O descompasso temporal do Programa de Desenvolvimento do Hidrogênio de Baixa Emissão de Carbono e o e-metanol marítimo: o que o Decreto nº 13.096/2026 datou, estreitou e alocou

E-methanol projects for marine bunkering reach final investment decision before the Brazilian tax credit becomes available. The question is what the implementing decree did with that interval. Doctrinal-normative analysis of primary sources, with validity checked on 16 September 2026. Decree 13,096/2026 dated the credits between 2030 and 2034, restricted the tax suspension to acquisitions made until 31 December 2026 — apparently narrower than the statutory term — and prioritised industrial self-consumption, in tension with the statute’s export objectives. Viability cannot rest on the incentive within the investment-decision horizon; a contractual crossing structure is proposed.