Changes in the RCD

[kingfisher]

http://europa.eu.int/eur-lex/en/oj/2002/ce17020020716en.html

page 1-22

NEW (and improved ???)
1) Emission standards for engines
2) PWC's now fall under the directive
3) Change of the categories
4) Changes in the conformity assessment modules
Others.

Sorry, haven't had time yet to go through the document.


Obi-Wan
http://sirocco31.tripod.com

 

[airbubble]

correct, and very attentive ! However, changes in the RCD or CE as we call it are of no importance and should not worry the consumer. We're living with them for 4 yrs now and its only us (surveyors) who have to check/keep up to date with them and manufacturers. The customers get a boat thet complies and don't have to check or worry about it. The competition between yards/boatbuilders sorts out that they all stick to the rules, and all yards have taken on offices like mine to check whether their products comply; it's their ass (read money)that's on the line ! If someone gets into trouble and finds that the boat did not comply, it's major cash in the bank !
We've had hardly any complaints/miscompliances from yards in these 4 years apart from some not ready in the beginning. We on the continent absolutely do not understand the worries of the public re RCD compliance in the UK. All boats you can buy comply, and afterwards there's no re-testing or keeping tu rules; once it's yours its yours, you can change what you want. The only time a member of the public has to be aware of RCD compliance is when he builts his own boat AND wants to sell it in the first 5 years. After that, again no worries.
K.R.

 

[graham]

Re the 5 year rule for homebuilt yachts ,when does the 5 year period start.Is it from the start of the project ,the launching day,or do you have to inform someone to get exemption from the RCD requirement?

 

[Strathglass]

The 5 years starts from when the craft is first launched. There is also a requirement to keep on board, documentary evidence that VAT has been paid on aprox ten of the major items used in the construction of the craft although the rules on the vat requirement changed a year ago with the demise of the Dover yacht VAT team and they may well change again.
What you must do is to ask the Customs and Excise Stand at the LBS what the current requirement is just before you launch the craft then you may have a faint hope of complying.
I have followed three different directives during the construction of a home built yacht only to find that the goalposts have moved each year for the last three years. I now find that the volume of paperwork I will currently have to carry on board to justify VAT payments is unreal. I will not only have to carry enough paperwork to satisfy any UK VAT inspector but also the VAT people on ANY EEC country I chose to visit. It is now impossible to obtain a statement which states that VAT is deemed to have been paid during the construction of a home made craft from anywhere within the UK. Thus any time one is challanged you must carry enough proof on board to satisfy anyone within the EEC.
That is until the craft has been launched for over five years (Under present rules)
I hope I have not boared you with my speal but, EVERY year for the last three years I have found a different set of rules apply to the VAT problem on home made boats when I asked at the Customs and Excise stand at the LBS.
I wonder what Jan 2003 will bring?
Iain Simpson

 

[kingfisher]

Not only the five year wait for home-built boats: I'm thinking of importing a boat from the US.

I was going to classify it as a class D, even though it's an ocean-going vessel, and do a total conformity assessment according to module A (self-certification). Apparently that will be no longer possible in the future: even class D boats need module Aa. Ergo: notified body envolved. And they will not accept the fake classification.

Obi-Wan
http://sirocco31.tripod.com

 

[airbubble]

if it is a series production boat, chances are 90% it is CE compliant anyway, as US rules were more stringent for years already, apart from a few little snags.
Only a self built boat would have the disadvantage that IF YOU want to put it ON THE market INSIDE the EC it has to comply, otherwise if you just want to use it and by it yourself (I mean the vendor does not have to import it into the EC and sell it) it has NO IMPLICATIONS ! Go on, use it !
That's also why we on the continent do not understand all your fears and fuss about the RCD. It is a trade-protecting, self regulatory law. Only if you start trading in a non compliant boat, you run the risk a competitor, or fellow boat builder, who does fully comply (rare, as it is a self regulatory law.... think abou this.) complains to the authorities about you.
You can have a notified body do only the stability thing and guarantee the rest of the rules yourself; then it;s your ass on the line, but remember, ONLY IF YOU START TRADING ACTIVELY with the model.
I see no trouble in the recent changes for you.( I have indeed read most of them today)

 

[Guest]

Sorry to be pedantic but the word "launched" could be misleading. Strictly, the vessel is "complete" when it has reached the stage where it can be used properly for its designed purpose, i.e. if a cruising boat it should have beds, cooker, loo etc. installed and working etc. This definition could infer that a boat can be complete although still sitting ashore, and also that even though a boat has ben launched it is still incomplete if the fitting out remains to be carried out. It is very important, if proposing to use the five year rule, to retain proof of the completion date: a surveyor's certificate would be the obvious way.

 

[Strathglass]

Yes Balliol
I supose I used the words 'first launched' to imply completion as I am refusing to launch the yacht I have been building for several years until it is completed-otherwise I will never finish it.
I supose this nicely opens up a grey area where boats can be purchased in sail away condition, but not completed.
But when is a boat ever fully completed?

The five year rule does not present any real problems.
The ability to carry on board sufficent documentation to prove on demand that VAT has been paid on the materials used to construct a home made boat is much more of a problem.
This is caused by the fact that when I and probably many like myself, started the construction there was no requirement to prove the VAT status on the materials.
As I posted earlier HM C&E seem to post a new set of guidelines anually at about the same time as the LBS.

It is all to do with them having to survive within the restraints of the financial package they have been allocated and their service reduces as cuts are made to save money.

Iain