The Spanish logistics sector closed 2024 with revenues of approximately €104 billion, representing 7.8% of national GDP. The transformation underway — driven simultaneously by digitalisation, pressure to decarbonise transport chains, and a deeply revised European regulatory framework — creates a landscape of opportunities and risks that operators of all sizes must manage with rigour.
The New European Regulatory Framework: CSDDD and Its Implications
Directive (EU) 2024/1760 on Corporate Sustainability Due Diligence (CSDDD) is arguably the standard with the greatest structural impact on European supply chains since the creation of the single market. Adopted in June 2024, it requires large companies to identify, prevent, mitigate, and remedy actual and potential adverse impacts of their operations and value chains on human rights and the environment.
For the logistics sector, the impact is bidirectional: large logistics operators are direct subjects of the standard when they exceed the thresholds (1,000 employees and €450 million in turnover from 2027), but they are also indirect subjects as suppliers in the supply chains of industrial companies already obliged. Practical implications include:
- Supply chain mapping: identification of all first and second-tier suppliers, with risk assessments on labour rights, environmental impact, and governance.
- Contracts with due diligence clauses: contracts with transport, warehousing, and distribution subcontractors must incorporate clauses requiring ESG standard compliance and permitting audit.
- Complaints management system: obliged companies must establish a mechanism for parties affected by operations to submit complaints. This mechanism can overlap with the whistleblowing channel required by Spain’s Law 2/2023, if designed correctly.
Decarbonisation of Transport: Fit for 55 and Carbon Border Adjustment
The European legislative package Fit for 55 — targeting a 55% reduction in GHG emissions by 2030 compared to 1990 — includes measures with direct impact on freight transport:
Extension of ETS to road transport. From 2027, ETS2 (the Emissions Trading System for buildings and road transport) will enter into force, placing a price on road diesel emissions. The road transport sector, which represents 27% of transport CO2 emissions in Spain, will see operating costs increase in line with the price of emission allowances.
Emissions standards for heavy vehicles. Regulation (EU) 2019/1242, strengthened in 2023, establishes that truck manufacturers must reduce average fleet CO2 emissions by 45% by 2030 and 90% by 2040. This is accelerating the transition to zero-emission vehicles (electric or hydrogen) in urban and short-haul transport fleets.
Carbon Border Adjustment Mechanism (CBAM). Regulation (EU) 2023/956 establishes a levy on imports of certain products (steel, aluminium, cement, fertilisers, hydrogen, electricity) based on their carbon footprint. Logistics operators managing imports of these products must adapt their information systems to capture and report the embedded emissions data required for CBAM calculations.
Mandatory Digitalisation: eCMR and Electronic Traceability
Spain ratified in 2023 the Additional Protocol to the CMR Convention on the Electronic Consignment Note (eCMR). Adoption of eCMR eliminates paper documentation in international road freight transport and facilitates compliance with the traceability requirements of the CSDDD and CBAM. However, interoperability between the systems of the various parties in the transport chain (shipper, carrier, recipient, customs authorities) remains the main obstacle to mass adoption.
Spain’s Sistema de Suministro Inmediato de Información (SII) of the AEAT, mandatory for companies with turnover exceeding €6 million, already requires immediate declaration (within four days) of issued and received invoices. For logistics operators managing thousands of monthly invoices with multi-country clients and suppliers, SII integration with Transport Management Systems (TMS) is an unavoidable operational requirement.
Public Procurement and Green Logistics
Law 9/2017 on Public Sector Contracts and European public procurement directives incorporate environmental sustainability criteria that favour logistics operators with low-emission vehicle fleets, ISO 14001 certification, or accredited waste management. Directive (EU) 2019/1161 on the promotion of clean vehicles sets minimum procurement targets for low- or zero-emission vehicles that Spanish public bodies must meet in transport tenders.
For logistics operators working with public administration — healthcare supply transport, postal distribution, military logistics — adapting to these requirements is already a condition for accessing contracts, not an option.
Impact on Financial Reporting
The growing weight of ESG obligations is also reflected in financial information. The EU Taxonomy Regulation (Regulation 2020/852) classifies economic activities according to their contribution to European environmental objectives. Transport and storage activities have their own Taxonomy categories, and companies subject to sustainability reporting (CSRD) must calculate and publish what percentage of their revenue, capex, and opex comes from Taxonomy-aligned activities.
For logistics operators that form part of the value chain of large industrial groups, the pressure to calculate and communicate the carbon footprint of their services (Scope 3 emissions for the shipper) is already a contractual reality that anticipates the regulatory obligation.
Recommendations for Logistics Operators in 2025
Adapting to the new regulatory and competitive environment requires concrete action on several fronts:
- Supply chain risk map: identify suppliers with the greatest ESG risk exposure (countries with high forced labour risk, suppliers without environmental certifications) and establish an improvement or substitution plan.
- Documentation digitalisation: implement eCMR and connect TMS systems with the SII to reduce manual work and reconciliation errors.
- Fleet decarbonisation strategy: evaluate electrification of urban and short-haul routes as a measure combining operational cost reduction (electricity price versus diesel) with ETS2 readiness.
- Contract review with clients and suppliers: incorporate due diligence clauses, emissions reduction commitments, and audit rights aligned with CSDDD requirements.
- Financial reporting update: begin calculating EU Taxonomy indicators and carbon footprint of services (Scope 1, 2, and 3) to be prepared when clients contractually require it.
At BMC, our operations team helps logistics companies navigate ESG compliance, supply chain due diligence, and financial reporting obligations. Learn about our business services.
