CE Mark Boats Europe
and
Recreational Craft Directive 94/25/EC

by Gary Polson 
RBBI

The European Commission has established a group of requirements called the EU Directives (European Union Directives) which will require goods in certain categories (ie. recreational boats) sold there to confirm to a single document to meet legal requirements of the European Community. Products meeting the directives will be branded with the CE logo shown in the top corners of this document (less the RBBI), which is why the program is referred to as the CE mark. Many additional specifications and standards may be required of the product, but having the CE mark means it is legal. One quote we encountered was, "CE marking does not indicate conformity to a standard, but indicates conformity to the legal requirements of the EU Directives."

The conformance to these EU Directives can be "self assessed" and documented (for some directives) or an outside body called a "Notified Body" can come in and make the assessment, similar to an ISO 9000 assessment. Approved firms are then certified to use the CE mark. Many of the EU Directives require manufacturers to have a quality system to ISO 9000 in operation and use the assistance of a "Notified Body" in order to legitimately apply the CE marking to their product.

Overall, the infrastructure around the CE mark and the Recreational Craft Directive bears many similarities to the infrastructure around ISO 9001, ISO 10,006, ISO 14000, ISO 19011 and ISO/TS 16949, in that a world of consultants have establshed training, auditing, certification, and verification services.

"Notified Bodies" are basically consulting firms that have been certified and approved by the governing bodies to administer the assessments, quite similar to the ISO 9000 program. In Europe, Notified Bodies are appointed by the government of each country. In the United States, the NIST (National Institute of Standards and Technology) oversees the program. Once appointed, each Notified Body can then serve manufacturers all over Europe as well as in the United States and other countries. These firms are certified for specific EU Directives (not all "Notified Bodies" are certified to administer the recreational boat directive.) Most Notified Bodies do provide access to the full set of EU Directives documents and can give you some assistance in getting prepared in areas they are not certified in.

There is another layer of firms called "Competent Bodies" that have approval to assist manufacturers in achieving certification for some EU Directives. Notified Bodies are required for more hazardous situations.

Those firms that "self assess" to meet the Directives are issued a SDOC (Self Declaration of Conformance). Effective 16 June 1998, all boats covered by the Recreational Craft Directive must meet the requirements and bear the CE mark to be sold in the participating European Countries.

The CE Mark Recreational Craft Directive 94/25/EC has been updated (called the "new" RCD) to 2003/44/EC. They remain separate documents. The "new" one extends its coverage to Personal Water Craft (PWC), ammends some requirements, and establishes limits for exhaust emission and sounds.

A combined version of the two regulations is available from the European Union's Recreational Craft Directive web site.

More coverage of the Recreational Craft Directive and related standards for other industries can be found at the EU site, New Approach

The International Council of Marine Industry Associations (ICOMIA) has a Technical Info page on the RCD that provides several helpful tools.

Several of the Recreational Craft Directive standards are now International Standards Organaization (ISO) standards. A listing of corresponding ISO Standards by number is provided by ICOMIA.

General Coverage of the CE mark program is provided by export.gov

The letters "CE" come from the French words "Conformite Europeene".

TWO-TEN News Coverage

Two-Ten Communications News
26 June 1996

FAIR WIND FOR BRITISH BOAT-BUILDERS

British boat-builders who can implement quickly the procedures necessary for compliance with the Regulations will gain an immediate head-start over competitors who delay and are not well prepared.

The Recreational Craft Regulations 1996 (Statutory Instrument No 1353 of 1996) will remove the need for separate requirements on documentation and testing for individual member states in the Community market.

Manufacturers who have complied with the requirements and put the CE mark on their products may trade freely throughout the Community and without the need for further checks.

Now that the regulations have come into force, manufacturers will have the option of either complying with the new regulations or continuing as before under the current regime until June 16 1998, when the transition period ends and both the EC Directive and the UK Regulations become mandatory.

UNS
Contact: Department of Trade & Industry Press Office 0171-215 5962/1 After hours: 0171-215 5110/5600

Michael Clarke Home Page

• This directive has been passed by the European Parliament and comes into full effect in 1998. However, I am concerned about the implications this will have on the design of English traditional style narrowboats.
• Narrowboats come under the design category 'Sheltered waters' - Designed for voyages on small lakes, rivers, and canals where conditions up to, and including, wind force 4 (Beaufort scale) and significant wave heights up to, and including, 0.5 m may be experienced.
• The requirement to meet 0.5m significant wave height, I believe, is onerous. By definition, the term significant wave height means the average amplitude of 1/3 highest waves and is used because wave motion is a (long-crested) irregular wave system. With a 0.5m significant wave height, approximately 5% of the waves encountered can be expected to be greater than 1m, i.e. greater than 2m crest to trough.
• I don’t doubt that a narrowboat can be made to survive such conditions as demonstrated by Chris Coburn’s narrowboat ‘Progress’, and conversely, Nick Sanders narrowboat Unspoilt by Progress II's sinking on the River Danube possibly shows how susceptible narrowboats are in rough conditions. However, the RCD states, it is the boat builder’s responsibility (and supported with documentation) to certify the boat is safe for use, and designed and constructed to withstand all parameters under all conditions. I believe that present narrowboat designs would suffer stability problems in a beam sea and flooding problems in following and head sea situations, and therefore, some modifications would be required to meet the regulations.
• I would very much like to hear from other interested persons who share the same and/or other concerns or who have a different interpretation of the requirements of the RCD.

Email from Tom Nighty - BMIF - 19/9/96

• Dear Mr Clarke
• I am sorry to have taken so long in responding to your fax. To a degree it is due to the vast pressure of work relating to the RCD implementation and our concerns about some of its elements.
• All major concern is exactly what you have detailed in your Email letter, that is the need for a 5th design category. I and many others have expressed our grave concerns about the effect the 0.5m significant wave height has on the vast number of boats specifically designed to be used on smooth water where maximum wave heights are unlikely to exceed 0.5m and a significant wave height of 0.2m would be more appropriate.
• As the trade association for the small craft industry we are making great efforts to:-
• 1. Make the legislators understand the consequences of this situation.
• 2. Actually change the directive to overcome the problem.
• I have contacted my associates in other EU countries to alert them of the problem and hope that they will support this view.
• Having belatedly confirmed your concerns, if you need further information, please contact me again.
• Yours sincerely - T.J.Nighy - Technical Manager

Conformance Web Page

"The Directive applies to all craft intended to be used for sporting and recreational purposes with a hull length of between 2.5 and 24 metres. Certain particular items of equipment are also covered, including ignition-protected equipment for inboard and stern drive engines; start-in-gear protection devices for outboard engines; steering wheels, steering mechanisms and cable assemblies; fuel tanks and fuel hoses and prefabricated hatches and portlights."

"In all there are thirty separate headings under which safety requirements are listed. These include requirements for marking, stability, fire protection, gas equipment, engine protection and many other items. Some are already the subject of harmonized standards, while others have standards in preparation."

Export Observer Article

Export Observer
November 1996
by Phil Gardiol

What To Look For In A Notified Body

Price - Obtain quotes from at least a few Notified Bodies; pricing can vary dramatically from one notified body to the next.

Service - Many Notified Bodies do not provide adequate service; usually due to peak load situations and some simply disregard customer needs.

Consulting - Some Notified Bodies will offer advice in addition to testing to accelerate the process an simplify the process for you. This may include a desk audit of your technical documentation prior to actual submission. Some will not.

ISO 9000 and Product Certification - Very convenient and economical (when both are required) if a notified body can provide both services.

Documentation - Find a notified body that will accept documents in English.

Mutual Recognition - Look for a notified body that will accept ISO 9000 registration from a U.S. registrar to avoid duplicate costs; also , find a notified body that will consider using qualified U.S. based subcontractors for audits to reduce travel related expenses.

"Standard Setting in the European Union"

NIST now provices a European Standards Information page.

Firms Providing Training in the Recreational Craft Directive

• American Boat & Yacht Council ABYC

• National Marine Manufacturers Association NMMA

• British Marine Federation BMF

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