CE Marking... has anyone actually done it?

Cookie Jar

Cookie Jar

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Hi everyone,

For the last few weeks, I have been reading all that I could get my hands on about this, and although the requirements and steps needed are more or less clear, the overall costs just seem impossible to anticipate. It's such a grey area...

Anyway, I was wondering if some of you have actually done it ?
And if so, could you give me just a "round number" on how much it costed?
Did you hire one of those companies to do everything for you, or did you arrange for all the separate steps and inspections on different places by yourself?

The boat is a small Dehler Varianta 65 and, of course, being of a certain age and before the RCD even existed, it does not have anything to start with. No plate, no HIN, no owner manual, no nothing... just a small "hand written" hull number in a bit of paper that was glued to the side of one stern locker (according to some owner's, this is the hull number and they are all roughly in the same place on this boats).

with more than 4000 of these made, I am hoping that at least one has gone through this process :)

To clarify, I'd like to do this because of two reasons:
First, due to my work I will again be changing the country of residence and probably again in 2 or 3 years... and I'd like not to have issues anywhere if I want to sell it and/or register it in a country that does require official technical info.
(registering it in Portugal, just as one example, is impossible without at least one of these:

  • CE plate
  • Owner manual
  • Declaration of conformity

Of course... I can always "kindly ask" Lloyds to classify it...but I guess that the price of such service would be enough to buy 5 boats like mine :nonchalance:

Any help or guidance will be highly appreciated!
 
What year is the boat?
That's important because if it's post 1992, or 1998 then it will require CE.
If earlier, it won't.

But it should be the manufacturer's responsibility to CE mark it, which they will have done if the boat was made after the years stated above and sold any within the EEA (European Economic Area).
Very difficult to do this after the boat has been designed and built although not impossible, as you need design information about the boat.
 
Yes, but according to what I have been reading, all boats need to have a CE mark if they are to be sold... even between private buyers. Owners of boats manufactured and put in operation in the EU prior to RCD regulations and therefore without CE marking, are free to keep them and sail them... just not sell them!
The worst part for me is that some countries require registration...which in turn can only be made if official technical documentation is provided!

What a nightmare!
 
Trundlebug said:
What year is the boat?
That's important because if it's post 1992, or 1998 then it will require CE.
If earlier, it won't.

But it should be the manufacturer's responsibility to CE mark it, which they will have done if the boat was made after the years stated above and sold any within the EEA (European Economic Area).
Very difficult to do this after the boat has been designed and built although not impossible, as you need design information about the boat.
Click to expand...
Not quite, as I understand it.
ANY boat requires CE marking on being imported into the EU, even if it is an old boat that wouldn't have required it if it was in continuous use in the EU. But exporting it and then re-importing it resets the clock, so to speak. Further, it isn't the RCD regulations in force when built that matter, but the RCD regulations in force on the date of import - which might be significantly different even if the boat was originally CE marked. But the point is that export and re-import resets the clock.

Concerning cost, I really don't know. But there are some show-stoppers; for example, an older engine or one made for a different market may not be capable of meeting the emissions regulations now in force. That should be discoverable, but if it doesn't, it's a new engine. However, if that's OK, you CAN mark it for a lower category than its actual capabilities - few yachts would fail to meet the requirements for class D (inland waterways!), and I understand that it is quite cheap and easy to obtain that. But if you want it to be in an RCD category that reflects the capabilities of the yacht, then the design data relevant to the RCD may be difficult to obtain without expensive testing by a marine architect. Of course, some countries restrict the use of a yacht to the waters designated by its RCD classification, so having a realistic classification is a "good thing".

Other threads have suggested costs somewhere between not a lot and too high to be realistically feasible. It all depends on yacht!
 
The idea that all boats sold in the EEA must be RCD compliant and certified is preposterous (as well as being completely at odds with the experience of many, many people on here).

From the RYA (and legion other sources):
A boat does not need to comply with the RCD if it was/is:
built in the EEA prior to 16 June 1998; or
in use in the EEA prior to 16 June 1998; or
only visiting the EEA for reasons of tourism or in transit (time scales are undefined); or
an exemption listed below.

(The exemptions include all sorts of oddballs from kayaks to hovercraft, which won't concern most of us.)

It is, of course, a fact, albeit a semantic one, that all boats meeting these exceptions rules are RCD compliant.

Import/export and re-setting the clock is also irrelevant: that pertains only to taxes.

If in doubt. Cookie Jar, I suggest you contact one of the companies offering RCD certification. They'll tell you you're bothered about nothing.
 
Last edited:
Trundlebug said:
What year is the boat?
That's important because if it's post 1992, or 1998 then it will require CE.
If earlier, it won't.

But it should be the manufacturer's responsibility to CE mark it, which they will have done if the boat was made after the years stated above and sold any within the EEA (European Economic Area).
Very difficult to do this after the boat has been designed and built although not impossible, as you need design information about the boat.
Click to expand...

not quite, CE marking is required if its imported regardless of when it was made, and any modifications necessary to bring it up to regulation. (if it was made and sold in the EEA to start with it would have a CE mark so anything made prior to 1998 in the EEA is technically exempt )

its also not the manufacturers responsibility, it is the importer / exporter / person putting into first use, yes the manufacturer has to comply with CE regulations but its not their responsibility to ensure it has a mark, after all if it was manufactured for outside the EU even if made in the EU the regulations don't necessarily apply so the manufacture does not have to follow them

You can self certify that it does comply with the CE regulations, if it does comply you have nothing to worry about, its when it doesn't comply and you CE mark it you will be in a world of trouble, the cost if you know what your doing (and your boat does comply) is a few hours work and a printer along with a nameplate, the cost to get someone to do the paperwork is variable, depends if the boat has a technical file, finally the other costs are if it dont comply it needs rectifying before a CE mark is applied again a "how long is a piece of string question"

i am qualified to CE mark & my background is machinery but the same principles apply in the marking process as each bit of equipment has specific BS EN ISO standards to comply to, from fork trucks to boats, machinery if anything is the most complicated.

but there are BS EN ISO standards for seacocks, gas valves, electrics, masts, you name it there's a standard to comply to.

fun fact for you, if you modify your boat technically it needs re-assessing for CE compliance but policing that would be a nightmare.
 
Last edited:
Cookie Jar said:
Yes, but according to what I have been reading, all boats need to have a CE mark if they are to be sold... even between private buyers. Owners of boats manufactured and put in operation in the EU prior to RCD regulations and therefore without CE marking, are free to keep them and sail them... just not sell them!
The worst part for me is that some countries require registration...which in turn can only be made if official technical documentation is provided!

What a nightmare!
Click to expand...

That is simply not true. If it were so then thousands of boats would have needed to be marked. Your only issue would be getting the boat registered in Portugal (and perhaps one or two other states in the EU who are anal about such things). Otherwise you are free to move anywhere in the world and sell to whoever you want to - certainly within the EU. You do not need to have a CE marked boat to visit Portugal, or other EU states provided the boat is registered elsewhere.

The boat is unlikely to meet the requirements of the RCD anyway without modification.
 
I've read swathes of RCD 2017 bumf before and after making post #9 and may have discovered where some of the confusion arises. Although (shamefully) it doesn't expressly say so, the new RCD seems to cover only vessels manufactured/placed on the market from the date of the new regulations (which is exactly what you'd expect). Any such vessels must, of course, be certified to the new Directive. This includes all existing products built after that date, not just new designs.

Further (from British Marine):
Vessels and components manufactured and placed on the market before 18 January 2017 will have been certified to RCD 1 (Directive 94/25/EC on recreational craft, as amended by Directive 2003/44/EC). The exact same product which is manufactured after January 18th 2017 must be re-assessed and re-certified to the new directive (Directive 2013/53/EU) before it is placed on the market.

“placing on the market” means the first making available of a product on the EU market"
(This direct from HM Gov's 'Statutory Instrument'. The same Instrument makes it clear elsewhere that this placing on the market is "in the course of a commercial activity".)
A 1982 Dehler would most certainly not qualify as first made available under the new regulations.

RCD 2017 does not apply to vessels already built and first placed on the market under previous RCD regulations, nor craft which were exempt under them.
 
Last edited:
Tranona said:
Your only issue would be getting the boat registered in Portugal (and perhaps one or two other states in the EU who are anal about such things). Otherwise you are free to move anywhere in the world and sell to whoever you want to - certainly within the EU.
Click to expand...

I really hope so...

my last 2 boats have been bought (and subsequently sold) without any CE marks and I have not had any problems nor questions asked by the buyers, BUT... definitely registering a boat in one of those countries proves to be utterly impossible (financially, of course) without one. And that was the reason behind my question in the first place.
Nevertheless (and what has made me become concerned about the legality of a sale) legislation seems to clearly cover and clearly state all and everything about importing/exporting/manufacturing/etc... except when it comes to a private person -as in "user", not a private importer- putting on the market a boat that is prior to 1998. It is so vague that there is not a specific article that I can point my finger to and say "Ah! this is it... I don't need one TO SELL it" ...at least with my limited understanding.

Saying that a boat from 1997 does not need one is different from saying that a boat from 1997 does not need one to be put on the market. Is these kind of grey that concerns me, simply because the legislation is so clear and detailed in every other article.


Oh well...
 
macd said:
I've read swathes of RCD 2017 bumf before and after making post #9 and may have discovered where some of the confusion arises. Although (shamefully) it doesn't expressly say so, the new RCD seems to cover only vessels manufactured/placed on the market from the date of the new regulations (which is exactly what you'd expect). Any such vessels must, of course, be certified to the new Directive. This includes all existing products built after that date, not just new designs.

Further (from British Marine):
Vessels and components manufactured and placed on the market before 18 January 2017 will have been certified to RCD 1 (Directive 94/25/EC on recreational craft, as amended by Directive 2003/44/EC). The exact same product which is manufactured after January 18th 2017 must be re-assessed and re-certified to the new directive (Directive 2013/53/EU) before it is placed on the market.

“placing on the market” means the first making available of a product on the EU market"
(This direct from HM Gov's 'Statutory Instrument'. The same Instrument makes it clear elsewhere that this placing on the market is "in the course of a commercial activity".)
A 1982 Dehler would most certainly not qualify as first made available under the new regulations.

RCD 2017 does not apply to vessels already built and first placed on the market under previous RCD regulations, nor craft which were exempt under them.
Click to expand...

Thank you for the "investigation" and explanation!
Unfortunately it leaves a lot unclear and although the legislator went into minor details in a lot of things, this particular situation, which in fact represent hundreds of thousands of boats, is left without a clear line.
 
Cookie Jar said:
Saying that a boat from 1997 does not need one is different from saying that a boat from 1997 does not need one to be put on the market. Is these kind of grey that concerns me, simply because the legislation is so clear and detailed in every other article.
Click to expand...

Cookie: you were obviously writing the above whilst I was amending the previous post. I hope I've satisfied you that a private sale of an elderly craft does not constitute 'placing on the market' so far as the regs are concerned.

If it helps (and I daresay it doesn't), Portugal has a long record of also placing illegal hurdles on the import of cars, frequently having been found in breach of EU regulations.

,
 
Cookie Jar said:
I really hope so...

my last 2 boats have been bought (and subsequently sold) without any CE marks and I have not had any problems nor questions asked by the buyers, BUT... definitely registering a boat in one of those countries proves to be utterly impossible (financially, of course) without one. And that was the reason behind my question in the first place.
Nevertheless (and what has made me become concerned about the legality of a sale) legislation seems to clearly cover and clearly state all and everything about importing/exporting/manufacturing/etc... except when it comes to a private person -as in "user", not a private importer- putting on the market a boat that is prior to 1998. It is so vague that there is not a specific article that I can point my finger to and say "Ah! this is it... I don't need one TO SELL it" ...at least with my limited understanding.

Saying that a boat from 1997 does not need one is different from saying that a boat from 1997 does not need one to be put on the market. Is these kind of grey that concerns me, simply because the legislation is so clear and detailed in every other article.


Oh well...
Click to expand...

There is no confusion - you are just reading in things that are not there. The directive and legislation only applies when goods are placed on the market after the qualifying date. There is therefore no need to positively state that goods already in the market do not have to comply.

It does indeed throw up anomalies such as non EEA built boats already in the EU on the date don't have to comply, but any coming into the market afterwards do. On the other hand boats built in the EEA prior to the date, but exported outside, can freely enter at any time (subject to duty and VAT of course).

So, it gets back to my earlier comments - the lack of certification is only an issue in states that use certification as a requirement for registration. Whereas CE marking is EU wide requirement, most other things to do with boats such as registration, safety equipment, licencing etc is not, so individual states can do as they please.
 
macd said:
Cookie: you were obviously writing the above whilst I was amending the previous post. I hope I've satisfied you that a private sale of an elderly craft does not constitute 'placing on the market' so far as the regs are concerned.

If it helps (and I daresay it doesn't), Portugal has a long record of also placing illegal hurdles on the import of cars, frequently having been found in breach of EU regulations.

,
Click to expand...

Absolutely... but they just pay the fines to the EU because the fines are soooo much cheaper than actually killing the illegal tax :ambivalence:

Thanks again for that... what should be clear on the legislation is that "putting on the market" should actually read "putting on the market for the first time"!

Interestingly, the only clear (official) mention I have found on this is from the Danish Maritime Authority's website. An FAQ about CE Marking:
https://www.dma.dk/SkoleFritidssejlads/Fritidsfartoejer/CEmaerkning/Sider/FAQ-om-CE-maerkning.aspx

Love this Forum!
Thanks again everyone!
 
Tranona said:
There is no confusion - you are just reading in things that are not there.
Click to expand...

Yep... probably right.
But being from one of those countries that treat boaters like they do... and living in another that does (almost) the same, I'm biased :o

Well, I'll be moving to Belgium in a few months... so let's see what I face there :confused:

Thanks Tranona.
 
Cookie Jar said:
Thanks again for that... what should be clear on the legislation is that "putting on the market" should actually read "putting on the market for the first time"!
Click to expand...

...like: “placing on the market” means the first making available of a product on the EU market"

As said before, that's straight from HMG's Statutory Instrument on RCD 2017.

Good luck and carefree sailing.
 
Cookie Jar said:
Yes, but according to what I have been reading, all boats need to have a CE mark if they are to be sold... even between private buyers. Owners of boats manufactured and put in operation in the EU prior to RCD regulations and therefore without CE marking, are free to keep them and sail them... just not sell them!
The worst part for me is that some countries require registration...which in turn can only be made if official technical documentation is provided!

What a nightmare!
Click to expand...
Thats not correct
If the boat was on in EU when RCD was established there is no need.
If the boat have been imported to EU post RCD it must be marked.
 
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