Public Consultation Feedback: EU Emissions Trading System (ETS) – update to list of neighbouring container transhipment ports

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.

Public Consultation Feedback: EU Birds and Habitats Directives – stress test

The Malta Sociological Association (MSA) notes the stress test of the Birds and Habitats Directives and recommends that any review strengthen implementation while maintaining the Directives' high level of environmental protection. The MSA recommends mainstreaming Social Impact Assessment (SIA) alongside ecological and economic considerations, recognising that biodiversity conservation has important implications for communities, livelihoods, health, cultural heritage and quality of life. The review should strengthen stakeholder participation, policy coherence and evidence-informed decision-making, while giving particular attention to small island states and coastal communities, where environmental and social systems are closely interconnected. Simplification should improve implementation without weakening environmental safeguards or social sustainability.

Public Consultation Feedback: European Ocean Research and Innovation Strategy

 The Malta Sociological Association (MSA) notes the European Commission's initiative to develop a European Ocean Research and Innovation Strategy and recognises its importance in supporting sustainable, resilient and evidence-informed ocean governance.

The MSA recommends that the Strategy explicitly strengthen the contribution of the social sciences, including sociology, alongside the natural sciences, engineering and technological innovation. Many ocean challenges—including climate adaptation, the blue economy, fisheries, coastal development, maritime transport, marine conservation and ocean governance—have important social dimensions that require interdisciplinary research.

The MSA also recommends mainstreaming Social Impact Assessment (SIA) within European ocean research and innovation. Research and innovation should not only advance scientific and technological knowledge but also improve understanding of how ocean policies and innovations affect coastal communities, workers, social inequalities, cultural heritage, wellbeing and public participation.

Particular attention should be given to the experiences of small island states, peripheral regions and coastal communities, where environmental, economic and social challenges are often closely interconnected.

The MSA further encourages the Strategy to promote participatory and transdisciplinary research, bringing together researchers, policymakers, civil society, industry and local communities in the co-production of knowledge. Such an approach would contribute to more socially just, inclusive and effective ocean research and innovation across the European Union.

Public Consultation Feedback: Review of EU rules on alternative fuels infrastructure

The Malta Sociological Association (MSA) notes the review of the EU rules on alternative fuels infrastructure and recommends that their implementation explicitly incorporate Social Impact Assessment (SIA) alongside environmental, economic and technical considerations. The deployment of alternative fuels infrastructure has important implications for accessibility, affordability, employment, territorial cohesion and social inclusion. The MSA also encourages the mainstreaming of social rights, ensuring equitable access to sustainable transport infrastructure, particularly for small island states, peripheral regions and vulnerable communities. Infrastructure planning should be informed by meaningful stakeholder participation and evidence-based assessment of social impacts to support a transition that is environmentally sustainable, economically viable and socially just.

 

Public Consultation Feedback: Targeted consultation on the draft guidelines for the classification of high-risk artificial intelligence systems

The Malta Sociological Association notes the European Commission's draft guidelines on the classification of high-risk Artificial Intelligence (AI) systems and recognises their importance in promoting trustworthy, human-centred AI across the European Union.

The MSA recommends that Social Impact Assessment (SIA) be incorporated into the classification and assessment of high-risk AI systems. While technical performance, safety, and legal compliance are essential, AI systems may also generate significant social risks, including impacts on employment, inequality, education, healthcare, public services, privacy, social inclusion, democratic participation, and public trust. A systematic assessment of these social impacts would strengthen evidence-informed, transparent, and socially responsible  governance.

The MSA also recommends that the European Commission complement regulatory measures with comprehensive public education and outreach initiatives to improve AI literacy among citizens, organisations, businesses, educators, and public authorities. Greater awareness of both the opportunities and the risks associated with AI is essential for informed participation, responsible use, and public confidence in these technologies.

Embedding SIA alongside technical and legal assessments, while investing in public education and engagement, would contribute to a more accountable, inclusive, and socially sustainable framework for the development and deployment of AI across the EU.

Public Consultation Feedback: AI Technical Update of Passenger Ship Safety Standards

The Malta Sociological Association notes the EU AI Technical update of passenger ship safety standards proposal. The proposal is welcome insofar as it updates and clarifies passenger ship safety standards. However, passenger ship safety should not be understood only as a technical matter. It is also a question of social infrastructure, island connectivity, labour conditions, accessibility, public trust and blue economy governance. The Commission should therefore accompany the technical update with a concise Social Impact Assessment, paying particular attention to island and peripheral regions, vulnerable passengers, crew working conditions, small operators, accessibility, emergency communication and the continuity of essential passenger services. This would strengthen the proposal’s legitimacy, proportionality and practical effectiveness.

Public Consultation Feedback: European Maritime, Fisheries and Aquaculture Fund (EMFAF)

 The Malta Sociological Association (MSA) notes the European Commission's initiative to simplify the implementation of the European Maritime, Fisheries and Aquaculture Fund (EMFAF) and to transpose the WTO Agreement on Fisheries Subsidies into EU law.

While reducing unnecessary administrative burdens is important, regulatory simplification should not overlook the social dimensions of fisheries and maritime policy. The Commission itself identifies challenges relating to employment, labour conditions, support for small-scale fisheries, and generational renewal. These are fundamentally social issues, which reinforce the need to integrate Social Impact Assessment (SIA) principles into the policy process, even where a full impact assessment is not undertaken.

The MSA recommends that particular consideration be given to the realities of small island states such as Malta, where coastal communities face unique structural challenges, including limited territorial space, climate change, competing coastal uses, tourism pressures, and dependence on marine resources. In such contexts, seemingly technical regulatory changes may have significant social consequences.

The Association also welcomes the EU Strategy for Coastal Communities, which recognises the importance of locally led solutions, resilient coastal economies, and vibrant coastal communities. EMFAF implementation should be fully aligned with this vision by recognising fisheries not only as an economic sector but also as a source of cultural heritage, social cohesion, community resilience, and sustainable local development.

The MSA further recommends that EMFAF continue to prioritise small-scale and artisanal fisheries, which make important contributions to local employment, food security, social and cultural cohesion, maritime heritage, and environmentally sustainable fishing practices. At the same time, public funding should avoid reinforcing forms of industrial fishing that contribute to environmental degradation, biodiversity loss, and unequal competition that undermines the livelihoods and long-term viability of small-scale fishers.

Future monitoring of EMFAF should extend beyond administrative efficiency and financial absorption to include social indicators relating to employment quality, generational renewal, community resilience, social inclusion, and the wellbeing of coastal communities. Such an approach would strengthen evidence-informed policymaking and contribute to environmentally sustainable, socially just, and resilient fisheries governance across the European Union.