• From 2030, with the removal of the ETS2 €45/t cap, the annual additional cost per MWh of gas consumed could range between €26.6 and €42.75, according to our calculations based on the European Central Bank’s carbon price estimates.

  • ETS2 will apply, from 2027, an additional cost of €8.55 per MWh of natural gas, which will be added to the final price paid by consumers.

  • Foro Industria y Energía calls for industrial SMEs to be included in the Carbon Social Fund, for support to promote the adoption of zero-emission technologies, and for legal certainty through the immediate transposition of ETS2 into Spanish law.

October 31, 2025.

There is an elephant in the room. Its name is ETS2, and in less than two years, we will all start paying for it. Households, companies, industrial SMEs—no one is exempt. Yet, we continue to behave as if it isn’t there. Perhaps because it still seems manageable. Perhaps because 2027 feels far away. But there is a problem: this elephant keeps growing. What may today seem like an acceptable cost threatens to become, in a matter of years, a structural burden that could jeopardize the viability of industrial companies in Spain.

ETS2 is not just another measure. It is the mechanism the European Union has chosen to accelerate the decarbonization of natural gas in buildings and transport. And although its purpose is climatic, its impact is economic, immediate, and increasing. For small and medium-sized industry, ignoring it is no longer an option.

From 2030, industrial consumers could face an additional cost of between €26.6 and €42.75 per year per MWh of gas consumed due to the EU’s new Emissions Trading Scheme (ETS2). This mechanism, designed to tax CO₂ emissions from natural gas use in buildings and transport, introduces a permanent operational burden that forces SMEs, previously exempt, to urgently review their strategic planning.

ETS2 presents itself as a key tool for decarbonization, but the economic reality for SMEs represents a significant burden from the start. Foro Industria y Energía has calculated that, under the capped price of €45/tCO₂ expected until 2030, a company will bear an additional cost of €8.55 per MWh of gas consumed, calculated using a standard emission factor of 0.19 kg CO₂eq/kWh. For some small and medium-sized industrial companies—such as those in the chemical sector or those whose processes require high temperatures and steam—this consumption can easily reach GWh annually, which would translate into an additional cost of €8,550 per year in this base scenario. Although the system includes the Market Stability Reserve (MSR), which releases allowances if prices exceed €45, its function is only an “emergency brake” against spikes, without eliminating this base cost, which Foro Industria y Energía highlights as already significant, especially for small industry.

Projections for 2030

The economic challenge of ETS2 intensifies toward 2030, when the €45/t cap will be removed and a sustained increase in the carbon price is expected. To estimate its potential impact, Foro Industria y Energía has used the European Central Bank (ECB) projections for the evolution of carbon prices under three climate scenarios, applying the same emission factor (0.19 kg CO₂eq/kWh) to translate these figures into real costs for industrial consumers.

According to the ECB, the scenarios are as follows:

  • IEA Carbon Tax Scenario: proposes a carbon tax that gradually rises to €140/tCO₂ by 2030, without other complementary measures. In this context, the additional cost would be €26.6 per MWh of gas consumed, according to FIE calculations.

  • Fit for 55 – Policy Mix Scenario: combines the rise in carbon prices—up to €180/tCO₂ by 2030—with technological improvements and policies supporting energy efficiency. In this intermediate scenario, the additional cost would be around €34.2 per MWh.

  • Fit for 55 – Carbon Tax Only Scenario: reflects the most demanding scenario, based exclusively on a carbon tax reaching €225/tCO₂ by 2030, without additional compensation or innovation measures. In this case, the additional cost would rise to €42.75 per MWh of gas consumed, according to FIE calculations based on ECB projections.

These estimates, prepared by Foro Industria y Energía, illustrate the magnitude of the potential increase in energy costs for small and medium-sized industry if support mechanisms are not implemented. In less than a decade, gas consumption costs could multiply fivefold, compromising the competitiveness of sectors that still rely on this resource for their production processes.

Given this outlook, Foro Industria y Energía calls for concrete measures to ensure that this mechanism does not penalize small and medium-sized industries. First, it highlights the asymmetry in support in the design of the Social Climate Fund, which prioritizes vulnerable households and microenterprises, leaving out small and medium-sized industries that face the most burdensome investments.

Second, FIE emphasizes that the effectiveness of ETS2 requires explicit and accessible mechanisms to enable SMEs to adopt zero-emission technologies, especially in hard-to-electrify sectors where replacing gas-intensive processes is more complex and costly. Such support is key for the regulation to act as a real incentive for decarbonization, not just as an economic burden.

Finally, FIE reiterates that delays in transposing the directive into Spanish law generate legal uncertainty, which paralyzes long-term investment decisions necessary for this transformation. Foro Industria y Energía calls on the Spanish authorities to provide the sector with the legal certainty and regulatory predictability needed by urgently publishing and approving the legal framework that will govern ETS2 in Spain.