Regulation

Spain’s Royal Decree 214/2025 explained for manufacturers

Royal Decree 214/2025 requires companies obliged to report on sustainability to calculate their organisation’s carbon footprint every year, draw up a reduction plan and publish both. It includes at least Scopes 1 and 2. If you are a supplying manufacturer, it mostly affects you indirectly, through what your customers ask of you.

By Gonzalo Ruiz Saura, CEO and founder of Xain4 min read

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This article is general information with the official source at the end, not legal advice.

  1. CalculateEach year, the organisation's footprint using the official factors.
  2. PlanA reduction plan with a quantified target and base year.
  3. PublishBoth, free of charge and accessible.

What is Royal Decree 214/2025?

It is the Royal Decree of 18 March 2025 that expands the register of carbon footprint, offsetting and carbon dioxide removal projects, created by Royal Decree 163/2014, and sets who must calculate their footprint and publish a reduction plan. The full detail is on the regulation page.

Who does it affect?

Companies obliged to include non-financial information in their report, under article 49.5 of the Commercial Code and article 262.5 of the Corporate Enterprises Act, or the rules replacing them. Also ministerial departments of the central government and other central public sector entities.

What do they have to do?

  1. Calculate the organisation’s footprint every year, with the emission factors published by the Spanish Climate Change Office.
  2. Draw up a reduction plan with a quantified target against a base year and a horizon of at least five years.
  3. Publish both free of charge and accessibly.

And if I am a supplying manufacturer?

The Royal Decree does not impose Scope 3 on companies, but many ask their value chain for product data to complete their inventory or for other rules, such as the CSRD. So, if your customer is obliged, they are likely to ask for your product footprint.

How to prepare

Organisation and product footprints measure different things. To answer a customer you need the second. See how Scope 3 for purchased goods is calculated and what a customer expects when they ask.

If you are a supplier: five practical steps

  1. Find out whether your customer is obliged. If so, they are likely to be under pressure to complete their inventory and pass it down their value chain.
  2. Ask what data they need. Product, service or organisation footprint, and with what boundary and standard.
  3. Gather the technical documentation. Drawings, data sheets, bill of materials, processes and transport.
  4. Calculate with a recognised standard. A figure under ISO 14067 is easier to reuse.
  5. Deliver a document, not a loose number. A certificate with an identifier and breakdown.

Questions an obliged customer may ask you

  • What is the footprint of this product per unit, and with what boundary?
  • Which standard was it calculated under and who verified it?
  • Can you show the breakdown and the assumptions?
  • How often is the figure updated?
  • Do you have data from your own suppliers that improves it?

What the Royal Decree does not do

It does not make every supplier obliged nor set a product method: it regulates the organisation footprint. So for a manufacturer, the practical value of the text is understanding why customers are starting to ask for data and what they expect to receive. For the legal detail, the official source is the BOE and the regulation page.

What can you do this week?

Ask your sales team which large customers you have and whether any has started asking for environmental information, even informally. Note what they ask for and with what deadline. That gives you a realistic picture of the pressure you may receive in the coming months, far more useful than any general forecast.

Then decide for which products you want the figure ready. You do not need to cover the whole catalogue: the products you sell most to those customers are enough. Gather their technical documentation and calculate the footprint under a recognised standard. When the formal request arrives, you will answer with a certificate instead of asking for time.

How does Xain help?

Xain calculates the product footprint from the technical documentation you already have, with a method verified by LRQA and a traceable certificate, so you can answer an obliged customer without setting up a project. To complete their inventory with purchases, see procurement Scope 3 or talk to us.

Frequently asked questions

What companies usually ask before getting started.

Am I obliged if I manufacture?

Only if you are a company obliged to include non-financial information in your report. If not, the effect is usually indirect, through what obliged customers ask of you.

Does it include Scope 3?

It includes at least Scopes 1 and 2. Scope 3 is voluntary for companies.

Does it replace the product footprint?

No. Organisation and product footprints measure different things. The second is the one many customers ask their suppliers for.

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