This paper provides a comprehensive analysis of the Brazilian freight railway system, examining the efficacy of the current concession renewal model in light of persistent structural problems such as market concentration, cargo dependence on export commodities and underutilization of the network. Situating Brazil within the broader international debate on railway reforms, the paper evaluates whether the ongoing early renewal of concessions can deliver a more diversified and competitive freight system.

The study adopts a sequential mixed-methods research design that integrates longitudinal quantitative analysis with qualitative institutional and policy evaluation. The quantitative component examines time-series indicators published by ANTT, DNIT and INFRA S.A. from 1999 to 2023 to identify structural patterns in traffic growth, investment, safety and market concentration. The qualitative component employs a process-tracing logic to reconstruct the evolution of concession renewals and the implementation of Railway Law 14.273/2021, drawing on concepts from regulatory economics, institutional theory and industrial organization. These empirical streams are synthesized through an analytical framework that connects three dimensions - regulatory design, market structure and system performance - allowing for a systematic assessment of how Brazil’s institutional configuration shapes incentives, competitive dynamics and network utilization.

The analysis confirms that the early renewal of concessions has successfully secured substantial private investment for capacity expansion on existing trunk lines. However, it has perpetuated the vertically integrated model, reinforcing the market power of incumbent operators and failing to significantly promote intramodal competition or cargo diversification. The system remains dominated by iron ore and agricultural commodities, with general cargo representing a minuscule share. The new authorization regime and short-line railway policies present a viable pathway for market opening but face significant operational and institutional barriers to implementation.

This research offers a timely and critical assessment of a pivotal moment in Brazilian railway policy. It moves beyond a simplistic evaluation of volume growth to a structural analysis of market failures and the interplay between concession renewal and regulatory innovation. The findings provide actionable insights for policymakers in Brazil and other emerging economies seeking to balance private investment with public interest goals in railway infrastructure, highlighting the necessity of complementary, pro-competitive measures alongside financial investment.