Gablemarine and CE

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People talk of a CE marking service, CE proofing, CE certification and CE compliance, so lets first put things into perspective. 

ce.gifThe CE mark is a universally recognised mark which implies compliance with a European Directive and/or ISO standard, in this case the Recreational Craft Directive (RCD) 94/25/EC as amended by 2003/44/EC.  We're interested in a CE mark for the imported boat as a whole (including engines if fitted) and possibly a CE mark for emissions on each engine.

Typically an imported boat will have a significant number of components (pumps, generators, A/C units etc) which will have a CE mark, but remember, this is just for that component and addresses a different Standard or Directive.

So, our aim is to CE mark an imported boat as proof of compliance with the Recreational Craft Directive (RCD).  To achieve this for used boats (even if technically unused) we undertake a Post Construction Assessment (PCA) during which we document how a craft does, or will, comply with each requirement from the Directive.  For Post Cosntruction we also look at emissions, both gas and noise and seek out certification which demonstrates engine compliance.  The compliance report, referred to as a Technical Construction File (TCF) is a comprehensive 100+ page report which considers each element of the requirements in turn.  As such it forms a record which can be inspected by a national authority and/or Notified Body within the statutory 10 year period.

Please be aware that not all individuals or companies offering a CE Marking service actually do so.  Please read our page entitled Pitfalls of CE Marking in the USA before deciding who is best for you. The cowboys in the US don't always ride horses and invariably they don't produce the full TCF you should insist on.

Gablemarine offers a range of CE marking service products, both pre-purchase and post-purchase.

  • Pre-purchase services include our pre-purchase CE Marking Assessment and CE Emissions Assessment, both designed to ensure you understand the likely compliance issue before committing to purchase.
  • Post-purchase services include the full CE marking service and Noise Emissions Testing as well as certificates to support claims for exemption from the RCD and as a means of verify CE status prior to a sale within the EU/EEA.

CE Markings in the form of a CE Plate should normally be located close to the helm position and in full view, the idea being that an inspector (eg Customs Official) can view the plate from the dockside.  Note also that all PCA craft will be issued with a new CIN, a label for which should be placed on the starboard (RHS when viewed from behind) transom and in the 'secret location' described in the Owners Manual.

One last point to note in relation to PCA and CE marking is that the importer must provide an address in the EU for the Declaration of Conformity (DoC) to be valid.  Only an importer with an EU address can import a craft from the US and for this reason whilst a US seller may (reluctantly) agree to pay for the CE Marking service they cannot be responsible for compliance or sign the DoC as they will not have an EU address.

New Construction

Our CE Marking services extend to the CE Marking of new craft as well as used.  New craft, sold by the manufacturer or their authorised representative, are not subject to Post Construction Assessment (PCA) but one or more of the other Conformity Assessment Modules contained within the RCD, normally in both the design and production phases of development.  These other Modules are A, Aa (A little a), B, C, D, E, F, G and H and in some cases as mentioned more than one will be applied at the same time eg B+C.  What Modules are applied depends on the Design Category and the length of the hull.

Modules, B+C, B+D, B+E, B+F, G or H can be applied to craft of any Design Category and Length.  In addition the following options exist.

Design Catagory / Length Lh 2.5m - 12m 12m - 24m
A (Ocean), B (Offshore) Aa None
C (Inshore)

A, A+Aa

None
D (Sheltered) A, A+Aa A, A+Aa

Note that builder self certification (Module A) is only an option for Category D or Category C (under 12m Lh).  Module Aa must involve a Notified Body and is typically relevant where a builder requests that a Notified Body or similar provides compliance documents for Stability and Buoyancy (ISO 12217), Structures (ISO 12215) or Noise Emissions (ISO 14509).

Unlike PCA craft, a new craft will retain the CIN number issued by the manufacturer in the country of origin.

 

Remember though, that a vendor within the EEA who claims CE marking compliance must be able to provide evidence to support this.

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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