Brazil is moving from carbon market framework to carbon market plumbing. A public consultation on the draft resolution governing Internationally Transferred Mitigation Outcomes (ITMOs) under Article 6.2 closed on 6 August, setting a 50 million tonne cap on authorized credit exports through 2035. In the same week, a private sector study put a price on what is at stake: Brazilian agriculture could generate 314.3 million carbon credits between 2025 and 2035, worth up to R$3.5 billion if even a small share is authorized for international sale. For buyers hunting future Article 6 supply and for developers sitting on Brazilian projects, the rules of the export game are finally being written.
What the Draft ITMO Rules Actually Say
The consultation, opened on 7 July by the federal government, implements Article 51 of Federal Law No. 15,042/2024, the statute that created the Brazilian Emissions Trading System (SBCE). According to an analysis by law firm Tauil and Chequer in association with Mayer Brown, the draft resolution ties Brazil’s Article 6.2 participation to a domestic goal: reducing net greenhouse gas emissions by 100 million tonnes of CO2 equivalent between 2031 and 2035 through cooperative approaches. Within that total, up to 50 million tonnes of CO2e may be authorized for international transfer as ITMOs.
The mechanics matter for anyone modelling supply. Mitigation outcomes destined for export must first be registered as Verified Emission Reduction or Removal Certificates (CRVEs) in the SBCE Central Registry, which means complying with methodologies accredited under the SBCE. The National Designated Authority will issue authorization letters that trigger corresponding adjustments, and a positive list of eligible activities will be proposed by the NDA together with the SBCE managing body.
Allocation runs through two channels. Future Transfer Agreements will be negotiated between the NDA and buyer-country representatives or authorized entities. Public Calls will select eligible projects and programs, with the Interministerial Committee on Climate Change setting maximum volumes for each channel through biennial resolutions. That biennial cap review is where export scarcity will be created or avoided.
The Private Sector’s Price Tag: R$3.5 Billion
The demand side of the argument arrived on 6 August at the Agri and Food Systems Forum during São Paulo Climate Week. A study by consultancy Carbonn Nature, the Instituto Equilibrio and the agribusiness institute IEAg, linked to the Brazilian agribusiness association Abag, estimates the farm sector could produce 314.3 million credits from Article 6 compliant projects between 2025 and 2035, mostly from degraded land restoration.
The study’s core scenario is deliberately conservative. Authorizing about 4% of that potential, roughly 15.7 million tonnes of CO2e, for sale as ITMOs through bilateral government negotiations would generate up to R$2.4 billion. If the credits instead serve CORSIA, the aviation offsetting scheme under which airlines must buy credits from 2027, the revenue potential rises to R$3.5 billion.
Natascha Trennepohl, partner at Carbonn Nature and head of the study, told AgFeed the binding constraint is not supply capacity or international demand but the absence of clear authorization rules. Because an ITMO cannot count toward Brazil’s own NDC, which targets net emissions of 850 million to 1.05 billion tonnes of CO2e by 2035, the study argues a gradual approach keeps the impact on national targets manageable while still delivering billions in rural income. Singapore and Switzerland are named as likely government buyers.
The China Angle and the Methodology Clock
Two further signals point in the same direction. Carbon Pulse reports that Brazil aims to approve the first carbon credit methodologies under the SBCE by the end of 2026, and that Brasilia is interested in pursuing an Article 6.2 memorandum of understanding with China covering ITMOs. Brazil already signed MoUs with several countries during COP30 to advance Article 6 cooperation, and a China track would add the largest emerging market buyer to that list.
The methodology timeline is the critical path item. Since exported credits must first exist as CRVEs under accredited SBCE methodologies, no methodologies means no CRVEs, and no CRVEs means no ITMOs regardless of how the export rules settle. An end-2026 approval target puts the first transferable Brazilian supply in 2027 at the earliest, neatly coinciding with the start of CORSIA’s mandatory phase.
What This Means for Buyers, Developers and Investors
For buyers, Brazil is shaping up as a rationed seller, not an open tap. A 50 million tonne cap through 2035, allocated through government-to-government agreements and competitive public calls, means early mover access will likely run through national negotiation channels rather than spot contracting. Airlines facing CORSIA obligations from 2027 should note that the study explicitly positions Brazilian farm credits as CORSIA supply.
For developers, the positive list of eligible activities is now the document that matters most. Degraded land restoration, the category the study identifies as the largest credit source, is a strong candidate for inclusion, but nothing is bankable until the list and the accredited methodologies are published. Projects should be structured so that credits can be registered as CRVEs once the SBCE Central Registry opens that path.
For investors, the sequencing risk is clear: rules first, methodologies by end-2026, first exports no earlier than 2027. The biennial volume resolutions from the CIM will function as a supply dial, and the first Future Transfer Agreements will set price benchmarks that secondary expectations will anchor to.
What to Watch
Three dates and documents will decide how fast this market opens. First, the final ITMO resolution following the 6 August consultation close, which will confirm or adjust the 50 million tonne cap. Second, the first SBCE methodology approvals, targeted for end-2026. Third, any Article 6.2 MoU signature with China or other buyers, which would convert the study’s revenue scenarios into named counterparties.
Brazil has spent two years building the legal architecture of its carbon market. The draft ITMO rules and the farm sector study are the first concrete numbers attached to the export side of that architecture, and they suggest the government intends to sell scarcity rather than volume.
