Perhaps it is not a very attractive and suggestive title, but I have the feeling that this is a little-known topic for companies…and mandatory for many starting on January 1st. The CBAM Regulation (according to its English acronym) or Carbon Border Adjustment Mechanism in Spanish, taxes the carbon emissions of imported products so that they can compete on equal terms with other products in the EU.
This is significant for some Spanish importers, imposing the obligation to notify the emissions of their products starting in January 2026, and to purchase, if applicable, CBAM Certificates (which certify the carbon price). There has been a three-year transition period, aimed at gradually eliminating free allowances under the European system. This promotes decarbonization in third countries and helps avoid «carbon leakage.»
According to the Ministry for Ecological Transition and the Demographic Challenge, this initiative, measure, or regulation of the CBAM, responds to a set of legislative measures known as «Objective 55.» With the implementation of the CBAM, the EU aims for it to be an instrument that allows the achievement and compliance with the climate neutrality goal, in line with the Paris Agreement. They have set the maximum deadline for 2050.
In my opinion, it penalizes companies in certain sectors that purchase products or relocate their production to third countries that are more lenient in terms of greenhouse gas emissions. Those obliged include importers of products related to the steel, aluminum, iron, cement, fertilizers, hydrogen, electricity, glass, ceramics, and cardboard sectors. This obligation starts with really low amounts, calculated at €150 per shipment. Another obligation is that they must register as «Authorized Declarants» to operate.
As mentioned earlier, a Transition Phase has been developed, from October 2023 until the end of 2025, with the «duties» of quarterly reporting, through the CBAM Registry to send these reports. And the Final Phase, starting this January 1, 2026, involves the obligations of being an Authorized Declarant, reporting the quantities of imported goods, determining and calculating emissions, and submitting an Annual Declaration, including the amount paid at origin.
Another important measure is the so-called Progressive Application. This phase involves the annual delivery of CBAM certificates, coordinated with the elimination of free allowances under the EU Emission Trading System, a process expected to conclude around 2034. The Purchase of Certificates must be conducted through the platform of the European Commission and presented in the corresponding Registry.
In summary, the process for companies is:
- Authorization: Request authorization as an «authorized CBAM declarant.» This must be a natural or legal person authorized by the Competent National Authority.
- Emission Reporting: Calculate and report quarterly the implicit emissions of the imported products.
- Planning: Determine and organize the traceability of the data and the certificate purchasing strategy.
- Purchase and Delivery: Buy CBAM certificates on the Platform and deliver them annually in the Registry. Adjustment: It is allowed to deduct the carbon price already paid in the country of origin.
And I conclude with a wish. Happy Holidays, and may 2026 (summing to 10) be a perfect year!
Miguel Ángel Otin Lloro
Secretary General, Huesca Excellent Business Forum
