EEA Directives

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RCD 94/25/EC - 2003/44/EC

When considering imported craft the only Directive relevant to you is the Recreational Craft Directive (RCD) 94/25/EC as amended by 2003/44/EC.  Originally drafted in the mid 1990's this was implemented across the EEA (European Ecomonic Area) on the 16th June 1998.  Various revisions have occurred but for you the most significant of these was introduced on the 1st of January 2006.

Though the history is worthy of note, retrospective assessments are not available so we must deal with the requirements today to understand what hurdles exist.

The RCD offers a number of Modules, the application of which depends on the nature of the craft, whether a new or used craft, whether certification is sought by a builder or importer and whether a one off or production line.  For you as a Broker, the only relevant module is PCA or Post Construction Assessment.

PCA was introduced on 1/1/06 and made two major changes to the way RCD compliance was addressed.  The first key change was that it made the involvement of a Notified Body mandatory.  No longer could the importer or their surveyor/representative 'self-certify' a used craft.  The second key change was the introduction of emissions requirements both for gas (NOx) and noise.

Notified Body (NoBo)

There are approximately 22 Notified Bodies in Europe (EEA) authorised to issue compliance certificates in respect of the RCD, none outside the EEA.   There are many more NoBo but these are NOT authorised to address the RCD, they address other unrelated Directives.  Each NoBo has a unique number (eg 1521) which must be displayed on both the CE plate and the Declaration of Conformity (DoC).

Any assessor who tells you they can CE mark a used craft (technically this could be new, just not sold by the manufacturer direct) without involving a NoBo is a fraud as is anyone who specifies a NoBo who cannot address the RCD.  I have recently seen both from a Florida based surveyor, for the second time.

RSG

The RSG (Recreational craft Sectorial Group) is the body which provides guidance to the various NoBo on the interpretation and application of the RCD.  The RSG Guidelines are issued annually and generally speaking are accepted by both the NoBo community and the customs authorities in each EEA state.  Currently there is one notable exception, Norway where a very hard line interpretation is applied which enforces requirements (rightly) ignored by other countries.  In particular whilst the RSG Guidelines allows a NoBo to use comparable emissions certification (eg CARB for SI engines) when EU certification doesn't exist, Norway insists that every engine is CE marked by the manufacturer, or removed/replaced.  Draconian though this sounds, this may be just the start as we have heard recently of plans to widen this CE by manufacturer requirement to other components such as tanks, steering equipment and other fuel/electrical system components.  

You can register and download a copy of the current RSG guidelines, or alternatively email us and we'll send you a copy.

ICOMA

ICOMA stands for the International Council Of Marine Industry Associations.  This is a useful source of information relating to the RCD as well as other issues marine.  Our only criticism is that some of the content is a little out of date and should really have been updated by now.  You can get some other useful guides fro the ICOMA website.  Take a look in their Library.

Written By: Rowland Smith

Rowland Smith is a Naval Architect and founder of Gablemarine.  His industry experience includes Lloyds Register, British Shipbuilders Hydrodynamics Ltd, Cammell Lairds, BP Shipping Ltd & Conoco.  He has a degree in Naval Architecture, a Diploma in Marketing (CIM) and an MBA (Cranfield School of Management).  He has also held Director level positions in a number of technology and engineering companies, including CEproof, which provides RCD compliance software to builders. 

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