Identification and Assessment of Regulatory Challenges in VLFS Projects with Ammonia Production

Abstract

This study addresses the regulatory challenges associated with the use of Very Large Floating Structures (VLFS) to produce blue ammonia in the offshore context. VLFS are emerging as innovative technological solutions for the creation of sustainable production hubs, especially in remote regions and in the Brazilian pre-salt, promoting the integrated exploration of maritime resources and the reduction of carbon emissions. The analysis identifies legal gaps and necessary adaptations in national and international regulations. Currently, Brazilian legislation considers VLFS as vessels, with regulations limited to safety and naval registration, ignoring their technological and operational particularities. At the international level, the United Nations Convention on the Law of the Sea (UNCLOS) and standards such as MARPOL and SOLAS offer complementary regulatory bases, but they are insufficient for the specificities of VLFS. A case study highlights the production of blue ammonia, which uses natural gas with CO₂ capture and storage, as a strategic opportunity for Brazil. The research proposes good regulatory practices, including the creation of specific legal frameworks, adoption of international safety standards, rigorous environmental licensing criteria, and economic incentives for low-carbon technologies. It is concluded that the implementation of VLFS in Brazil depends on legislative advances, multi-sector integration, and institutional strengthening, allowing the alignment of technological innovation with the Sustainable Development Goals (SDGs). These frameworks represent an essential component in the sustainable energy transition and the efficient exploitation of maritime resources.