Brazil has just moved from the regulatory promise phase to the execution phase. With the publication of Decree No. 13,096/2026 in August, the federal government gave operational form to the Brazilian Hydrogen Certification System, SBCH², foreseen since 2024 in the Low Carbon Hydrogen Legal Framework Law. For producers targeting the export market, the question is no longer "when will this leave the drawing board" but "how will this work in practice".
The answer begins with governance. SBCH² is not run by a single body, but is distributed among four institutions with well-defined roles:
- Coges-PNH2, the Management Committee of the National Hydrogen Program, acts as the competent authority of the system.
- ANP assumes the role of regulatory authority, responsible for defining guidelines, requirements, and methodologies for carbon intensity certification.
- Inmetro functions as an accrediting authority, certifying companies that will audit producers in the field.
- CCEE operates as a registry manager, maintaining the public database where certificates are issued and consulted.
This segregation of functions is not a bureaucratic detail. It exists to give international credibility to the Brazilian certification, preventing the same actor from regulating, accrediting, and registering at the same time—a design that follows practices already established in systems like RenovaBio.
The logic behind the number
At the heart of the certification process is life cycle analysis. Emission intensity is measured in kilograms of CO2 equivalent per kilogram of hydrogen produced (kgCO2eq/kgH2), and the law already sets the ceiling: up to 7 kgCO2eq/kgH2 for the product to be classified as low-emission hydrogen. Reduction targets are gradual, starting in 2027 and reaching a 10% cut by 2037.
The CNI (National Confederation of Industry) argues that the methodology should adopt the well-to-gate boundary—from energy generation to the factory exit, without accounting for transportation and end use—as it is the most internationally used approach. The organization also recommends that Brazil align the SBCH² (Brazilian Hydrogen Supply Chain System) with the ISO/TS 19870:2023 standard, currently a global benchmark for calculating emissions in the hydrogen supply chain.
One certificate, two layers.
One point that directly interests exporters: the proposal under discussion includes a national certificate with basic information, and an optional module with more detailed data specifically geared towards export operations. In practice, this means that producers don't need to carry all the complex documentation required for the European market to sell in Brazil, but can activate this extra layer when the destination is a demanding buyer.
"Demanding" is the right word to describe the main buyer market. The European Union, under the rules of RED III and the RFNBO regime, enforces three strict criteria: additionality (use of new renewable sources, not from the existing energy mix), temporal correlation between energy generation and hydrogen production, and complete traceability of the supply chain. A significant point of contention is that European regulation restricts certification to fuels of non-biological origin, which in practice excludes the biofuel route that Brazil advocates in international forums.
Here's a little-known but strategic piece of information: CCEE already operates the SCH2 EU RFNBO Scheme, its own scheme for certifying Brazilian renewable hydrogen according to European rules. It's a technical bridge that existed even before the full consolidation of SBCH², and one that export-oriented producers should be mapping out now.
What changes for those who produce and export?
In operational practice, the regulation already authorizes the ANP (National Agency of Petroleum, Natural Gas and Biofuels) to grant authorization for the production, processing, treatment, import, export, storage, and commercialization of low-emission hydrogen. Facilities that are already in operation and do not fall under the exemption categories have two years to regularize their situation with the agency.
Three key areas should guide the planning of exporters:
- Traceability from the design stage. Monitoring and chain-of-custody systems need to be considered during the engineering phase, not after the plant is already in operation.
- Choosing a technological route with the target market in mind. Producers targeting Europe need to consider the restrictions of RED III right from the project design stage, especially regarding the source of energy.
- Leveraging existing port infrastructure. Hubs like Pecém in Ceará, Suape in Pernambuco, and Açu in Rio de Janeiro already concentrate investments and logistical expertise for large-scale exports.
The potential is significant: Brazil has an estimated technical capacity of 1.8 gigatons of low-emission hydrogen per year, and more than US$290 billion in private projects already announced in 18 states. The European Union, in turn, plans to import 10 million tons by 2030—a demand that the country is positioned to meet, provided that certification acts as a bridge of trust, and not as an additional barrier.
Certification remains voluntary. However, as the CNI itself points out, it has already established itself as a competitive advantage, especially for those who negotiate with buyers who demand proof of origin and environmental performance. Clear, proportionate rules that are compatible with the national productive reality are, according to the entity, the condition for transforming potential into real advantage.
