STX Commodities B.V.
STX
STX actively trades in Renewable Energy Certificates, Carbon Offsets, Biofuels, Renewable Gas, and provides consulting services in emissions assessment and decarbonization strategy.
ID: 404044351983-49
Lobbying Activity
Meeting with Margareta Djordjevic (Head of Unit Energy)
5 Nov 2025 · STX Reintroduction & Exploring A Pilot for the EU Energy Efficiency Market
Response to European Climate Law amendment
15 Sept 2025
STX Group supports the EUs binding target to reduce net greenhouse gas emissions by 90% by 2040, emphasizing the need for a comprehensive policy framework that combines carbon removals, international credits, renewable fuels, and energy efficiency to achieve cost-effective and competitive decarbonization. [1] Support for 2040 Climate Target: STX welcomes the EU Commissions proposal for a binding 90% net greenhouse gas reduction by 2040 as a critical step toward climate neutrality by 2050, requiring clear policies to mobilize private capital and maintain industrial competitiveness. [2] Carbon Removals in EU ETS: The group advocates integrating permanent, high-integrity carbon removals into the EU Emissions Trading System (ETS) with strict monitoring, reporting, verification, and liability rules, including eligibility for biochar and a pilot phase before 2030. [3] Use of International Credits: STX supports limited use of high-quality international credits under the Effort Sharing Regulation to provide cost-effective flexibility while ensuring these credits complement, not replace, domestic emission reductions, with introduction planned from 2031 onwards. [4] Renewable Fuels Role: Renewable fuels such as biofuels, biomethane, and emethane are vital for sectors where electrification is not feasible, with biomethane highlighted for its strategic benefits including fossil gas displacement and soil carbon improvement. Regulatory alignment and market integrity are essential for scaling these fuels. [5] Biomethane Market Integration: STX calls for removing barriers to cross-border biomethane trade, prioritizing a fully operational Union Database to ensure tracking and prevent double counting, and supports the EUs one-grid principle for efficient transport infrastructure. [6] Energy Efficiency and White Certificates: Energy efficiency is emphasized as the first fuel, with STX advocating harmonized White Certificate schemes across Member States to enable cross-border trading, mobilize private finance, and reduce compliance costs. [7] Policy Mix for 2040 Target: Achieving the 2040 target requires a balanced approach combining carbon removals, international credits, rapid renewable fuel scale-up, and harmonized energy efficiency certificates to preserve competitiveness and attract investment.
Read full response26 Aug 2025
STX Group (STX) welcomes the introduction of the Carbon Border Adjustment Mechanism and appreciates the opportunity to provide feedback on the Commissions initiative to assess possible scope extensions, anti circumvention measures, and clarify the rules on indirect emissions. Our comments refer mainly to the rules for calculation of emissions for electricity. Please see the attached PDF for our full feedback.
Read full responseResponse to EU industrial maritime strategy
28 Jul 2025
STX Group, a Netherlands-based environmental commodity trading firm, welcomes the European Commissions initiative to shape a forward-looking Industrial Maritime Strategy. Drawing on practical experience supporting shipping companies with FuelEU Maritime and ETS compliance, STX provides recommendations to help build a coherent and investment-ready policy framework that supports both decarbonization and industrial competitiveness. [1] A coherent certification and compliance landscape is essential to ensure environmental integrity and regulatory certainty. Current misalignments, such as the use of Tank-to-Wake (TtW) accounting in the ETS versus Well-to-Wake (WtW) in FuelEU Maritime, undermine recognition of renewable fuels like biomethane, e-methanol, and bioLNG. STX recommends updating ETS MRV guidance to allow WtW reporting, harmonizing recognition of RED-compliant fuels as zero-emission under ETS, aligning documentation requirements (including enabling Proofs of Sustainability to serve as compliance evidence), and fully operationalizing the Union Database (UDB) to support traceability and reporting of certified fuels. STX also highlights the potential of virtual BioLNG, where biomethane is virtually liquefied for maritime use. Unlocking this pathway requires recognizing LNG terminals and DSO networks as part of the gas grid, removing restrictive physical flow and licensing requirements, and clarifying that grid-injected biomethane and the liquefied molecule are equivalent, provided emissions from liquefaction are properly accounted for. [2] EU-level funding instruments such as the Innovation Fund, the Modernization Fund, and a future Net-Zero Fund must offer predictable, scalable rewards for overcompliance and innovation. STX calls for alignment with the IMOs upcoming global framework, which introduces continuous, verifiable incentives for decarbonization via a certificate-based system. These mechanisms should ensure fungibility, transparency, and liquidity. Reward certainty depends on eligibility clarity, reliable lifecycle assessment protocols, and banking or price floor mechanisms. Reinforced maritime-dedicated funding windows can further accelerate investment and deployment. [3] A robust market for FuelEU Maritime compliance units can reduce costs, stimulate innovation, and reward frontrunners. STX recommends establishing a compliance market with a clear timeline, rules, and governance structure. The Commission should introduce tiered unit classes based on fuel type, origin, and verification status, define banking and expiry rules in advance, and publish regular market data such as unit issuance and redemptions to support trust and transparency. In conclusion, EU leadership on maritime decarbonization will depend on reducing regulatory uncertainty, enabling scalable reward systems for high-performing fuels, and establishing flexible, transparent compliance markets. STX encourages the Commission to focus on aligning regulation, certification, finance, and market infrastructure to unlock investment and deliver an ambitious yet feasible green transition for the maritime sector. Further information for these recommendations can be found in the full document attached: STX Group Contribution to the European Commissions Industrial Maritime Strategy Consultation.
Read full responseResponse to Industrial Decarbonisation Accelerator Act
8 Jul 2025
STX Group, a global environmental commodity trader facilitating the low-carbon transition, welcomes the European Commissions Industrial Decarbonization Accelerator Act (IDAA) as a timely initiative to unlock investment in hard-to-abate sectors. For the IDAA to succeed, it must address the structural barriers that continue to delay industrial decarbonization. Regulatory uncertainty remains one of the main impediments to clean industrial investment. Lengthy and complex permitting procedures, fragmented governance, and inconsistent policy signals prevent companies from moving forward with projects. The IDAA should offer regulatory clarity, streamline permitting aligned with other EU instruments, and provide a coherent framework across Member States. Public financial support will be essential to de-risk investments. However, it must be deployed carefully. Grant funding should target high-impact innovation and disruptive technologies not yet mature for traditional financing. Two-way carbon contracts for difference (CCfDs) should be limited to emerging markets and new technologies. Meanwhile, the broader investment landscape will benefit more from a policy environment that enables long-term power purchase agreements, financial guarantees, and tax incentives, which are tools that create stable conditions for market-driven decarbonization. A clear designation of priority industrial decarbonization projects would help accelerate decision-making and create certainty for investors. Prioritizing entire sectors under this category would send a strong political and market signal, allowing industrial actors to plan collectively and mobilize action faster. Stimulating demand for low-carbon industrial products is equally crucial. Although the technological capacity to differentiate cleaner products exists, downstream sectors and consumers lack willingness to pay a premium. Public procurement should serve as the backbone of lead markets, shifting away from price-only criteria toward sustainability-based purchasing that favors EU-produced and climate-aligned products. This shift would also reinforce demand for biofuels, renewable electricity GOs, renewable gas, and high-quality carbon credits. The creation of an EU-wide label on the carbon intensity of industrial products can support transparency and harmonize market expectations. However, to have real impact, a voluntary scheme may not be enough. A mandatory label, developed in consultation with industry and calibrated to minimize administrative burden, would ensure comparability and strengthen buyer confidence. Particular attention must be paid to avoid excessive compliance costs that could harm competitiveness, especially for SMEs. In sum, the IDAA has the potential to become a cornerstone of Europes clean industrial future. It must resolve regulatory bottlenecks, focus public funding on catalytic areas, prioritize sectors to unlock scale, and activate demand through smart procurement and harmonized product labelling. STX Group stands ready to contribute its expertise in environmental markets to help bring this framework to life.
Read full response8 Jul 2025
STX Group is a global leader in environmental commodity trading, driving the transition to a low-carbon economy by enabling the market-based exchange of carbon credits, renewable fuels, and other decarbonization instruments. As the EU strengthens its Emissions Trading System (ETS) to meet the 2040 climate target, the system must evolve to ensure environmental integrity, support market innovation, and provide a clear, investable framework across all sectors. STX Group advocates for a more coherent and forward-looking ETS architecture, one that fully integrates high-integrity carbon removals, supports renewable fuels for decarbonization, and aligns with corporate sustainability reporting and broader EU climate policy. Permanent removals such as biochar, BECCS, and DACCS should be eligible for use within the ETS, provided they meet rigorous monitoring, reporting, verification (MRV), permanence, and liability requirements. Their integration must be governed by robust market infrastructure and a technology-neutral, science-based definition of permanence. A buffer mechanism should be established to insure against reversal risks. To unlock the full decarbonization potential of renewable gases and advanced biofuels, the ETS must establish a harmonized EU standard for zero-emission recognition. Mass balancing systems should be explicitly accepted. Guarantees of Origin (GOs) and Proofs of Sustainability that meet RED III criteria must be considered sufficient for ETS compliance. Where renewable gas production falls outside RED certification, tailored guidance is needed to avoid excluding legitimate low-carbon volumes. Overlapping compliance checks between ETS and RED frameworks must be resolved to eliminate duplication and reduce administrative burden. STX supports maintaining the current approach to indirect cost compensation through state aid mechanisms. However, to ensure that this aid genuinely incentivizes decarbonization, proof of renewable electricity consumption should be based solely on market-based instruments, such as Guarantees of Origin (GOs), rather than location-based reporting. This would ensure greater transparency, comparability, and consistency across Member States. Equally important is aligning the ETS with corporate sustainability reporting obligations under the Corporate Sustainability Reporting Directive (CSRD) and the EU Sustainability Reporting Standards (ESRS). Companies need clarity on how to report and validate the climate value of renewable gases and carbon removals within the ETS. Integrated guidance and methodologies would enhance transparency, strengthen investor confidence, and ensure that corporate disclosures reflect true decarbonization efforts in both compliance and voluntary markets. By reinforcing the ETS with robust removals, credible fuel recognition, and seamless policy alignment, the EU can secure its leadership in climate action while building a carbon market that is fit for purpose, innovation-ready, and trusted by both industry and society. STX Group stands ready to support EU policymakers, regulators, and market stakeholders in building a future-proof ETS, one that delivers real emissions reductions, drives investment in innovation, and maintains Europe's global leadership in carbon markets.
Read full responseMeeting with Mario Ronconi (Head of Unit Directorate-General for International Partnerships) and ACT group and
27 May 2025 · Exchanges on Global Gateway implementation and on EU private sector engagement in South East Asia in the context of Global Gateway
Response to Rules for the FuelEU database under Article 19(3) of the FuelEU Maritime Regulation
3 Mar 2025
We are submitting this feedback on behalf of STX Group, a stakeholder in environmental commodities and maritime compliance. We support the FuelEU Maritime Regulation's goals and appreciate the opportunity to contribute. Our key recommendations focus on fairness, market integrity, and confidentiality, especially in compliance pooling and access rights. Clear definitions and functionalities will help prevent market distortions, protect sensitive data, and ensure a level playing field. Article 3 Access rights and management actions The companies access to "limited information on the pooling of compliance arrangements should be further defined: We suggest that a company participating in a compliance pool can view only the contributions and allocations related to its own ships within the pool, but not the total compliance balance of the entire pool or the specific contributions and allocations of other participants' ships. The only company that should be able to see the full allocation of compliance balances within the pool is the company responsible for managing and allocating those balances. Justification: Compliance balances, allocations, or even just IMO numbers can reveal strategic decisions about the other parties. This refined definition would prevent strategic manipulation and maintain fairness while naturally allowing verifiers and authorities with full oversight. Additionally this extends to the information on the compliance balance to be made available by verifiers to other users, according to Article 5(6), so it is crucial that the provisions of Article 3 are set appropriately. This article should include the right for company to assign account access rights to third parties as they may want to outsource management of their database account. The management functionalities should be defined clearly to avoid confusion/ too much room for interpretation on the access granted to Administering States Article 5 Management of the compliance balance and FuelEU penalties The pooling functionality should be further defined/restricted as confidentiality must be safeguarded: "The FuelEU database shall incorporate a pooling functionality that enables companies and verifiers to interact with one another in order to verify compliance at the pool level without disclosing individual ship-level allocations. The verifier shall confirm the total verified compliance balance of the pool and ensure that each participant meets their required contribution without revealing specific allocations to pool participants other than the allocating entity." Justification: Verifiers see the full allocation of compliance balances within the pool, and they may inadvertently disclose allocation details to pool participants, intentionally or not.
Read full responseResponse to Carbon footprint methodology for electric vehicle batteries
28 May 2024
STX Commodities (STX) welcomes the introduction of the Product Carbon footprint (PCF) requirements for EV batteries to maximize the decarbonization potential of the battery value chain in the European Union and appreciates the opportunity to provide feedback on the methodology. Our comments refer mainly to the electricity modelling rules. STX opposes the proposed exclusion of contractual instruments such as energy attribute certificates (EACs), including GOOs, RECs, and I-RECs in accounting for electricity consumption taken from the grid. The draft states that in many non-EU jurisdictions, single claiming of environmental attributes cannot be ensured, though many countries such as the United States, Canada, the United Kingdom, Japan, and Australia have robust EAC systems that have long demonstrated verifiability and reliable mechanisms against double claiming of green power. It is, in fact, the proposed reliance on the national average electricity consumption mix in section 2.4 of the annex which poses a threat of double claiming, particularly for countries with high renewables share in their national production mix. Producers claiming the green attributes of their grid will claim the same energy units as those using EACs of that country (through local procurement or import), a direct violation of the Renewable Energy Directive (RED). The use of unbundled EACs is in line with industry standard emission accounting schemes used by the European Commission such as Greenhouse Gas Protocol and guidelines set by the Association for Issuing Bodies, and is embedded throughout established EU regulations and directives. The only clear method of accounting in renewable energy is with a verified EAC. The PEF method already sets criteria for contractual instruments to ensure reliable tracking and claiming, which many non-EU countries meet. Where reliable national residual mixes are disclosed and PEF criteria are met, contractual instruments such as EACs should be favoured in the accounting of emission factor from grid electricity consumption. End users in the European Union still rely primarily on unbundled GOOs to fulfil green claims. Even in cases of instruments such as Power Purchase Agreements (PPAs), now well developed in the EU and primarily entered for electricity price stability, nearly all the electricity generated goes through the grid and is backed by Guarantees of Origin from the projects covered in those PPAs. Excluding these agreements penalizes European manufacturers and creates conflicting signals from the Commission on the European GOO system, considering market-based instruments like GOOs are used throughout various EU GHG reporting directives. Furthermore, it reduces the incentive to invest in developing new renewable energy assets through standard PPAs. STX urges the Commission to reconsider its proposed carbon footprint methodology to ensure consistent approaches for renewables tracking and the inclusion of long established, robust, and verifiable mechanisms like GOOs, RECs, and I-RECs.
Read full responseMeeting with Henna Virkkunen (Member of the European Parliament)
15 Feb 2024 · 2040 Climate Target - industry and energy
Meeting with Heidi Hautala (Member of the European Parliament)
12 Feb 2024 · Courtesy meeting in energy and climate policy