Spanish exporters' club calls for the ETS-CBAM binomial to be put on standby

The Club de Exportadores e Inversores Españoles called on September 2, 2026 for the EU to put the ETS-CBAM pair, which the club calls a "binomial," on standby, in a 12-page technical note that also demands the immediate exclusion of fertilizers from the EU ETS on food security grounds. The note, titled "Cuando la política climática se convierte en shock de costes: ETS, CBAM y competitividad industrial" ("When climate policy becomes a cost shock: ETS, CBAM and industrial competitiveness"), is written by the economist Antonio Merino and dated July 2026. The association put it in front of the Spanish press on September 2, when infobae and other outlets reported the demand.

The release lands twelve days before the European Parliament plenary of September 14 to 17, where Parliament is expected to adopt its negotiating position on the CBAM review. August already produced suspension and expansion demands from farm and steel lobbies, but this is the first demand tracked on CBAM Guide that targets both the EU ETS and CBAM at once. It comes from a private business association, not from the Spanish government.

What the technical note demands

The note's first recommendation is to put the ETS-CBAM binomial on standby, and its further recommendations call for much lower carbon prices and for fertilizers to leave the EU ETS immediately. The recommendation section closes its opening argument with the sentence, translated from Spanish: "Therefore, the first recommendation is to put the ETS-CBAM binomial on stand-by."

The note makes four demands, listed below.

• Pause the pair: put the ETS-CBAM binomial on standby to avoid inflation and loss of industry
• Cut the carbon price: make CO₂ prices "much more moderate," moving them closer to the levels competitors face (paraphrased from the Spanish text)
• Exclude fertilizers now: "Sectors such as fertilizers need to be excluded from the system (ETS) now: first, on food security grounds, and second, because the inflationary effects of fertilizers on agricultural goods are crystal clear" (translated from Spanish)
• Protect strategic sectors: use tariffs and active industrial policy to stop production relocating outside Europe

The economic framing behind all four is the same. Because upstream producers pay the carbon price directly while downstream industries absorb it through dearer steel, aluminium, chemicals, and electricity, the note argues the combined effect on European value chains "is equivalent to the introduction of an implicit internal tariff" (translated from Spanish). On fertilizers specifically, it adds that China has raised nitrogen fertilizer production by 50 percent using coal rather than natural gas, a figure the note presents without a cited source.

The cost numbers behind the standby demand

The note estimates that at a carbon price of €100/tCO₂ the embedded steel and aluminium in a single vehicle carry €600 to €800 in carbon costs, absorbing 30 to 70 percent of the unit profit of carmakers running 3 to 6 percent operating margins. The table below collects the note's headline figures, all of which are the note's own estimates and scenarios rather than official EU data.

The €100 scenario is not hypothetical for the note's author: the note recalls allowance prices shooting up to €100 per tonne in 2022, a level EUA prices in fact only touched in February 2023 after peaking just below it in 2022, and it points to the Fit for 55 package's reference to a €250 per tonne carbon price in 2030. Both figures sit well above the Q2 2026 CBAM certificate price of €75.28/tCO₂e. The note also claims 200,000 automotive jobs have already disappeared in Europe and that exports of CO₂-intensive goods have been falling since 2021, attributing both to the cost gap with competitors. Importers who want to test the note's arithmetic against their own tonnages can use the CBAM cost calculator.

The note's structural critique goes beyond prices. Because CBAM covers inputs such as steel, cement, aluminium, and fertilizers but not the finished goods made from them, it argues the mechanism invites circumvention through intermediate transformation in third countries, while extending it downstream would bring what it calls diminishing returns: harder emissions calculations, more administration, and a higher risk of trade retaliation.

A private association's demand, not Spain's position

The Club de Exportadores e Inversores Españoles is a private multisectoral business association representing Spanish companies with international operations, and its technical note does not state the position of the Spanish government. Antonio Merino signs the note as Técnico Comercial y Economista del Estado, a senior Spanish civil service corps title, but the document is a publication of the association, not of any ministry.

Spain's official role in CBAM runs through a different body entirely: the Oficina Española de Cambio Climático (OECC) acts as the national competent authority that authorizes declarants and enforces the mechanism, as covered in the CBAM Spain country guide. Nothing published by OECC or the Spanish government endorses the standby demand. Readers of the September 2 coverage need that distinction, because a member state calling for suspension in the Council would be a materially different event from an exporters' club recommending one in a technical note.

How the demand compares with the other pre-plenary pressure

The Spanish note is the broadest of three lobby demands published since mid-August, because it targets both climate instruments while earlier demands aimed at single sectors or at CBAM alone. The three positions point in different directions, as the table below shows.

The fertilizer demand overlaps with the Irish farmers' demand to suspend CBAM on nitrogen fertiliser, though the Spanish note goes further by asking to remove fertilizers from the ETS itself rather than pausing the border mechanism. The steel position runs in the opposite direction: the 500 signatories demanding downstream CBAM expansion want CBAM widened to finished goods precisely because of the input-cost asymmetry the Spanish note describes, where the note concludes the whole binomial needs pausing instead.

What changes for importers

Nothing in the note changes any legal obligation, because a technical note from a business association has no procedural effect on Regulation (EU) 2023/956 or on the ETS Directive. Three fixed points remain for compliance teams.

1. Certificate sales open on February 1, 2027
2. The first annual CBAM declaration is due September 30, 2027, covering calendar year 2026
3. The 2026 CBAM factor stays at 2.5 percent, with free allocation phasing out to zero by January 1, 2034

The note matters as a signal, not as law. Suspension arguments now come from farm lobbies, from an exporters' association, and, in softer form, from governments seeking sectoral carve-outs, and all of them converge on the September plenary and the trilogues that follow. The price channel the note attacks is explained in how the EU ETS determines CBAM certificate prices: as long as free allocation shrinks and the allowance price feeds both the ETS bill and the certificate price, every euro on the carbon price strengthens the constituency asking Brussels to pause the machine.