Carbon adjustment in full force

The European Union today activates the sanctions regime of the Carbon Border Adjustment Mechanism (CBAM), marking the definitive end of the transitional period that began in 2023.

September 12, 2026  |  3 min read

Operational phase and sanctions

As of this date, importers of steel, aluminum, cement, fertilizers, electricity, and hydrogen must purchase CBAM certificates to cover the embedded CO2 emissions in their products. The price of these certificates is directly linked to the weekly auctions of the EU Emissions Trading System (ETS), eliminating the competitive advantage of non-EU producers with lax environmental standards.

This operational phase introduces severe fines for companies that fail to comply with the declaration of verified emissions or that submit incomplete data. The European Commission has deployed a coordinated customs control infrastructure to prevent evasion of the mechanism through goods triangulation via third countries. China and India, the main parties affected by this measure, have raised their protests before the World Trade Organization (WTO), labeling the levy a “green barrier” and threatening to impose retaliatory tariffs on high-value-added European industrial goods.

Reconfiguration of costs and supply chains

The transition of the CBAM from a reporting system to an effective payment system alters the cost structure for Spanish construction and infrastructure companies with a high dependence on imported steel and aluminum. The sudden rise in the price of these inputs puts pressure on the operating margins of ongoing projects and forces a revision of long-term supply contracts. However, this scenario favors national steelmakers that have invested in electric arc furnaces and the use of green hydrogen, as the cost differential with producers from Asia or Russia narrows significantly for the first time.

The full implementation of the tariff acts as a catalyst for industrial relocation or nearshoring. Spanish companies now face the need to audit the carbon footprints of their external suppliers under European standards to avoid unforeseen sanctions. This requirement for traceability generates a competitive advantage for suppliers located in the Mediterranean arc and North Africa that manage to integrate decarbonized processes early on. Those subsidiaries of Spanish companies operating in markets with weak climate regulations lose their cost advantage when trying to export to the common market.

Resilience and trade order

The risk of a trade war intensifies with the announcement from Delhi and Beijing regarding potential countermeasures. The Spanish export sector, especially chemicals and automotive components, remains exposed to cross-retaliation. The ability of companies to diversify their export markets and secure contracts with suppliers that have low-emission certification determines their resilience in this new trade order. CBAM is no longer a regulatory directive, but a critical financial variable that directly affects asset valuation and the strategic planning of industrial groups.