You are right about ICAO FAQ, etc...
The problem is ICAO itself, as you know its an Organisation, not an Authority, and as such it can only issue recomendations subjected to local authorities, who ratify them or not or create exemptions. And it is to the local authorities to certify and regulate all issues, in this case you come down to a ANAC level in Brazil! To get a clue how bad it can be, the top positions in this Civil Aviation Agency are not filled by people who are competent or knowledgeable about the issue, but some darlings of the ruling party.
Given the quality of the government elected we cannot expect anything good coming from it
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