St1 Nordic Oy
St1
St1 is a Nordic energy company with its own production of liquid fuels for the transport sector; road, marine and aviation.
ID: 446001847598-51
Lobbying Activity
22 Sept 2025
On Biogenic Emissions Carbon Capture and Storage Bio-CCS: 1) To support development of new DACCS and Bio-CCS initiatives, we propose widening the coverage of the methodology from geological storage to permanent non-geological storage, including injection and mineralization to concrete and cement. There is a large variation of techno-economically feasible alternatives for carbon storage between the Member States. Supporting credible development of a voluntary carbon market in all carbon removal methodologies is important to advance climate change mitigation. It is also important to ensure that the regulation does not pose a barrier to advancing new technologies. 2) To support new investments in long-term capital-intensive facilities with Bio-CCS, the activity period should be aligned with economic lifetime of the facilities. The 10-year cap on activity periods for DACCS and Bio-CCS introduces unnecessary uncertainty for operators and investors. Since these facilities are capital-intensive and typically designed for 2030 years of operation, a longer activity period (e.g. 20 years) would better align with economic lifetimes, reduce transaction costs, and improve financing certainty, while still allowing monitoring and methodologies to evolve. Periodic reviews of methodologies can be maintained without forcing operators into short renewal cycles. 3) Reporting requirements should be clarified and harmonized to prevent overlaps with ETS reporting. Consolidated reporting formats should be allowed where ETS is already available. On biochar: 1) We recommend permitting aggregated product batches, when feedstock and process parameters are consistent, and allowing reduced sampling frequency once process stability has been demonstrated. This would ensure integrity while reducing unnecessary administrative and laboratory costs. 2) We propose either removing or at least lowering the threshold temperature. Current 350°C threshold unintentionally excludes valid carbonisation processes that yield stable carbon, such as torrefaction (typically 200300 °C) and hydrothermal carbonisation (HTC) (180250 °C in wet conditions). Both produce carbonaceous solids (torrefied biomass, hydrochar) with significant stability. Excluding them would reduce innovation and close off viable pathways for durable carbon storage. 3) We propose introducing materiality thresholds (e.g. <2% of the total GHG balance) or allowing default emission factors, to exempt minor emission sources while maintaining environmental integrity. Current requirement for detailed accounting of energy use at application sites is appropriate for large-scale projects, but it may create administrative burdens for small projects where such emissions represent a minor share of the total balance. 4) We suggest widening the scope of eligible forms of biochar applications. Composting, incorporation to soil after water treatment activity and construction materials such as insulation boards/composites should be included in the scope, as these are viable applications for biochar and offer a range of usage methods for biochar. Finally, we wish to highlight a critical gap in the current regulatory framework: the absence of a methodology for crediting avoided emissions from Bio-CCU technologies. Bio-CCU can contribute to climate mitigation by enabling the re-use of captured Bio-CO in products and industrial processes to replace fossil CO2. For example, in Food & Beverage industry, it is used e.g. for carbonation, packaging and preservation, chilling/freezing, fermentation re-use, and inerting/storage protection. However, without a recognized crediting or accounting system, Bio-CCU projects are at risk of being excluded from carbon accounting and incentive mechanisms. This regulatory uncertainty may discourage investment and delay the deployment of Bio-CCU and at the same time Bio-CCS solutions, despite their potential to support EU climate targets.
Read full responseResponse to Sustainable transport investment plan
4 Sept 2025
St1 Nordic Oy is a Nordic energy company whose vision is to be the leading producer and seller of CO-aware energy. St1 is committed to advancing low-carbon solutions for the aviation and maritime sector. In our view, the current policy frameworks and support mechanisms are important, but insufficient to drive the necessary scale of change. Aviation The aviation sector is undergoing a critical transition. Despite recent technological advancements, St1 sees that the sector will continue to rely heavily on liquid fuels for the foreseeable future. But there is a shortage in the production of sustainable fuels today. Challenges include price and offtake agreements, as well as feedstock availability. Market for bio-SAF already exists but is highly unstable due to regulatory volatility. For e-SAF, the market will be created when mandates come into effect and the product is traded. In principle, regulation should determine the early market prices based on penalty levels set in the ReFuelEU Aviation. However, the current penalty levels are so high that the market players see them as unsustainable hence, expect them to be changed or the system to be modified so that the penalties will not be realized. The visibility of market development is clouded, and uncertainty persists. In the current situation, mandates and penalties are not sufficient tools to guarantee the uptake of e-fuels. Producers need long-term commitments from buyers to make investment decisions, but airlines have limited willingness to pay. To address the problem, further support mechanisms for producers are needed to reduce product price risks and to attract funding from external sources. This includes a combination of loan guarantees, capital expenditure funding, and a revenue certainty mechanism preferably in the form of a Contract for Difference, which has been proven to be an effective tool in introducing new technologies. The main benefit of a CfD is that it restores the investment environment by offering revenue certainty. Compared to other forms of revenue certainty mechanisms, with CfDs the fuel producers maintain access to the molecules and negotiate contracts directly with fuel suppliers or airlines. This creates an early mover advantage by leaving a potential upside between the strike price and the penalty levels. Additionally, integrated companies that are both producers and obligated parties are guaranteed access to volumes they have invested in to meet their own compliance needs. As a first step, it is important that the upcoming Sustainable Transport Investment Plan outlines the need for a revenue certainty mechanism to support e-fuels market development. Thereafter, swift implementation of the mechanism is needed to resolve existing market challenges and scale e-SAF across Europe. Finally, to support the broadening of feedstock potential for SAF, similar incentives and support mechanisms are needed to develop solid biomass-based bio-SAF use. Marine To decarbonize the marine sector in the mid- to long-term, a mix of alternative fuels will be essential. Price competitiveness and production capacity remain key challenges in the sector. The infrastructure required to deliver the products is also lacking and needs investment to be built. A revenue certainty mechanism will likely be crucial also for renewable fuel production for marine market, especially for e-methane. Given the lack of cost competitiveness with fossil fuels and the need for investor confidence, support structures, combined with long-term policy stability, are needed to accelerate final investment decisions and unlock the full potential of fossil-free maritime operations. The development of dedicated bunkering infrastructure for fuels like ammonia, methanol, and liquefied biomethane is also critical and requires targeted investment support. While AFIR provides a regulatory framework, additional support measures would benefit Member States.
Read full responseResponse to Verification of carbon removals, carbon farming and carbon storage in products
1 Jul 2025
The implementing rules of verification are a core part of a certification system that ensures efficient and functioning processes. It is especially important that the roles, responsibilities and tasks of stakeholders are clear, non-overlapping and accountable. Keeping this target in mind, we would like to draw attention to following points in the advancement of the implementing rules of Regulation (EU) 2024/3012. 1) Overlapping, ambiguous roles between certification schemes and bodies to be clarified. There is ambiguity of roles especially related to reporting and documentation. For example, certification schemes monitor auditing quality, but they also rely on certification bodies to self-regulate and report. This dual structure can create information and accountability gaps. In terms of documentation, both the certification schemes and certification bodies are responsible, yet the division and boundaries between scheme and audit-level responsibilities and records needs delineation to avoid duplication or omission. Additionally, both must ensure transparency and data sharing, but regulations lack clarity on who is ultimately accountable for data integrity in shared systems like the Union Registry. 2) Consistency in timelines to be assured. Some of the proposed monitoring and auditing timelines seem to conflict with certification timelines. This may cause practical challenges in implementing the actions. For example, internal annual monitoring is required yearly for audit reports while for instance peatland activitys monitoring / certification period is proposed to be done every 5 years. The yearly monitoring might not bring new information but simply increase the workload. In addition, certification bodies should rotate the auditors every 3 years. This is shorter than the anticipated certification period for some activities. 3) Competency requirements of auditors to support the market entry of new players. Finding competent auditors can become a bottleneck. The lack of auditors can already be seen in current certification efforts. Therefore, it is important to ensure that required auditing competencies are sufficient, yet do not hinder market development to reach EU climate targets. In addition, sufficient funding for independent audits and technical experts is needed to support market entry opportunities. As an example, certification bodies may face the challenge of finding qualified experts for auditing work, and 3-year-cycle requirement increases the challenge. This can form a barrier to up-scale certification schemes. Therefore, the 3-year-cycle should be re-evaluated, also referring to previous remarks about timelines. The draft further requires a minimum of 2 years experience in fuel life-cycle assessment. It would be important to re-evaluate this requirement, especially from the viewpoint that the competence requirements should not unintentionally form a barrier to new auditors to enter the market. It could be, for example, assessed whether the requirement should only apply to the auditing team lead, or if the certification scheme training alone provides sufficient competences. 4) Group auditing should be an option when it does not affect credibility and reliability of results. Keeping in mind the significant task ahead of reaching EU climate targets, there is also a colossal auditing effort needed. This ties a lot of resources that could otherwise directed at implementing the necessary climate change mitigation actions. Therefore, it should be considered whether the wording only in the Article 12 part 1 is needed and whether the certification scheme itself should be given more flexibility in evaluating whether group auditing is an option if it provides sound, reliable and suitable basis for each action.
Read full responseMeeting with Ville Niinistö (Member of the European Parliament)
15 Feb 2023 · ST1 on transport decarbonisation (staff level)