Stockholm Exergi

Stockholm Exergi is Stockholm’s energy provider.

Lobbying Activity

Response to Circular Economy Act

4 Nov 2025

Circular Economy Act call for evidence, contribution from Stockholm Exergi Stockholm Exergi is the energy company serving Swedens capital. We ensure that the region can continue to grow with resource-efficient access to heating, electricity, cooling, and waste treatment services. By relying on EU-sourced feedstock, our plants secure Stockholms energy supply while helping to stabilize the regional electricity grid during fluctuations and shortages. We provide heat to more than 800,000 residents through our 3,000 km district heating network, which serves as a platform for innovation and public value created in collaboration with our customers and other stakeholders. Alongside our other major energy generation plants and storage systems, we own and operate two waste incineration facilities with a combined capacity of approximately 900,000 tonnes per year. Together, these facilities produce around 2.2 TWh of heatcovering about 18% of Stockholms heating demandand approximately 0.5 TWh of electricity. We are currently constructing one of the worlds largest facilities for permanent carbon dioxide removal, supported by multiple funding sources including the EU Innovation Fund. The project aims to capture and store 800,000 tonnes of biogenic CO annually, starting in 2028. As a company, we are committed to achieving net-zero emissions by 2035. Our contribution Stockholm Exergi welcomes the proposed Circular Economy Act as an important step toward establishing a well-functioning market for recycled materials in Europe. As part of our energy generation and waste treatment services, we actively promote a circular society and continuously seek new ways to increase recycling rates. To this end, we have introduced a differentiated gate fee to incentivize improved upstream sorting , and additional sorting prior to incineration has been implemented. Achieving net-zero is central to our operations. We are currently exploring how our responsibility for delivering energy and waste treatment services to Stockholm can be ensured at the same time as reaching this objective. As part of this process, we are developing our perspective on how carbon and material flows can best support a circular society with robust energy provisioning and responsible waste treatment services. Against this background, we would like to share our current insights at a principal level, focusing on key challenges, opportunities, and policy considerations. In essence, we believe that to increase recycling and circularity, policy focus must put even more emphasis on upstream incentives. Simultaneously, CCUS and consistent EU-wide carbon pricing, through the inclusion of waste incineration and landfill in the ETS, will be key in supporting sustainable handling of unrecyclable fractions and providing precious carbon for future applications.
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Response to Carbon removals, carbon farming and carbon storage - certification methodologies for permanent carbon removals

19 Sept 2025

Stockholm Exergi strongly welcomes the CRCF and its implementation in the Commission Delegated Regulation, with its detailed implementation in the acts Annex. We limit our comments to BioCCS, where we deem the Annex to provide a robust and promising basis for a standardized approach to permanent removals. In our view, there are a few important improvements that can still be made, which are reflected in this consultation response - see attached file.
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Response to European Climate Law amendment

15 Sept 2025

Stockholm Exergi would like to emphasise the critical importance of the 2040 target in sending a clear message to investors, other market actors, citizens and Member States parties and legislators. The political signal sent by the 2040 climate target is fundamental for Europes ability to reach net-zero by 2050. It will set the frame for how companies and Member States will be assessing risks and opportunities for new climate investments, and determine if Europe can leverage the cleantech sector for competitiveness and prosperity. The target will therefore be essential to secure a prosperous and sustainable Union capable of delivering growth and new job opportunities, including accelerating the build out of the permanent carbon removals industry, which is vital for Europe to reach net-zero and net negative post 2050 - as set out in Article 2 of the EU Climate Law. The 2040 target should therefore explicitly clarify that domestic permanent removals may, in general, be used to meet the 90% net emissions reduction target. To build the European permanent removal industry required to meet the objectives set in the EU Climate Law, the 2040 target should build demand for domestic permanent negative emissions. The absence of clarity on the role of domestic permanent removal towards the 90% net target risks creating uncertainty for the market, investors and purchasers. The EU and Member States have invested significant public money into European permanent removals projects, and making such removals eligible towards the 2040 target is essential to protect these investments and attracting capital and government aid for an accelerated scale-up of the sector. In addition, domestic permanent removals should be introduced in the EU ETS, as fast as possible, while safeguarding the ETS and EUs ambition on decarbonisation. Only domestic permanent removals should be introduced, as soon as the Carbon Removal and Carbon Farming (CRCF) Regulation is operational - expected to happen in 2028. They should qualify as an optional way to fulfil a companys obligation to acquire European Union emissions Allowances (EUAs), with a view to compensating for residual emissions from hard-to-abate sectors once all unabated emissions have been reduced. To safeguard the pace of industrial decarbonisation and increase the willingness to pay a premium for permanent removal in the ETS, for every permanent removal introduced an EUA should be withdrawn a 1-in-1-out principle. In the absence of separate targets for removals and reductions, in case policymakers see a risk that domestic permanent removals could significantly impact the pace of emission reductions, the proposals presented can be complemented with safeguards. For example, they could be expressed as a percentage of unabated emissions. Stockholm Exergi remains available for any questions you might have. You can reach out to Karin Boman Röding, Head of Public Affairs and Strategic Communication, at karin.boman.roding@stockholmexergi.se About Stockholm Exergi: Stockholm Exergis BECCS Stockholm initiative is a leading cleantech permanent carbon removals project that is supported by the European Commissions Innovation Fund (180 million Euros). It will remove and permanently store up to 800,000 tonnes of CO2 from the atmosphere per year - almost 2% of Sweden's yearly greenhouse gas emissions. Stockholm Exergi recently concluded the worlds largest permanent carbon removal agreement with Microsoft for 5.08 million tonnes. The company took its Final Investment Decision in March, for a total investment of 1.2 billion EUR, and started the construction of its plant last month. In a competitive bidding process, the project has been selected to receive close to 2 billion in government aid over 15 years of operation, starting 2028.
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Meeting with Wopke Hoekstra (Commissioner) and

12 Jun 2025 · Stockholm Exergi’s BECCS ‘first shovel in the ground’ event

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

29 Jan 2025 · Introductory meeting

Response to Amendment of the EU ETS Monitoring and Reporting Regulation (MRR) in response to the ETS revision/Fit For 55 (Batch 2)

24 Jul 2024

Amendment 25(c) concerning Article 49 proposes that: "An operator of a CO2 transport infrastructure or a storage site shall monitor emissions from leakage events, fugitive emissions and vented emissions from any CO2 mentioned in the first sub-paragraph, including from CO2 stemming from entities not carrying out activities listed in Annex I to Directive 2003/87/EC, and report emissions as if the CO2 were fossil," This implies that emitted zero-rated CO2 (as defined under the regulation) should be considered as it were fossil emissions within the boundary of the "CO2 transport infrastructure", which includes liquefaction and intermediate storage. This goes against the new Commission's desire to develop a "Clean Industrial Deal" as it is oblivious to the industrial challenge the Union is facig in kick-starting and scaling the industry for permanent carbon removals. The proposal to treat zero-rated CO2 from BECCS and DACCS as fossil in the transport phase, should be revised, because: - It reduces the incetives to invest in tech-CDR and makes the achievement of the Union's climate targets more expensive - It distorts competition between non-fossil CCU (usage) and non-fossil CCS (i.e. removals/CDR), since transport of the same CO2 to CCU is not covered by these rules - It is unreasonable since the CO2 is zero-rated, as defined by the regulation itself, and has not yet entered final storage (which could legitemately be considered to belong to the "fossil domain") - It is administratively complicated, since before injection to geological storage, the liquefied, temporary stored and transported CO2 could go either to CCU or CDR The Commission does not provide any convincing argument why zero-rated CO2 should be treated this way in the transportation link. The fact that reporting may follow from IPCC/UNFCCC rules does not imply that the full consequences of the ETS should become applicable to the zero-rated CO2. Consequently, the proposed text should be amended with an extra sentence at the end: "...., except that for zero-rated CO2 this reporting shall not incur an obligation under Directive 2003/87/EC to acquire emission allowances as regards emitted CO2 within the transport infrastructure."
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