The Malta Sociological Association (MSA) notes the proposed update to the list of neighbouring container transhipment ports under the EU Emissions Trading System (ETS) and supports measures that safeguard the environmental integrity of the ETS while ensuring fair competition across the maritime sector.
The MSA recommends 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 risk undermining the objectives of the EU's climate policies, social rights, and the principles of a just transition.
Particular consideration should be given to small island states and peripheral EU regions, whose ports are essential for 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 to jurisdictions operating under substantially lower labour, social, or environmental standards.
The MSA also recommends that the implementation and future evaluation of the ETS incorporate Social Impact Assessment (SIA) alongside environmental and economic considerations. This would strengthen evidence-informed policymaking by assessing impacts on workers, port communities, regional development, and maritime employment, while promoting socially sustainable and equitable decarbonisation across the European Union.
The transition to low-carbon maritime transport should be environmentally effective, economically viable, and socially just, ensuring that climate action reinforces rather than undermines decent work, fair competition, and the long-term resilience of European coastal and island communities.
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