interstate transportation of hazardous products (land, river, sea) by road, via AATIPP , since 2012 , with updates via digital system.
- In 2021, Ordinance 2294/21 made registration in the CTF-APP mandatory for liquid fuel distributors (LPG, diesel, etc.).
b) Carriers
- The RNTRC (formerly CIOT/PED) requires registration of road freight carriers – mandated by ANTT (CNAE H-4930-2-02 and H-4930-2-01).
- The ANTT website lists companies authorized for interstate and international road transport of passengers.
The focus now expands to inventory + CBEs , which will require integration of these records with the new system.
(reference: [ibama.gov.br] , [dadosabert…ama.gov.br] [consultapu…ntt.gov.br] )
Compliance deadlines for transportation
- By 2026 : completion of regulations and definition of sectors (phase 1–2).
- 2026 to 2028 : Start of mandatory submission of MRV reports and emissions inventories.
- Starting in 2028 : allocation and auctions of CBEs ( Brazilian Central Bank’s Credit Certificates) will begin ; companies must buy/transfer quotas to operate.
Penalties
- Fines — ≥ cost of obligations up to 3% of gross revenue .
- Suspension of environmental or transport licenses in case of non-compliance.
- Possible ineligibility and restrictions in public bidding processes with federal agencies or ANTT (National Agency for Land Transport).
Compliance steps for companies
- Map emissions (CNAEs, routes, types of transport — road freight, passenger, maritime, airport)
- Registering with CTF-APP : already mandatory for hazardous fuels.
- Integrate failures in the RNTRC / ANTT / IBAMA systems.
- Implementing MRV : collection, monitoring, platform, and auditing of GHG data.
- Generate annual inventory with validation from certifiers.
- Participate in SBCE auctions and acquire CBEs
- Audit annually and adjust operational reduction targets.
How can Sustain Quality help?
- Road diagnostics : emissions analysis by fleet and measurement point.
- MRV implementation and inventory aligned with the future PNA.
- Data integration with CTF-APP, AATIPP, RNTRC and ANTT systems.
- Simulations of CBE purchases and support in bidding processes.
- Technical training and certification of validation and verification bodies.
- Monitoring legislative deadlines , fines, and licensing risk.
Carbon Credits
Once the carbon inventory is complete and reliable, carbon credits can be considered. In short, a carbon credit is a mechanism that represents the reduction of one metric ton of carbon dioxide equivalent (CO₂e) or its removal from the atmosphere. The process of choosing a carbon credit involves:
- Project Identification : Projects that reduce emissions, such as renewable energy, energy efficiency, reforestation, and methane capture.
- Certification : Rigorous assessment to ensure the legitimacy and accuracy of emissions reductions.
- Trading : Credits are traded on regulated markets, where companies and governments can buy them to offset their own emissions.
Standards like Gold and Verra
There are several international standards that guarantee the quality and integrity of carbon credits:
- Gold Standard : This standard ensures that emissions reduction projects also contribute to sustainable development, promoting additional social and environmental benefits.
- Verra : Verra is an organization that develops and manages standards for emissions reduction projects, ensuring that carbon credits are real, measurable, and verifiable.
Learn more about the Standards here!
However, we recommend that carbon credits be considered an option only after the possibilities of reducing the carbon footprint operationally have been exhausted.
Conclusion
In short, a carbon inventory is a fundamental tool for companies and organizations that want to understand and reduce their GHG emissions. By following the steps and considering international standards, it is possible to develop an accurate and effective inventory, contributing to a more sustainable future.
Call to action
With the regulatory landscape materializing by 2026/2028 , transportation companies have a short timeframe to begin preparations. We recommend starting as soon as possible.
Sustain Quality offers technical expertise to help its clients anticipate challenges, avoid fines and suspended licenses, and stay ahead in the transition to a regulated carbon market.