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In brief

The Brazilian Institute of Environment and Natural Resources (IBAMA) opened a public consultation regarding a new normative that regulates the control of corporate emissions and the management of pollutant emission credits for the Vehicle Emission Control Program’s L8 phase (“Proconve L8“).

The public consultation is being done in accordance with CONAMA Resolution No. 492/2018, which established the Proconve L7 and L8 phases, and aims to obtain input from stakeholders who will be involved in Proconve L8.

Further details

The public consultation presents the draft of the new normative, considering the need for advances in the control of vehicle emissions. 

Proconve program, instituted by CONAMA Resolution No. 18/1986, has, among others, the following objectives:

  • To reduce the levels of pollutant emissions by automotive vehicles.
  • To promote the national technological development for measurements of pollutant emissions.
  • To create inspection and maintenance programs for motor vehicles.
  • To promote knowledge about air pollution by motor vehicles.
  • To promote improvement in the technical characteristics of available fuels to reduce pollutants emitted.
  • To establish conditions for the evaluation of the results obtained.

Proconve has already passed through a few phases, aiming to reduce the limits of pollutant emissions by light and heavy-duty vehicles in the long term. Currently, CONAMA Resolution No. 490/2018 establishes the Proconve L7 phase (currently in force), which aims to reduce fuel vapor in the atmosphere, and Proconve L8 (in public consultation), which aims to reduce emission of nitrogen oxides.

Proconve L8 phase, which will come into effect as of 1 January 2025, will bring new maximum limits for pollutant emissions in a corporate manner for light commercial and light passenger road vehicles sold in Brazil. In addition, it establishes the generation of pollutant emission credits with the aim to meet the defined emission levels.

Considering that IBAMA is responsible for publishing the procedure regulating the generation, balance and use of pollutant emission credits, it published the normative’s draft regulating the control of corporate emissions and management of emission credits. The purpose of the current public consultation is to collect contributions for the improvement of the proposal, which establishes (i) the obligation to submit to IBAMA a report with data on compliance with corporate emission limits; and (ii) the possibility of generating, compensating and exchanging credits between corporations that manufacture and/or import light passenger vehicles, vehicles with special characteristics for off-road use and light commercial vehicles.

Those interested in offering suggestions for the proposed normative must submit the contribution form by 21 November 2022.

Our Environment, Climate Change and Sustainability team is available to provide further clarifications on the subject.

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Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.


Renata Campetti Amaral joined the firm in 2002 and became a partner in 2013. She is the head of the firm’s Climate Change, Environmental Law and Sustainability group in Brazil, and the leader of Ablfs McKfnzif’s global climate change group in Latin America.  Is also the coordinator of the sustainability initiatives conducted by the office’s B-Green Committee.

Renata assists the major players in the Brazilian market in Nature-bases Solution (NbS) projects, transaction of carbon credits, implementation of decarbonization strategies and carbon-related advocacy and regulatory matters. Renata leads several of the largest environmental and regularization cases in the country. She has extensive experience in sustainability matters, as well as in managing crises and negotiating with stakeholders.

Advises on negotiating with authorities; judicial and administrative litigation; reviewing environmental aspects of institutions and financial operations; drafting environmental provisions in contracts and other commercial operations. Renata has extensive experience in dealing with environmental management, legal auditing and other organizational practices; regulatory and institutional analysis and environmental control; negotiation and implementation of environmental remediation plans; environmental licensing; legal aspects of biodiversity protection; environmental crisis management; development of preventive policies and strategies for companies; negotiation and drafting of contracts for the purchase and sale of carbon credits and acting in transactions related to various aspects of the energy transition.

*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.


Giovani Bruno Tomasoni joined the Firm in 2008 and became partner of the Environment, Consumer and Sustainability practice group in 2020. He practices with focus on Environment, Public Law, Energy, Forestry, and helps clients in the internalization of concepts such as sustainability, ESG, circular economy, environmental compliance, among others. Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.


Manuela Demarche joined the Firm in 2017, and has been working with Environmental Law since 2010. She is currently a Senior Associate of the firm’s Environment, Sustainability and Climate Change practice group.

She has several years of experience in complex matters connected to environmental, sustainability and climate change, and her practice focus on a wide range of matters, particularly in connection to environmental liability, licensing proceedings, carbon and M&A transactions and cross-border disputes. During 2022, she did an attorney training program in the U.S. and has worked as a Legal Extern for the American Clean Power Association.

She regularly advises international and domestic clients in relevant cases, including preparing opinions, overseeing due diligences, drafting administrative and judicial claims for disputes arising from controversial environmental matters. Under her umbrella, she regularly deals with regularization (air pollution, effluents, solid waste, contaminated areas), circular economy, take-back schemes, extended producer responsibility, carbon markets, REDD+, biodiversity and crisis management.

Awards and Recognitions

Manuela Demarche is recognized for her work as an outstanding professional – “Associate-to-watch” – in Environmental Law in Brazil, by the publication Chambers and Partners. She was also mentioned by Análise Advocacia Mulher.

*Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.


Rafael Gil is an Associate in Trench, Rossi e Watanabe Advogados, Sao Paulo office. Trench Rossi Watanabe and Baker McKenzie have executed a strategic cooperation agreement for consulting on foreign law.

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