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December 4, 2023
Ricardo Lewin
Chief Financial Officer
Cosan S.A.
Av. Brigadeiro Faria Lima, 4,100 – 16th floor
São Paulo – SP, 04538-132, Brazil
Re:Cosan S.A.
Form 20-F for the Fiscal Year Ended December 31, 2022
Form 6-K Furnished on August 15, 2023
File No. 1-40155
Dear Ricardo Lewin:
            We have reviewed your filing and have the following comments.
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 20-F for the Fiscal Year Ended December 31, 2022
Note 4. Segment Information, page F-31
1.We note your presentation of Gross sales (Domestic market and External market) for your
various segments and on a consolidated basis on pages F-32 through F-34. Please tell us
how your presentation complies with IFRS. Also, please tell us the nature of the
adjustments you record to Gross sales to arrive at Net sales as presented on the face of
your financial statements. Refer to IFRS 8 and 15.
Note 5.1. Net Debt, page F-42
2.We note your disclosure that net debt is a non-GAAP financial measure and is not a
measure in accordance with the IFRS and should not be considered as a substitute for
measures of debt determined in accordance with the IFRS and the Brazilian accounting
standards. As such, please tell us your consideration of the guidance in Item
10(e)(1)(ii)(C) of Regulation S-K related to presenting non-GAAP financial measures on
the face of the financial statements prepared in accordance with GAAP or in the
accompanying notes. Also, refer to General Instruction C.(e) of Form 20-F.

 FirstName LastNameRicardo Lewin
 Comapany NameCosan S.A.
 December 4, 2023 Page 2
 FirstName LastNameRicardo Lewin
Cosan S.A.
December 4, 2023
Page 2
Note 8. Investments, page F-76
3.Please tell us your consideration of making the disclosures in paragraph 7(a) of IFRS 12
related to how you control the subsidiaries listed in the table on page F-77 where you have
less than a majority stake in the subsidiaries. We note your disclosure in the second
paragraph of page F-90 which appears to apply to the following subsidiaries:
•Tellus Brasil Participações S.A.,
•Janus Brasil Participações S.A.,
•Duguetiapar Empreendimentos e Participações S.A., and
•Gamiovapar Empreendimentos e Participações S.A.
Form 6-K Furnished on August 15, 2023
Earnings Release, page 2
4.We note your presentation of Cosan pro forma measures which considers the
consolidation of 50 percent of the results of operations of your equity method investment
in Raizen S.A. and 100 percent of other operations and pro forma investments accounted
for on a cash basis and excluding M&A. Please tell us your consideration of the guidance
in Questions 100.01 and 100.04 of the Non-GAAP Financial Measures Compliance and
Disclosure Interpretations since the recognition and measurement principles used to
calculate these measures are inconsistent with IFRS.
Reconciliation of Adjustments - EBITDA and Net Income, page 17
5.Please tell us your consideration of beginning your reconciliations of Adjusted EBITDA
with Net (loss) income per Cosan Consolidated which is the most directly comparable
IFRS measure. Refer to Item 100(a)(2) of Regulation G.
6.Please explain in detail to us each adjustment to arrive at Adjusted EBITDA and Adjusted
Net Income. Explain why the adjustments do not result in a non-IFRS measure that could
be considered misleading. Refer to Questions 100.01 and 100.04 of the Non-GAAP
Financial Measures Compliance and Disclosure Interpretations.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of
action by the staff.

 FirstName LastNameRicardo Lewin
 Comapany NameCosan S.A.
 December 4, 2023 Page 3
 FirstName LastName
Ricardo Lewin
Cosan S.A.
December 4, 2023
Page 3
            Please contact Tony Watson at 202-551-3318 or Adam Phippen at 202-551-3336 if you
have questions regarding comments on the financial statements and related matters.
Sincerely,
Division of Corporation Finance
Office of Trade & Services