Scoping diagnosis
We review which goods you import and whether they fall under Annex I of the Regulation (iron and steel, aluminium, cement, fertilisers, hydrogen or electricity), and assess whether the 50-tonne annual de minimis exemption applies.
Sostenibilidad
CBAM · Carbon Border Adjustment Mechanism
Since 1 January 2026, CBAM requires importers to declare the embedded emissions in imports of iron and steel, aluminium, cement, fertilisers, hydrogen and electricity. We help you calculate those emissions and prepare the authorised declarant application.
**What CBAM is and who it affects.** The Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956) entered its definitive phase on 1 January 2026, after the transitional reporting-only period (October 2023 to December 2025). From that date, importing iron and steel, aluminium, cement, fertilisers, hydrogen or electricity from outside the EU is no longer just a customs formality: it requires declaring the greenhouse gas emissions embedded in those goods and surrendering equivalent CBAM certificates. Imports of up to 50 tonnes per year per importer are exempt, a threshold introduced by the 2025 simplification package.
**The authorised CBAM declarant.** Before importing covered goods, the importer must apply for authorised declarant status with the National Competent Authority — in Spain, the Ministry for the Ecological Transition and the Demographic Challenge, through the CBAM Registry. The application requires an EORI number, no record of serious customs or tax infringements, and demonstrable financial and operational capacity. We support the importing SME through this process so the first application arrives complete.
**Emissions calculation and CBAM certificates.** Here CBAM builds on the same work we already do for carbon footprinting: quantifying emissions with methodological rigour. In the definitive phase, CBAM certificates are calculated on the actual emissions embedded in the imported goods, verified by an accredited verifier. We extend our ISO 14064 carbon footprint service to also cover the calculation of embedded emissions in imported products, with the documentary traceability the annual declaration later requires.
**The first annual declaration.** The first CBAM declaration of the definitive period is submitted in 2027, covering imports made during 2026, with its deadline set at 30 September 2027 following the simplification package. It must include the quantity of goods imported, total embedded emissions in tonnes of CO2e, the CBAM certificates to be surrendered and the reports of an accredited verifier. We help the company prepare that documentation in advance, to reduce the risk of customs incidents or an incomplete declaration.
The CBAM process.
The process · four stagesAuthorised declarant application
We support you through the application for authorised declarant status with MITECO's CBAM Registry, gathering the EORI number and the documentation proving financial and operational capacity.
Embedded emissions calculation
We extend our ISO 14064 carbon footprint service to quantify the actual emissions embedded in imported goods, with the traceability the declaration later requires.
Annual declaration preparation
We organise the documentation —quantities imported, emissions in tonnes of CO2e, certificates to be surrendered and accredited verifier reports— ahead of the 30 September deadline.
What is included
What CBAM includes.
The operational detail: what we deliver as part of the work and what we keep alive afterwards.
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Scoping diagnosis
Identification of the goods, sectors and volumes that fall within the scope of CBAM.
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Embedded emissions calculation
Quantification of the greenhouse gas emissions of imported goods, using the ISO 14064 methodology.
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Authorised declarant support
Support through the application with MITECO's CBAM Registry, including the EORI and operational-capacity file.
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Annual declaration documentation
Preparation of the information on quantities, emissions and certificates to be surrendered.
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Regulatory monitoring
Notice of changes to deadlines and thresholds, such as those introduced by the 2025 simplification package.
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Briefing session for your team
A one-off briefing on CBAM obligations for the procurement and finance teams involved.
Summum cluster
How it connects with its sisters.
Frequently asked questions about CBAM.
What exactly is CBAM?
It is the EU's Carbon Border Adjustment Mechanism (Regulation (EU) 2023/956): it passes on to imports a cost equivalent to what European producers pay for their emissions under the Emissions Trading System.
Which sectors are covered?
Iron and steel, aluminium, cement, fertilisers, hydrogen and electricity, as set out in Annex I of the Regulation. The list may be extended in future reviews of the mechanism.
What is an authorised CBAM declarant?
It is the status every importer of covered goods must apply for before importing, with the National Competent Authority (in Spain, MITECO, through the CBAM Registry). Without that status, CBAM goods cannot be imported in the definitive phase.
How are embedded emissions calculated?
In the definitive phase they are calculated on the actual emissions of the imported production, verified by an accredited verifier. That calculation is what gives rise to the CBAM certificates that must be surrendered.
When must 2026 emissions be declared?
The first annual declaration of the definitive period is submitted in 2027, covering 2026 imports. After the 2025 simplification package, the deadline moved from 31 May to 30 September; it is advisable to confirm the current date on the MITECO website before each campaign.
How does CBAM relate to the ISO 14064 carbon footprint?
Calculating embedded emissions uses the same measurement discipline as carbon footprinting. That is why we approach it as an extension of that service: anyone already measuring their footprint has the groundwork ready for CBAM.