Brazil proposes regulatory overhaul for routine B100 bunkering

Brazil's national energy agency has launched a public consultation on a draft resolution proposing to permit up to 100% biofuel (B100) for routine marine bunkering, law firm Mayer Brown said.

IMAGE: Aerial view of Port of Salvador, Brazil. Getty Images

Brazil's National Agency of Petroleum, Natural Gas and Biofuels (ANP) has published a draft revision to ANP Resolution No. 903/2022, which governs the specifications for marine diesel oil and marine fuel oil sold in the country.

One of the most significant changes is a proposal to permit up to 100% biofuel (B100) for routine use in vessels, rather than only under exceptional authorisations. B100 could also be sold directly to end users under the new regulation, according to information published by Mayer Brown.

The current regulation limits the biodiesel content of marine diesel oil to a maximum of 0.5% by volume.

Biofuel blending procedures would be simplified by defining which market participants are authorized to carry out biofuel blending. This will remove the need for prior ANP approval for individual blends and replace it with a simple notice to the regulator, Mayer Brown said.

Hydrotreated vegetable oil (HVO) and synthetic marine diesel oil are proposed to be classified as "drop-in" fuels, meaning they can replace conventional marine fuels without requiring modifications to existing engines or bunkering infrastructure.

The proposal also strengthens requirements for fuel quality control, certification, sampling, traceability and documentation.

A dedicated commercial authorisation framework would be introduced to use LNG for bunkering, given the existence of established technical standards and emerging LNG bunkering infrastructure in Brazil.

Ethanol, methanol, ammonia and hydrogen would remain subject to ANP approval for experimental use before they can be bunkered.

According to Mayer Brown, the proposed changes aim to align Brazil's marine fuel regulations with the IMO's decarbonisation ambitions and standardise the regulatory treatment of these fuels according to international standards like the ISO and MARPOL.

The ANP has opened a 45-day public consultation from 28 July to 10 September. This will allow interested parties, including shipping companies, bunker suppliers, industry groups, technical experts and non-profit organisations, to submit comments on the draft.

It will then hold a public hearing on 23 September, a formal regulatory meeting where participants can present their views directly to the ANP before the resolution is considered for adoption.

By Konica Bhatt

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