What exactly changed with ANP Resolution no. 984/2025
A 984/2025 maintains the backbone of RenovaBio (certification via RenovaCalc and issuance of CBIOs backed by the Energy-Environmental Efficiency Note), but updates critical points of the process. Among the main improvements announced by the ANP, stand out:
- faster updating of RenovaCalc fields and data;
- details of the rules for composing the audit team of inspection firms;
- provision of penalties for inspection firms and producers;
- change of document delivery deadlines;
- clearer qualification and criteria for eligibility of foreign producers;
- possibility of transferring certificate ownership;
- explicit procedure for changing route; e
- inclusion of procedures related to the grain chain of custody. In practical terms, This means more predictable audits, more agile calculation and strengthened traceability.
To avoid any doubt about the legal status: the ANP itself indicates, on your RenovaBio legislation page, ANP Resolution no. 984/2025 as the current standard for certification, replacing the framework of 758/2018. Other related acts are also included there. (CNPE and ANP resolutions and decrees) that are linked to the program.
National and individual targets for 2025
In terms of goals, the CNPE set for 2025 the total volume of 40,39 millions of CBIOs, broken down by the ANP into definitive individual targets per distributor, according to the methodology of ANP Resolution no. 791/2019 and expected rebate rules (long term contracts, adjustments for previous non-compliance, etc.). The official ANP page details the calculation, clarifies the treatment of retired CBIOs and makes orders available with targets by CNPJ. In terms of compliance, 2025 inaugurates the “RenovaBio 2025–2035” regulatory cycle with a level that requires rigorous commercial and financial planning from distributors for the timely retirement of CBIOs by 31 from December.
Practical impacts on certification (producers and importers)
1) RenovaCalc more dynamic. The commitment to “faster” updates unlocks the incorporation of fields, factors or methodological adjustments with less friction. Outcome: recertification cycles tend to be more fluid, with less risk of mismatch between operation and tool. For plants and plants with complex routes, This reduces deadline uncertainty and avoids bottlenecks during harvest periods.
2) Audit and accountability rules. Detailing the minimum composition of audit teams and predicting penalties raises the governance standard. Inspecting firms will need to show strict adherence to technical competencies and independence; Producers must maintain solid audit trails (primary data, field evidence, mass and energy integrations, allocation technical notes, etc.). The regulatory message is clear: quality of verification matters — and will have consequences.
3) Route change and transfers. By explaining procedures for changing routes and transferring ownership of certificates, the ANP creates regular channels for strategic adjustments (ex.: technological switch, co-product optimization, corporate restructuring). This provides legal and operational security for decisions that were, before, more sensitive to case-by-case screening.
4) Eligibility of foreign producers. Clearer criteria and specific qualifications reduce asymmetries and favor competitive equality in imported chains (as biomethane, HVO, PURE, corn ethanol, among others, if applicable), as long as traceability and emissions measurement requirements compatible with RenovaCalc are met.
5) Grain chain of custody. The inclusion of chain of custody procedures strengthens the link between the GHG inventory and the origin/integration of biomass, mitigating risks of double counting and improving the credibility of CBIOs generated. For grain-integrated plants (or buy by-products), requires finer document mapping and integration between procurement, logistics and compliance.
Effects for distributors (goals, CBIO risk and strategy)
With the total goal of 40,39 millions of CBIOs for 2025 consolidated by CNPE and individualized by ANP, active management of CBIO becomes a central discipline: demand projection, emission seasonality reading (ethanol/biodiesel/biomethane crops), long-term contracts with certified producers, and monitoring of stock prices. The standard makes it clear that rebates for long-term contracts are recognized, but require proof and formal adherence; delays in retirement can generate carry-over and adjustments, with reputational and financial consequences.
RenovaBio 2025–2035: trends for the decade
Over the decade, the regulatory debate already calls for progressively more ambitious carbon intensity targets and the refinement of market governance (verification windows, Data Transparency, price monitoring, integration with H2V and SAF policies). In this context, a 984/2025 works as a “clean base” on which the ANP can iterate faster (via RenovaCalc and infralegal acts), maintaining coherence with the deliberations of the CNPE and the provisions of Law no. 13.576/2017. For regulated agents, This means that operational efficiency and data quality will no longer be differentiators but will become prerequisites.
lean checklist for 2025 (from a certification point of view)
- Auditable primary data: mass and energy balances, process notes, inventory of energy and chemical inputs, field evidence (agro), measurement and calibration routines.
- Traceability: contracts, invoices, CTRs, load maps and any chain of custody controls (especially for grains).
- Methodological compliance: parameters and factors used in RenovaCalc in its current version, with justifications and sources.
- Audit governance: internal committees, technical managers, approval tracks, and readiness to meet the composition of inspection teams and new deadline requirements.
Expected earnings
The sum of celerity (RenovaCalc more agile), predictability (route/transfer procedures) e accountability (rules and penalties) tends to reduce transaction costs, shorten lead times (re)certification and increase confidence in the support of CBIOs. For the investor, This mitigates compliance risks; for the regulator, delivers better price signal and greater environmental integrity.
In summary, the regulatory package of ANP Resolution no. 984/2025 inaugurates a new phase — the “RenovaBio 2025–2035” phase — in which the quality of data and the discipline of managing CBIOs will be as decisive as the environmental energy efficiency of the route. Who gets organized now?, wins the decade.
More about RenovaBio? Here in our blog and here, in the documentation official!