Mining
Brazilian Sustainable Taxonomy: Between Green and Greenwashing
On the eve of COP 30 and the UNPRI meeting (an international event on sustainable investments held in Brazil in November 2025), the Brazilian federal government published the Brazilian Sustainable Taxonomy (TSB), a regulatory framework intended to put the country on the path to green finance. With this, Brazil aligns itself with a global trend of creating financial taxonomies.
Sustainable finance taxonomies aim to classify economic activities according to their degree of sustainability, guiding financial flows towards those considered compatible with environmental, social, and climate objectives. Although the concept is promising, the effectiveness of taxonomies depends on the methodological robustness employed in defining the criteria and verifying their implementation and compliance.
TSB criteria for CNAE A
The Brazilian taxonomy covers 8 sectors, including the CNAE A sector — Agriculture, Livestock, Forestry Production, Fishing and Aquaculture, as well as mining (CNAE B), construction, and others.
The technical guidelines for CNAE A, in turn, provide eligibility criteria for 8 categories of eligible activities: annual crops (soybeans and corn), coffee, cocoa, pasture-based systems (beef and dairy cattle farming), planted forests (eucalyptus), natural regeneration of native forests, pirarucu fishing, and aquaculture.
The logic of the TSB is to identify and encourage sustainable practices for the sectors most important to the Brazilian economy. This is a different logic from the European Union’s taxonomy, for example, which seeks to define the minimum criteria for an activity to be considered sustainable.
This difference is important because it should be noted that the TSB covers precisely some of the sectors known as the largest drivers of deforestation: cattle production, soybean and corn production, and eucalyptus production. Therefore, the simple inclusion of a sector in the TSB does not imply that the sector is considered sustainable.
For a project to be considered aligned with the taxonomy, it must meet the three general criteria and the exclusion criteria:
1. Minimum Safeguards
First, the individual or legal entity involved must comply with the minimum safeguards (MS). The MS are based on legislation and include requirements such as not being on the “dirty list” of slave labor, having all required environmental licenses, and the absence of environmental fines. The MS have practical and binary verification indicators – compliance or non-compliance.
Even so, simple compliance does not prove the absence of negative impacts. For example, the MS require the producer to present an active Rural Environmental Registry (CAR). But the vast majority of CARs are self-declared and have not yet been validated, and therefore the simple presentation of the CAR does not guarantee environmental regularity. The MS also prohibit overlap with Indigenous Lands, but only those declared, approved, and registered, thus allowing activities in Indigenous Lands that are still in the early stages of demarcation.
Looking at the Extractive Industries sector (CNAE B), the concept of safeguards is even more fragile. While the government celebrates the inclusion of minerals such as iron, potassium, and gold as “strategic” for the transition, the Mining Observatory, a member of our Coalition, warns that the TSB fails by ignoring Scope 3 emissions, which represent the vast majority of the mineral sector’s climate impact. Furthermore, the definition of “irreplaceable areas” that would be off-limits to mining remains vague, leaving dangerous loopholes for the expansion of the mineral frontier into sensitive ecosystems under the pretext of “strategic interest” or “public interest.”
This legal weakness is not unique to Brazil, but has been identified in other countries with tropical forests. In dialogue with the organization TuK Indonesia, also a member of the coalition, we observed an alarming pattern: both there and in Brazil, the taxonomy is used to “greenwash” mining in traditional territories through discursive maneuvers. In Indonesia, coal was rebranded under the justification of “energy generation” to soften its rejection; in Brazil, the TSB (Technical Standards for Sustainable Development) conditions the sustainability of mining in Indigenous Territories on Congressional approval. In practice, the regulatory mechanism is created even before territorial protection is implemented, serving more as a safe-conduct for investments than as an effective brake on socio-environmental degradation.
2. Do No Significant Harm
Secondly, measures to do no significant harm (NPS in Portuguese) to the 4 climate and environmental objectives, must be implemented (at least 3 measures per objective). This includes implementing agro-ecological practices and restoring degraded areas. However, there is no minimum requirement, no methodology, and no indication of deadlines for verifying implementation. This gives the financial institution complete discretion to decide whether the requirement has been met.
Furthermore, the NPS include practices of questionable sustainability, such as the use of biomass and biodigesters. Burning biomass can emit more greenhouse gases than fossil fuels, and the use of biodigesters can reduce soil carbon. Extensive analysis have shown that, on average, biodigesters do not significantly contribute to reducing GHG emissions, and they create dependence on activities with high environmental impact (livestock farming).
3. Eligible Items by Sector
Thirdly, at least 3 practices listed in the Appendices must be implemented for the 8 supply chains. This includes positive measures such as the use of bio-inputs and green manure. However, as with the NPS, there are no minimum or maximum requirements, no methodologies, the indicators are imprecise, and there is no mention of implementation deadlines, making monitoring implementation virtually impossible.
Furthermore, practices that are often unsustainable, such as production intensification, have also been included. Studies show that intensification suffers from Jevons’ paradox, and that in the case of soy and cattle, it increases pressure on the Amazon.
Practices also include the use of pesticides (without restriction in terms of quantity), their application by drones, the cultivation of genetic varieties resistant or tolerant to insect pests and diseases (without excluding the use of GMOs), the use of bioenergy and biodigesters, and the confinement of livestock, which, in addition to impacting animal welfare, goes against scientific reports indicating the urgency of reducing livestock production if we are to meet climate and biodiversity goals.
Another critical point is waste management and circularity. The Mining Observatory recommends that minerals with high recycling potential, such as iron and aluminum, be evaluated by much stricter criteria in order to avoid the opening of unnecessary new mines. Indonesia’s experience with nickel serves as a warning: the promise of local industrialization and value aggregation without rigorous safeguards resulted in massive deforestation and severe impacts on public health. Brazil risks repeating this mistake if the TSB continues to allow the lowering of groundwater levels and the maintenance of tailings dams without independent monitoring and the active participation of affected communities.
4. Exclusion Criteria
Finally, the property must comply with the exclusion criteria regarding pesticides and deforestation. But despite a ban on the use of certain pesticides, many others are permitted, including glyphosate and pesticides that have already been banned in the European Union, such as mancozeb, acephate, and atrazine.
Regarding deforestation, the TSB does not allow financing the deforestation of areas larger than 5 hectares, but makes an exception for the clearing of areas that have already been used for agricultural production less than 5 years ago (provided it complies with the Forest Code). This means that interrupting the regeneration process can be classified as sustainable.
Furthermore, the taxonomy allows for the financing of properties with deforestation up to the end of October 2025 (provided it complies with the Forest Code), and from 2030 onwards, properties with deforestation of more than 5 years. This means that anyone who deforests today will become eligible for sustainable financing in five years.
Conclusion
At the end of 2024, IPBES, the leading UN scientific platform on biodiversity, published its Report on the underlying causes of biodiversity loss and the determinants of transformative change, as well as options for achieving the 2050 Vision for Transformative Change in Biodiversity. The document warns that “profound and fundamental changes in how people view and interact with the natural world are urgently needed to halt and reverse biodiversity loss”. According to the authors, there is a “window of opportunity that is closing” and the risk of exceeding “irreversible biophysical tipping points, including (…) the irreversible decline of the Amazon Rainforest.”
In 2025, the EAT Lancet report found that food systems are the single largest cause of planetary boundary transgressions and encourages urgent changes towards more sustainable, healthy, and equitable diets.
By prioritizing the status quo, intensification, and productive efficiency, the Brazilian Sustainable Taxonomy missed the opportunity to fully leverage its potential to direct resources towards ecologically and socially just transition practices.
A comparação com a Indonésia revela que o Brasil não está sozinho nessa tentativa de institucionalizar o greenwashing financeiro. Ambos os países possuem grandes florestas tropicais e governos que, sob o manto da ‘sustentabilidade’, avançam com a mineração sobre territórios ancestrais. Para que a TSB não seja apenas um verniz para a exportação de commodities brutas, é urgente que o Consentimento Livre, Prévio e Informado (CLPI) seja obrigatório e vinculante para qualquer projeto, incluindo aqueles em áreas em processo de identificação. Sem isso, a taxonomia brasileira será apenas mais uma ferramenta de mercado para validar a contaminação de rios e corpos, como o trágico e persistente exemplo do povo Xikrin e da impunidade da Vale.
The comparison with Indonesia reveals that Brazil is not alone in this attempt to institutionalize financial greenwashing. Both countries possess large tropical forests and governments that, under the guise of ‘sustainability’, are advancing mining on ancestral territories. For the Brazilian Taxonomy not to be merely a veneer for the export of raw commodities, it is urgent that Free, Prior and Informed Consent (FPIC) be mandatory and binding for any project, including those in areas undergoing identification. Without it, the Brazilian taxonomy will be just another market tool to validate the contamination of rivers and bodies of water, as exemplified by the tragic and persistent case of the Xikrin people and the impunity of Vale.