STX Group

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.

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.

STX welcomes the opportunity to provide input on the Commission's post-2030 renewable energy framework to boost "EU competitiveness and energy independence through reliable, competitively priced and decarbonised energy for all users," with our full response attached. STX supports a post2030 framework that is predictable, marketbased, coherent across sectors and supportive of the EU internal market.

STX Group welcomes the European Commissions initiative to update the greenhouse gas accounting methodologies for biofuels, bioliquids and biomass fuels under the Renewable Energy Directive. We support the overall direction of the draft presented, as it strengthens the credibility of renewable fuels markets, improves investment signals, and reduces the scope for inconsistent interpretation across Member States.

STX Group welcomes the European Commission's initiative to develop an energy efficiency framework for the decade ahead. STX is uniquely positioned to contribute: it is the only market participant currently operating simultaneously across white certificate schemes in Spain, France, Poland and Italy, with over a decade of active engagement.

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 welcomes the introduction of a datacentre rating scheme under the Energy Efficiency Directive as a tool to enhance transparency, guide procurement and investment decisions, and support the decarbonisation of the datacentre sector. STXs comments focus on the use of Guarantees of Origin (GOs) under Annex III, which are essential for tracking renewable electricity attributes across the EU internal market.