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Natural gas in Brazil: transport, processing, LNG, imports and trading under the 2021 Gas Law

Argentina. For full detail on Argentina, go to The Argentine Thread.

Last verified: 2026-10-27 · Status: Changing

The 2021 Gas Law moved pipelines, storage, processing, LNG and trading to ANP authorizations granted to Brazilian incorporated companies at their own risk. Pipeline owners must be independent of producers and traders, capacity is sold on an entry exit basis, and third parties get regulated access to transport and negotiated access to upstream pipelines, processing plants and LNG terminals. Local distribution remains a state matter, and from 2026 gas producers and importers also carry a biomethane decarbonization target.

Key facts

Biomethane GHG reduction target for gas producers and importers, 20260.5 %Resolução CNPE nº 4/2026 art. 1, as of 2026-05-06 · in force
Maximum biomethane GHG reduction target under the law10 %Lei nº 14.993 art. 17 § 1, as of 2026-10-27 · in force
Period given to separate producer and trader influence over distributor management3 yearsLei nº 14.134 art. 30 § 1, as of 2026-10-27 · in force

The rule

1. Gas transport by pipeline, import and export, gathering, treatment, processing, underground storage, packaging, liquefaction, regasification and trading are regulated by the ANP and may be carried out by companies or consortia incorporated under Brazilian law with head office and management in Brazil. Activities under these authorizations run at the investor's own cost and risk and are never a public service.Lei nº 14.134 (Gas Law), Art. 1 caput and §§ 1 and 2, 2021-04-08 official text · verified 2026-10-27
2. Gas transport is carried out under authorization covering construction, expansion, operation and maintenance. An authorization involving a new or expanded pipeline is preceded by a public call. Spin offs, mergers, transformations, capital reductions and any transfer of control of the authorized transporter need prior ANP authorization, in addition to merger control by CADE.Lei nº 14.134, Art. 4 §§ 2 and 3, 2021-04-08 official text · verified 2026-10-27
3. Transporters must be independent: no direct or indirect control or affiliate relationship is allowed between a transporter and companies active in exploration, production, import, shipping or trading of gas, and those companies may not access competitively sensitive information of the transporter or appoint its board or officers.Lei nº 14.134, Art. 5 §§ 1 and 2, 2021-04-08 official text · verified 2026-10-27
4. Transport capacity is offered on an entry exit basis, with entry and exit contracted independently; transporters in the same capacity market area must set up a market area manager. The ANP regulates third party access to transport pipelines and must create compulsory release of contracted capacity whose continued need is not proven.Lei nº 14.134, Arts. 13 § 1, 14 and 18 § 2, 2021-04-08 official text · verified 2026-10-27
5. Third parties have non discriminatory, negotiated access to production gathering pipelines, treatment and processing plants and LNG terminals. The owner keeps a preference to use its own infrastructure; tariff and term are agreed on the basis of a published code of conduct; the ANP settles disputes unless the parties agree another method.Lei nº 14.134, Art. 28 caput and §§ 1 to 4, 2021-04-08 official text · verified 2026-10-27
6. Import and export of natural gas require ANP authorization, available to companies incorporated in Brazil with head office and management in the country, and follow CNPE guidelines. Underground storage is also authorized by the ANP at the investor's risk.Lei nº 14.134, Arts. 19 and 20, 2021-04-08 official text · verified 2026-10-27
7. Local piped gas distribution is a state service under the Constitution. Where the state distributor cannot meet their needs, free consumers, autoproducers and autoimporters may build their own pipelines and facilities for their specific use, under a contract assigning operation and maintenance to the state distributor, with operation and maintenance tariffs set by the state regulator.Constitution art. 25 § 2; Lei nº 14.134, Lei nº 14.134 art. 29 caput and § 1, 2021-04-08 official text · verified 2026-10-27
8. Gas sales are made under purchase and sale contracts registered with the ANP or an entity it accredits, except distributor sales to captive consumers. Distributors, free consumers, producers, autoproducers, importers, autoimporters and traders may trade gas under ANP authorization.
Cost to do it: No authorization fee is set in the law; registration follows ANP regulation.Lei nº 14.134, Art. 31 caput and §§ 2 and 3, 2021-04-08 official text · verified 2026-10-27
9. To fight concentration, the ANP may order supply deconcentration and compulsory release of transport, gathering and processing capacity, and a gas release program obliging dominant sellers to auction part of their volumes at a minimum price, quantity and term set by the ANP, after hearing the competition authority.Lei nº 14.134, Art. 33 § 1 I and II, and § 2, 2021-04-08 official text · verified 2026-10-27
10. A transport authorization may be revoked only on the listed grounds, such as insolvency, request, permanent deactivation, serious breach or failure to meet independence rules. Transport assets do not revert to the Union, and there is no indemnity for undepreciated assets.Lei nº 14.134, Art. 10 caput and § 3, 2021-04-08 official text · verified 2026-10-27
11. Gas producers and importers must meet an annual greenhouse gas reduction target through biomethane, proven by buying or using biomethane or retiring biomethane origin certificates. The law set an initial 1 percent from 1 January 2026, capped at 10 percent, and lets the CNPE lower it temporarily; CNPE Resolution 4 of 1 April 2026, published 6 May 2026, set the initial target at 0.5 percent from publication while a monitoring desk works to restore 1 percent.
Cost to do it: Cost of biomethane or certificates equal to the target share of each obligated company's gas sales.Lei nº 14.993 (Fuel of the Future Law); Resolução CNPE nº 4 of 1 April 2026, Lei nº 14.993 art. 17 §§ 1 to 3; Resolução CNPE nº 4 art. 1, 2026-04-01 official text · verified 2026-10-27 · changed: Resolução CNPE nº 4 of 1 April 2026 (DOU 6 May 2026) set the first biomethane target at 0.5 percent instead of the 1 percent in the law.

Worked example

  • A Brazilian subsidiary of a foreign trader wants to import LNG and sell to industrial free consumers: it needs ANP import authorization (art. 19), ANP trading authorization (art. 31 § 2), negotiated access to an LNG terminal (art. 28) and entry and exit capacity contracts with transporters (art. 13); every sale contract is registered with the ANP or an accredited entity (art. 31). From 2026 it also owes the biomethane target on gas it sells, 0.5 percent under CNPE Resolution 4/2026.

Step by step

  1. 1. Incorporate in Brazil with head office and management in the country.
  2. 2. Obtain the ANP authorizations for each activity: import, trading, processing, storage or transport.
  3. 3. For transport, check independence rules before structuring any shareholding with producers or traders.
  4. 4. Negotiate access under each facility's published code of conduct; escalate disputes to the ANP.
  5. 5. Contract entry and exit capacity and register sale contracts with the ANP or an accredited entity.
  6. 6. Check the state regulator rules for any sale to captive or free consumers inside a distribution concession.
  7. 7. Budget the yearly biomethane target set by the CNPE.
  8. 8. Pipeline gas bought from a neighbouring producer such as Argentina is an import like any other and needs the ANP import authorization; the Argentine export side is covered in The Argentine Thread guide.

Common traps

  • A transporter cannot share control with a producer, importer or trader; unwinding a non compliant structure means an independence certification process.
  • Acquiring control of an authorized transporter without prior ANP approval breaches art. 4 § 3, on top of CADE filing duties.
  • Pipeline assets built by a free consumer may later be incorporated into state assets by declaration of public utility with indemnity (art. 29).
  • The biomethane target can change each year by CNPE act; it fell to 0.5 percent for 2026 and the stated aim is to restore 1 percent.

Sources

Related pages

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