CBAM for Spanish Industry 2026: Complete Guide for Steel, Cement and Fertiliser Exporters
Published 19 Revisado / June 2026 · IgeraSolutions Editorial Team · 13 min read
The Carbon Border Adjustment Mechanism (CBAM) is not just an obligation for EU importers. Spanish industrial producers that export to other EU member states are increasingly being asked by their European buyers to provide embedded carbon documentation. Without this data, buyers face default-value CBAM costs that may make Spanish suppliers uncompetitive. This guide explains exactly what Spanish steel, cement, aluminium and fertiliser producers need to do — even if they are not the direct CBAM declarant.
Key point for Spanish producers
As a Spanish producer selling to EU buyers, you are not the CBAM declarant (your buyer is). But your buyer will pay significantly less CBAM costs if you provide accurate actual embedded carbon data rather than forcing them to use default values. Producers that help buyers with carbon data win contracts; those that don't may be replaced by competitors who do.
Wait — Spain is in the EU. How does CBAM affect Spanish producers?
CBAM applies to imports into the EU from non-EU countries. Spain is an EU member state, so Spanish producers selling within the EU are not directly subject to CBAM. However, three indirect scenarios affect Spanish industry:
- Spanish subsidiaries of non-EU groups may be classified as non-EU producers for specific product flows if the legal entity is outside the EU
- Spanish producers supplying non-EU exporters (e.g., a Spanish steel producer selling semi-finished goods to a Moroccan fabricator who then exports to the EU) face indirect CBAM pressure through the supply chain
- Most importantly: Spanish producers whose EU buyers face CBAM competition — If a German buyer is choosing between Spanish steel and Turkish steel, CBAM costs on the Turkish steel raise its effective price. But if the Spanish producer cannot demonstrate its own carbon footprint (to help buyers argue their supply chain is lower-carbon), the competitive advantage is lost
Embedded carbon data: what Spanish producers need to calculate and document
| Sector | Key emissions sources | Scope 1 | Scope 2 | Typical t CO2/t |
|---|---|---|---|---|
| Steel (EAF) | Electrode oxidation, scrap charging | 0.06–0.15 | 0.35–0.55 | 0.45–0.70 |
| Steel (BF-BOF) | Coke combustion, iron reduction | 1.60–2.10 | 0.05–0.15 | 1.65–2.25 |
| Cement (clinker) | Calcination (50%), fuel combustion (40%) | 0.75–0.85 | 0.02–0.05 | 0.77–0.90 |
| Aluminium | Electrolysis (Scope 2 dominant) | 0.35–0.60 | 3.50–8.00 | 4.00–8.50 |
| Fertilisers (urea) | Ammonia synthesis (steam reforming) | 1.40–1.80 | 0.05–0.15 | 1.45–1.95 |
The default values trap: why accurate data matters
The default values penalty
CBAM default values (set per product category per country of origin) are deliberately conservative — they represent the 75th percentile of carbon intensity for each sector. For many efficient Spanish producers, actual embedded carbon is 20–40% below the default. Using defaults means your buyer pays significantly more CBAM certificates than necessary, making your products less competitive than they should be.
Example for Spanish EAF steel (electric arc furnace, powered by Spain's increasingly renewable grid):
- CBAM default for steel (Spain): approximately 1.2 t CO2/t steel
- Actual embedded carbon for a modern Spanish EAF plant: 0.52 t CO2/t steel
- Difference per tonne at €65/t ETS: €44/t in excess CBAM costs for your buyer
- For a buyer purchasing 5,000 t/year: €220,000 in avoidable CBAM costs
5 documents Spanish producers should prepare for EU buyers
Carbon footprint calculation report (CBAM methodology)
A calculation of embedded carbon per tonne of product, using the methodology in Implementing Regulation (EU) 2023/1773. This must separately identify Scope 1 direct emissions and Scope 2 indirect emissions (electricity). The calculation should be verified by an accredited third party if possible.
Production facility declaration
Declaration identifying the production facility (name, address, coordinates, installation ID if covered by EU ETS) where the goods were produced. CBAM declarations link embedded carbon to specific facilities.
EU ETS certificate records (if covered)
If your facility is covered by the EU ETS (most Spanish steel, cement and aluminium plants are), provide documentation of ETS allowances surrendered. Although Spain/EU producers are not CBAM declarants, this data helps buyers when comparing EU vs. non-EU suppliers.
Electricity grid carbon intensity certificate
Spain's grid carbon intensity in 2025 averaged 95 g CO2/kWh — well below the EU average of 233 g CO2/kWh. Provide REE (Red Eléctrica de España) data or your power purchase agreement (PPA) documentation showing actual grid mix if your facility uses residual mix tracking or guarantees of origin.
Quality management and traceability records
Provide production batch records linking each delivery to specific production runs for which carbon data is available. This traceability allows buyers to submit product-specific embedded carbon data in their CBAM declarations rather than facility averages.
Case study: Valencian ceramic manufacturer saves €180,000
A Valencian manufacturer of porcelain tiles (classified under CBAM as cement-related goods, CN 6908) was losing contracts to Italian competitors after several German buyers reported that CBAM default values made Spanish tiles more expensive on paper than tiles from EU plants with documented carbon footprints.
Working with IgeraRegTech, the company implemented continuous kiln emission monitoring and solar PPA documentation for its production facility. The resulting embedded carbon report showed 0.38 t CO2/t tile — 43% below the CBAM default value of 0.67 t CO2/t.
The company distributed its carbon report to its 12 major EU buyers. Three buyers that had been considering switching to Portuguese suppliers reversed their decision. The estimated annual value of retained contracts: approximately €2.1M. The cost of the IgeraRegTech implementation and carbon verification: €42,000. ROI: 50x in the first year.
Do Spanish EAF steelmakers have an advantage under CBAM?
Potentially significant. Spain's EAF steel sector uses approximately 80–90% scrap, with most plants powered by Spain's increasingly renewable grid. This typically results in embedded carbon of 0.4–0.6 t CO2/t — compared to 1.8–2.2 t CO2/t for blast furnace producers in countries without carbon pricing. If Spanish EAF producers document their actual carbon, they can position themselves as the low-carbon steel source of choice for EU manufacturers subject to supply chain decarbonisation pressure.
What is the cost of carbon footprint verification for a Spanish producer?
For a single-site producer with one product category, third-party verification of the CBAM carbon footprint calculation typically costs €8,000–25,000 per year depending on facility complexity and verifier. This is a fraction of the contract value at risk if buyers switch to competitors with verified carbon data. The cost decreases significantly in subsequent years once monitoring systems and procedures are established.
How does IgeraRegTech help with regulatory compliance?
IgeraRegTech indexes complex regulations like DORA, NIS2, or the AI Act and answers compliance questions in seconds, citing the exact article and paragraph of the legal text.
Does the system hallucinate or invent regulatory articles?
No. Thanks to the RAG architecture, IgeraRegTech only answers based on the official texts of the directives and regulations loaded into the knowledge base.
Is it secure to upload sensitive corporate documentation to the system?
Absolutely. Documents are stored securely on encrypted servers in the EU and processed under strict security controls that guarantee confidentiality.
What advantages does it offer over conventional search tools?
It allows semantic and complex searches in natural language, finding cross-references between different regulations without needing to know the exact legal terms.
For more information and a reference guide about this vertical, visit our Igera pillar page.
Help your EU buyers reduce their CBAM costs
IgeraRegTech helps Spanish industrial producers calculate, document and distribute their embedded carbon data in CBAM-compatible format. Turn your low-carbon grid advantage into a competitive differentiator.
Explore IgeraRegTechReviewed by: IgeraSolutions Compliance Team