David Greening Naval Architect Ltd has provided  Recreational Craft Directive advice to boat builders, designers and boat owners since 1998.  The RCD is now being taken seriously following recent prosecutions against boat builders for non-compliance, spot checks by Trading Standards officers and the difficulties in selling non CE marked boats.

A users guide to the  Recreational Craft Directive 

This guide was originally written to answer common questions about the Recreational Craft Directive and has recently been updated to reflect the changes brought about by the Amending Directive.  It is not exhaustive and is intended as a primer since there are thousands of pages of standards and legislative documents that may be applied to demonstrate conformity.  Should you require further advice or if you would like a quotation for RCD compliance work please contact David Greening at david@boatsurvey.biz

What is the Recreational Craft Directive (RCD)? 

The RCD is a legal requirement in European Member States (EEA). Recreational craft must conform to the Essential Requirements (ERs).  It is good for consumers since it details the minimum acceptable standards for design and construction of recreational craft.  Manufacturers also recommend design categories and maximum recommended loads which can be found on the builders plate.  It is suggested that some caution is exercised when applying Design Categories, as the user’s experience and skill must also be considered. 

What is the Amending Directive? 

The Amending Directive was introduced and consolidated with the Recreational Craft Directive on 30^th June 2004, however most of the additional requirements of the amending directive did not become mandatory until 1^st January, 2006.  This guide has been updated in order to reflect these changes.

Which boats need to comply? 

All recreational craft of between 2.5m and 24m which have been put onto the market or into service in the European Community (EEA) since 16^th June, 1998 and that are not exempt. 

What are there exemptions from RCD compliance? 

The main exempt craft include;

Who is responsible for compliance? 

The company or person first placing the product on the European Market (EEA).  Putting into service is considered to be the same as placing on the market, so a boat brought into the EEA from outside should be CE marked by the importer. 

Therefore if you are considering purchasing a craft from outside of the EEA for import you are strongly advised to check that a craft is compliant prior to purchase and also to factor in the RCD compliance costs into your budget.

What are the builder’s obligations?

The builder must;

The manufacture must satisfy these requirements even if using a self-assessment module.

How do I know that a boat does comply?

The most important document is the Builder's Declaration of Conformity.  However if you are looking at boats for purchase, good indicators are having a valid HIN number at the starboard side of the transom, a builder's plate with a CE mark near the steering position and an owner's manual.  Usually the Builder's Declaration of Conformity is appended to the owner's manual.

What happens if a boat is not CE Marked?

Non compliance is a criminal offence and is enforced by Trading Standards Officers with penalties of up to £ 5,000 &/or 3 months imprisonment.  Operators can encounter difficulties when travelling from state to state or when selling their craft within the European market without appropriate documentation. 

There is a real risk that should a non-compliant craft be involved in a marine accident it will be traced back to the builder or importer who could be considered to be negligent.

With an increased awareness to the RCD brokers and purchasers are unlikely to touch recreational craft that have been built or imported since 16^th June, 1998 unless they are supplied with an acceptable Builder's Declaration of Conformity.

What is a Notified Body and what do they do? 

Notified Bodies are Government appointed organisations that will verify technical information provided by the manufacturer before issuing EC Type Examination Certification or authorising the builder to affix the Notified Bodies distinguishing mark on the builders plate.   

A Notified body must be involved in Design Category A, B or C [craft over 12m] assessment and also to issue a report for all Post Construction assessments, however builders may self certify Category C and D assessments for craft under 12m.

What boats need to comply with noise emissions requirements? 

Essential requirements for noise emissions of propulsion engines were added by the Amending Directive.  Since this topic is complex, the following advice is only intended for one-off assessments.  It is worth seeking an expert's advice if it is unclear whether the installation being considered complies or if you are a series production builder where a boat family approach might be considered.

All craft with a Froude number of less than 1.1 and a Power Displacement ratio of less than 40 are deemed to comply with the noise requirements.  This means that most displacement craft comply.  However these calculations must to be certified by a Notified Body.

If the craft has an outboard motor or an engine and sterndrive with an integral exhaust, these should have been tested by the engine manufacturer.  The sterndrive should be CE marked and a Certificate of Conformity should be supplied with the engine.

If the outboard motor or engine and sterndrive installation were offered to the market or put into service in the EEA prior to 1^st January, 2006 then it does not need to comply. 

If the installation is not in any of these three groups, then a "pass by" (on the water) test is likely to be required.    This can be expensive and will require notified body involvement.

What boats need to comply with exhaust emissions requirements? 

Essential requirements for exhaust emissions of propulsion engines were added by the Amending Directive.  If the engine was offered to market or put into service in the EEA prior to 1^st January, 2006 then it need not comply with the exhaust emission requirement. 

If not it must be correctly CE marked by the engine manufacturer and a Certificate of Conformity should be supplied with the engine.  If neither of these requirements are met, testing is likely to be required which may prove difficult and expensive. 

Terminology 

Design Categories

A.      OCEAN: Designed for extended voyages where conditions may exceed wind force 8 (Beaufort scale) and significant wave heights of 4 m and above but excluding abnormal conditions, and vessels largely self-sufficient.

B.      OFFSHORE:  Designed for waves of up to 4m significant height and a wind of Beaufort force 8 or less.  Such conditions may be encountered on offshore voyages of sufficient length or on coasts where shelter may not always be immediately available.  Such conditions may also be experienced on inland seas of sufficient size for the wave height to be generated. 

C.      INSHORE:  Designed for waves of up to 2m significant height and a typical steady wind force of Beaufort force 6 or less.  Such conditions may be encountered on exposed inland waters, and in coastal waters in moderate weather conditions.

D.      SHELTERED WATERS:  Designed for voyages on sheltered coastal waters, small bays, small lakes, rivers and canals when conditions up to, and including, wind force 4 and significant wave heights up to, and including, 0.3m may be experienced, with occasional waves of 0.5m maximum height, for example from passing vessels.

Declaration of Conformity; certifies that the craft meets the Essential Safety Requirements.

Essential Requirements (ER);  these are based on a comprehensive list in the RSG Guidelines, compliance can normally be demonstrated by applying a relevant harmonised standard (ISO) or equivalent.

Froude Number; Fn = V / (g*Lwl)^0.5 where V = boat speed in m/s, g = 9.8 m/s and Lwl in metres.

Owner’s Manual; includes details of the craft and manufacturer.  Loading and design category information and guidelines as to the safe operation of the craft and its systems, as may be requires by the ER’s.

Power Displacement Ratio; = P/D where P = engine power (kW) and D = Displacement (tonnes).

Technical Construction File (TCF); the manufacturer is required to complete and retain technical documentation which demonstrates a yachts compliance with the RCD.

How can David Greening Naval Architect Ltd help?

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