2003/44/EC, referred to as RCD1, introduced in 2006 has now, after 11 years been replaced by 2013/53/EC. 2013/53/EC, often referred to as RCD2 became optional in early 2016, then becoming mamdatory from 17th February 2017, when RCD1 ended.
RCD2 unsurprisingly is an extension of RCD1, introducing complexity in some areas (particularly in the treatment of multihulls and indeed any craft with deck recesses) and stricter requirements in others, particularly emissions. In terms of general changes, two stand out:
- Craft with toilets must now have holding tanks
- Craft must have a compliant boarding ladder which can be operated from the water (thus excluding any clip on ladders)
Probably the most significant changes for importers of used craft concerns gas emissions (noise emission requirements are unchanged).
Inboard Engines – Petrol
Four options exist, that’s one more than before, but the news is far from good.
EPA 2008 – In RCD1 EPA could only be used for Diesel engines, but in RCD2 it can be applied to Petrol too, but the hurdle values are higher and as the date implies this is unlikely to be available for pre-2008 engines.
CARB (California Air Resources Board) – CARB has for many years been the goto certification for engines sourced outside the EEA. The certificates are easily available and well organised. RCD1 required a minimum three star (CARB 3*) rating for compliance. Unfortunately RCD2 now requires a four start rating (CARB 4*) which excludes virtually all engines older than 2008 and quite a few that are newer too.
EU Compliance (CE marked) – Though not a new issue (some 2001 engines were CE marked for power rather than emissions), this time the impact is widespread. It’s a case of CE being the wrong CE for RCD2 compliance. This affects virtually all engines manufactured prior to 2017 (except those <37Kw). In practice, most pre-2017 engines that have CE on the engine plate will have been certified to RCD1 and are thus no longer compliant with RCD2, or put another way, were never tested to RCD2 (and won’t be). In one fell swoop, a CE on an engine plate has gone from being the best option (as it will have covered noise emissions too) to the worst.
Bodensee (BSO/SAV) - In the early years BSO/SAV provided options for older engines as it started before CARB (2003) so covered some engines from the 1990’s. Now however, few US engines are covered as there is a requirement for each specific engine to have unique certificate. This means we can’t use it for an engine model, without a specific certificate.
In conclusion, for pre-2017 engines EU certification is non-existent and BSO rarely applicable. CARB is still good but realistically not sufficient for pre-2008 engines. EPA offers a new possibility, but again only for 2008 and newer engines. So if your craft has a petrol engine originally built before 2008 you’ll probably be looking at replacement.
Inboard Engines – Diesel
Two options officially exist, EU RCD2 and EPA 2008. In practice many engines are also CARB certified and though we can’t use the certificates directly, we can use the test values which if sufficient can be used to demonstrate RCD2 compliance. BSO is not available for Diesels.
Note that for engines with power <37Kw (~50hp) the RCD2 reqirements are currently the same as RCD1 so any engine of this size with a CE mark on the engine plate will meet RCD2 requirements (~2006+).
In conclusion, for diesels >=37Kw, the best option is EPA 2008, which of course implies engines of this size manufactured prior to 2008 will need replacement.
This also covers PWC (eg jet skis). It’s a similar picture to that for inboard petrol (as most outboards are petrol) except that the CARB requirement is now three stars (CARB 3*) and not (yet) four stars (CARB 4*). EPA 2008 also works as does EU compliance to RCD2 (but again pre-2017 engines are unlikely7 to have been tested to RCD2).
In practice, many 4-stroke outboards will have CARB 3*, particularly the smaller units. There are now relatively few newer 2-strokes available ( a notable exception being the Evinrude ETEC series) and older units will almost certainly only make CARB 2* so won’t be compliant. The real problem area concerns the more powerful engines (eg Mercury Verado 200-350hp) which (for the Verado) were CARB 2* rated before the 2014 model year. Some, may also be EPA 2008 rated in which case this can be used to demonstrate compliance. EU RCD2 certification only applies to 2017 or newer and only in cases where the CE mark is on the engine plate.
Though most engines sold in the US are available (or at least found) internationally, not all manufacturers place the CE marked engine plate on engines sold outside Europe.
Mercury (outboards) is a case in point, in that for their new Verado units, only those built for Europe carry the CE. So even a new Verado purchased in the US, which may be identical to one packaged for Europe, won’t have a CE on the engine plate. Without this reference on the engine we can’t use the EU declaration, so be careful. For common Inboard engines (eg V8 series from Mercruiser and Volvo Penta) these manufacturers started putting CE on virtually every engine in 2006, making them truly international, but please bear in mind that compliance with RCD1 for gas emissions is no longer sufficient, except for engines <37kw.
If in doubt, contact us in the first instance, preferably attaching a photo of the engine plate reference to emissions.
More on RCD2 changes
One of the other ‘painful’ changes relates to the calculations around ‘Recess areas’, required for craft with a fully enclosed deck. In this scenario a recess is any enclosure in/on a deck which could retain water. The most obvious candidate being a cockpit.
The description in RCD2 (particularly the initial version) is ambiguous and complex, relying on data which though available to a designer, and possibly the builder is unlikely to be known to the owner. This means we have to use alternative approaches which may be more conservative and thus more likely to fail. It’s a pain, but when you pay faceless experts in Europe to ‘improve’ the RCD one should not be surprised the result is more complex and unwieldy. After all, the powers at be would much rather you didn’t import at all.