On August 12, 2026, the Brazilian government published two decrees in the same Official Gazette. Decree 13.094 regulates ProBioQAV, the national program for sustainable aviation fuel. Decree 13.096 regulates the legal framework for low-carbon hydrogen. At first glance, the two texts seem to address separate agendas. However, when read together, it becomes clear that they describe the same production chain.
This coincidence of dates is not a regulatory coincidence. On the contrary, it reflects a trend that is already appearing in practice in refineries outside of Brazil: green hydrogen is ceasing to be a product purchased separately and is becoming an embedded input within other products that the market already demands, such as SAF (Sodium Antiphosphorus).
What did OMV Petrom do at the Petrobrazi refinery?
The Romanian refinery Petrobrazi has increased its electrolysis capacity to 55 MW to guarantee its own hydrogen supply for its new SAF unit. At the end of August, the oil company OMV Petrom announced the delivery of the complex's second electrolyzer, bringing the estimated annual production to approximately 8,000 tons of green hydrogen, all destined for domestic consumption.
The final destination is noteworthy: the hydrogen will fuel refining processes, as well as the new SAF and HVO unit under construction in the same complex, with a projected capacity of 250,000 tons per year. In total, the investment in the hydrogen program amounts to €750 million, partly financed by the European Union's recovery and resilience plan.
The relevant point here, therefore, is not the electrolyzer itself, but the strategic decision behind it. That is, the refinery did not build electrolysis capacity to sell hydrogen on the open market. Instead, it built it to secure input for a product with a more attractive margin, since SAF faces mandatory blending targets in virtually all relevant aviation markets.
How Switzerland is testing another path for synthetic SAF.
Water, renewable electricity, and CO₂ can also be turned into aviation kerosene, and a plant in Switzerland is already demonstrating this process in practice. On August 20th, the Paul Scherrer Institute and the startup Metafuels inaugurated the "aerobrew" demonstration plant, which combines these three inputs to produce green methanol and then converts that methanol into synthetic kerosene.
The scale is still small, only 50 liters per day, but it is sufficient to validate the process under industrial conditions before commercialization. Even so, the conceptual design reinforces the same pattern observed in Romania: hydrogen produced by electrolysis enters as an intermediate step in a route that ends in aviation fuel, and not as a final product.
Why the demand for hydrogen doesn't always appear as a demand for hydrogen.
Much of the future demand for green hydrogen will not come from someone buying pure H₂. Instead, it originates within other production chains, which completely changes how the market is assessed. Key examples include:
- SAF and e-SAF, via HEFA and Alcohol-to-Jet routes, which use hydrogen to deoxygenate oils and break hydrocarbon chains.
- e-methanol, produced from green hydrogen and biogenic CO₂, used both as a marine fuel and as a feedstock for synthetic SAF.
- Green ammonia, a fertilizer input that consumes approximately 180 kg of hydrogen per ton produced.
- Synthetic fuels in general, obtained via Fischer-Tropsch routes from captured hydrogen and carbon.
For a company that produces or intends to produce low-emission hydrogen, this distinction changes the way they think about the business. After all, the end customer may never buy hydrogen directly; instead, they buy SAF, they buy fertilizer, they buy marine fuel, and hydrogen simply travels embedded in the price and composition of these products.
How much hydrogen will Brazil's SAF require by 2034?
The Energy Research Company estimates that the demand for hydrogen via the HEFA route for SAF and green diesel could exceed 320,000 tons per year by 2034. Furthermore, the Suape Hub for Energy Transition, in Pernambuco, foresees up to 3 GW of electrolysis capacity focused on the production of e-methanol and SAF, using biogenic CO₂ from the sugarcane and ethanol sector as a carbon source. The complex already brings together e-methanol projects from companies such as European Energy and GoVerde, each with investments in the range of R$ 2 billion, and Petrobras is currently evaluating becoming a partner in one of them.
In this context, Decree 13.096 provides a clearer regulatory path for this type of project, with Rehidro offering tax incentives such as the suspension of PIS/Cofins taxes on equipment imports. Simultaneously, Decree 13.094 creates the market for sustainability certificates for SAF (Sustainable Agricultural Systems), with the book-and-claim model as the official commercialization mechanism, an innovation that places Brazil in the position of the first country to adopt this model as public policy.
What changes for those considering investing in electrolysis?
Refineries, ports and industrial centers that are currently considering investing in electrolysis do not necessarily need to bet on the future existence of a buyer of pure hydrogen. On the contrary, they can structure the investment around a product with already regulated demand, such as SAF, and thus use hydrogen as an internal component of the chain.
This logic, therefore, reduces one of the main commercial risks of green hydrogen: the uncertainty about who will buy it. When H₂ is embedded in a product with a mandatory blending mandate, such as SAF in Brazil from 2027 onwards, demand ceases to depend on a hydrogen market that is still being formed and begins to depend on an aviation fuel market that already exists.
References
- OMV Petrom (comunicado, 28/08/2026) — expansão de eletrólise em Petrobrazi
- Paul Scherrer Institute / Metafuels (comunicado, 20/08/2026) — planta “aerobrew”
- Governo Federal do Brasil — Decreto nº 13.094/2026 e Decreto nº 13.096/2026 (DOU, 13/08/2026)
- Empresa de Pesquisa Energética (EPE) — Nota técnica sobre hidrogênio e biomassa
- Portal da Indústria / CNI — Hidrogênio Sustentável, projeto Hub Suape for Energy Transition
