The Malta Sociological Association (MSA) has submitted its views on proposed developments concerning the EU Emissions Trading System (ETS) and the implementation of financial compensation measures under ETS2, highlighting the need to ensure that Europe’s transition towards climate neutrality is environmentally effective, economically viable, and socially just. Safeguarding fair competition in maritime transport.
The MSA said that it noted the proposed update to the list of neighbouring container transhipment ports under the EU Emissions Trading System and supports measures that safeguard the environmental integrity of the ETS while ensuring fair competition across the maritime sector.
The Association has recommended that the implementation of the Regulation ”should not create incentives for shipping operators to relocate activities to neighbouring non-EU ports primarily because of lower labour costs, weaker social protections, or less stringent environmental and regulatory standards. Such practices could undermine the objectives of EU climate policy, social rights, and the principles of a just transition.”
The MSA stressed that particular consideration should be given to small island states and peripheral EU regions, whose ports play an essential role in territorial cohesion, connectivity, employment, and economic resilience.
”These regions should not be placed at a competitive disadvantage through regulatory asymmetries that encourage the diversion of maritime activities towards jurisdictions operating under substantially lower labour, social, or environmental standards,” it said.
The MSA therefore recommended that the implementation and future evaluation of the ETS incorporate Social Impact Assessment (SIA) alongside environmental and economic considerations. ”SIA can strengthen evidence-informed policymaking by identifying and assessing impacts on workers, port communities, regional development, and maritime employment. Ensuring a socially just transition under ETS2.”
The MSA said it also noted the European Commission’s initiative on financial compensation under ETS2, covering buildings, road transport, and additional sectors, and ”recognises its importance in supporting a fair and socially just transition towards climate neutrality.”
The Association recommended that the design, implementation, and evaluation of compensation measures explicitly incorporate Social Impact Assessment alongside environmental and economic considerations.
It said that carbon pricing and related measures may affect social groups unevenly, particularly lower-income households, older persons, persons with disabilities, and communities with limited access to affordable and sustainable transport or energy alternatives.
The MSA encouraged a ”stronger social rights approach, recognising access to affordable energy, mobility, and a healthy environment as important components of social wellbeing and inclusion. Financial compensation should therefore prioritise those most affected by the transition, while also supporting long-term investments that reduce social vulnerabilities and strengthen resilience.”
”Future evaluations of ETS2 compensation measures should assess their wider social impacts, including effects on inequality, energy poverty, transport accessibility, employment, and territorial cohesion. Recognising the needs of island and peripheral regions.” it said.
The MSA further emphasised that ETS2 should ”adequately account for the specific circumstances of small-island, insular, and peripheral regions within the European Union, as well as the particular challenges faced by small island states more broadly.”
The Association stressed that ”geographical isolation, dependence on maritime and road transport, limited economies of scale, and restricted access to alternative energy and transport systems can create additional social and economic pressures during the transition to a low-carbon economy.”
The MSA therefore called for appropriate mitigating and compensatory measures to address these impacts and ensure that climate policies do not disproportionately burden communities that already face structural geographical and economic disadvantages. Putting social impact at the centre of climate policy.
The MSA said that the transition to low-carbon transport, energy, and other sectors ”must extend beyond environmental and economic indicators. The social consequences of climate policy must also be systematically assessed.”
”Embedding Social Impact Assessment within the implementation and evaluation of the ETS and ETS2 would contribute to more comprehensive and evidence-informed policymaking. It would enable policymakers to identify unintended social consequences, anticipate distributional impacts, and develop measures that support workers, households, communities, and regions affected by decarbonisation,” it said.
The Malta Sociological Association said it believes that climate action should ”reinforce rather than undermine decent work, fair competition, social inclusion, and the long-term resilience of European coastal, island, and peripheral communities.”
It concluded by saying that a successful transition to climate neutrality must therefore be not only environmentally effective and economically viable, but also socially sustainable and equitable.
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