Covid UK Prices

[jon and michie]

Boat kept in UK marina is more likely to be inspected on regular basis by its owner, if only to sit on it and to note stuff that needs doing.
Ensuring work is done by telephone can be a challenge when the boat is lying a day away by air.

Chum had a Targa 37 in Nice, wanted to have a hole drilled into the hull for an additional A/C unit.
Last time he was down, yard assured him that boat would be lifted both hole and valve would be done pronto. Senor .
Phone call a week later to tell them he would be flying down to arrange fitting of actual A/C unit , discovered that boat was still in water but that job would done before he arrived.
The skipper and muggins fly down that weekend expecting to have relaxing weekend eating/drinking and perhaps even boating, arrive to find the boat has not been touched.
All Saturday is spent making sure the boat is actually lifted with the promise that the valve will be fitted immediatly after lift and boat will be put back in water the same day.
Spend night on boat on the hard and fly home from a still holeless boat the following day.
The bogs of course were miles away from the yard and circa 2.00am this an inconvenience to say the least.
Total water action was a swim on nearbye beach while trying to avoid the jellyfish.

There was a Targa 43 a few years ago kept in Southampton I believe with basically the Propeller falling off and a jungle growing around it
@volvopaul will know of this vessel.
The marina where my last boat was kept we knew of an owner that had his VHF turned on for roughly 2 years and only visited the boat now and again never saw it lifted in over 4 years for antifoul / anode change out.

Ref your Chum in Nice - This could happen at any marina - doesnt he have any friend's / other boaters at the Marina that he could have asked if the work had been done or does the marina have a Webcam - This would have save him and you a lot of time and the expense of flights.

 

[jon and michie]

Well that would blow the whole thing out of the water!

However, I’d be grateful to be pointed to where the regulations state that a privately imported (from EU to UK) boat that is already CE marked needs to be certified as compliant with a later version of CE.

I can find the need for current CE compliance on a private import from EU to UK where a boat has never been CE marked - and that seems to be the thrust of the PBO article cited - but not where the boat has already been CE marked by the manufacturer when first sold under an earlier CE regime.

I’m not trying to be clever about this; I genuinely can’t find the requirement.

Slightly off topic but has relevance - Had a gas engineer come down to service the central hating boiler - told me I needed a new one as it doesn't meet current Regs.
I got rid of him quick as he started to measure up - I then contacted an engineer who had been in the game for years (wasn't available at the time to service the Boiler) and he said Regs change all the time and you'd be buying a boiler every couple of years - When my current boiler was installed it met the regulations at that time therefore will pass its test providing everything is in good order.
I then got another engineer out who went around it and passed it.

Right Back to the Topic

So a British built boat of a certain age cannot return back to the UK from the EU even though it has been built to the same standard in the same yard as the same model already in the UK?
So the same Boat in the UK doesn't meet the Standard either then but that's Allowed?

 

[st599]

Well that would blow the whole thing out of the water!

However, I’d be grateful to be pointed to where the regulations state that a privately imported (from EU to UK) boat that is already CE marked needs to be certified as compliant with a later version of CE.

I can find the need for current CE compliance on a private import from EU to UK where a boat has never been CE marked - and that seems to be the thrust of the PBO article cited - but not where the boat has already been CE marked by the manufacturer when first sold under an earlier CE regime.

I’m not trying to be clever about this; I genuinely can’t find the requirement.

From that article:

A product must comply with the legislation at the point it is first sold or put into service in the territory.

The UK Government is not recognising the EU Recreational Craft Directive (RCD) as an alternative act to the UK Recreational Craft Regulations. It is recognising European compliance as a means demonstrating compliance with the UK RCR. This subtle point is of importance later.
...
If the boat is CE-marked, one might think that this announcement means that the boat is considered compliant in the UK but remember point 1 above.
If the boat is coming to the UK today, it must comply with the regulations today.
...
There have been three versions of the Recreational Craft Directive (and Regulations) and if the Declaration of Conformity that accompanies the boat declares the boat complies with the current RCD (2013/53/EU), I cannot see why the UK enforcement authorities (Trading Standards) would take issue with the ‘freshness’ of compliance.
Note that this version of the RCD became mandatory on 18 January 2017, so if the boat is younger than this, it could only have complied with the current Directive.

The article does state that there's only one company in the UK that can test older boats (the authors) and that he doesn't think it will be well policed, but the article clearly states that compliance with RCD(2013/53/EU) is what is needed to meet RCR, not the previous versions.

 

[st599]

So a British built boat of a certain age cannot return back to the UK from the EU even though it has been built to the same standard in the same yard as the same model already in the UK?
So the same Boat in the UK doesn't meet the Standard either then but that's Allowed?

If the boat in the EU doesn't meet the latest EU RCD, then no, it will need a UK RCR Post construction assessment
The boat in the UK isn't being imported or sold as new, so there's no legal event to trigger the requirement.

This is one of the consequences of the UK's wish to diverge standards. It's only fairly recently they allowed the latest EU RCD to be used as evidence of compliance with RCR. The initial rules meant that every single second hand boat imported to the UK would require a PCA test (despite the UK only having one small test facility).

 

[jon and michie]

deleted

 

[st599]

Ok so without me sounding too stupid - what would meet this standard as in boat terms - at the end of the day its a plastic tub with an engine and its accessories.
why can I import a Classic American car with a V8 or V6 into the UK without problems ??

Looking at the overview there seems to be requirements for buoyancy, flotation, stability, handling characteristics, electrical and LPG installations, emissions and handling of waste, requirements for full manuals, drawings and calculations for all systems.

Classic cars have different standards required on import.

 

[jon and michie]

If the boat in the EU doesn't meet the latest EU RCD, then no, it will need a UK RCR Post construction assessment
The boat in the UK isn't being imported or sold as new, so there's no legal event to trigger the requirement.

This is one of the consequences of the UK's wish to diverge standards. It's only fairly recently they allowed the latest EU RCD to be used as evidence of compliance with RCR. The initial rules meant that every single second hand boat imported to the UK would require a PCA test (despite the UK only having one small test facility).

So a possible way around it it would be if the said boat was originally UK Tax paid - and the current owner - Completed the sale in UK ?

 

[jon and michie]

Looking at the overview there seems to be requirements for buoyancy, flotation, stability, handling characteristics, electrical and LPG installations, emissions and handling of waste, requirements for full manuals, drawings and calculations for all systems.

Classic cars have different standards required on import.

So my question there would be its a British built boat from the same mould so floatation, Stability and Handling characteristics are the same - Electrical and LPG - Yes I get that but wise to get them tested especially LPG on any boat - Handling of waste - well its likely to be the same as one in the UK.
Drawings - Come with the Operators manual.
p/s I am not trying to be a smart arse just questioning

 

[Tranona]

So a possible way around it it would be if the said boat was originally UK Tax paid - and the current owner - Completed the sale in UK ?

If the boat in Mallorca originated in the UK and was taken out by the current owner then he can bring it back using returned goods relief and sell it to you without paying VAT or requiring recertification. If it changed hands outside the UK it is treated as if it is a EU boat a nd will need recertification and pay VAT. Sounds barmy but as already noted that is a consequence of Brexit.

Boats like this are cheaper in Mallorca because they are less desirable than other brands to buyers in Mallorca. Desirable maybe here but unobtainable for use in the UK by a UK resident. Nothing new about this where you have closed markets with their own rules. No different from 25 years ago when the RCD came in and shut down virtually all the previous trade in used boats from the US.

 

[benjenbav]

From that article:



The article does state that there's only one company in the UK that can test older boats (the authors) and that he doesn't think it will be well policed, but the article clearly states that compliance with RCD(2013/53/EU) is what is needed to meet RCR, not the previous versions.

Thanks. The important wording seems to be:

"A product must comply with the legislation at the point it is first sold or put into service in the territory"

Does 'territory' in this context mean the EU territory in which the product was first sold or put into service?

Or, does the whole compliance process refresh if it is then sold in another territory?

The former interpretation would seem to be more likely because manufacturers can't be expected to certify items that have been outside their control for a period of time.

HMRC guidance includes the following (my emphasis):

"8. Obligations of private importers​

A private importer is any natural or legal person (e.g. a company) established in the UK who imports in the course of a non-commercial activity a product from a country outside the UK with the intention of putting it into service for their own use.

The obligations of private importers include:

• If a private importer imports a product that has not previously been placed on the GB market, where the manufacturer has not carried out the relevant conformity assessment procedure, the private importer will have to carry out a post construction assessment to demonstrate conformity with the Regulations,..."

And looking at the website of the organisation from which the author of the PBO article hails, there is the following flowchart:

 

[st599]

So a possible way around it it would be if the said boat was originally UK Tax paid - and the current owner - Completed the sale in UK ?

Only if the original exporter re-imports it before sale and uses it here for whatever the time requirement is. Otherwise it's a new import.

So my question there would be its a British built boat from the same mould so floatation, Stability and Handling characteristics are the same - Electrical and LPG - Yes I get that but wise to get them tested especially LPG on any boat - Handling of waste - well its likely to be the same as one in the UK.
Drawings - Come with the Operators manual.
p/s I am not trying to be a smart arse just questioning

Doesn't matter if it's an exact replica of one in the UK. The move from the EU standards territory to the UK standards territory requires proof it matches the current UK standard. The fact it was built in the UK to a previous EU RCD standard is completely irrelevant. That is UK law (it didn't need to be, but the current government decided it would implement it this way as a non-tariff barrier).

They did a huge U-turn to allow an EU RCD v3 certificate as proof of RCR, but that doesn't allow previous RCD versions to be used.

Thanks. The important wording seems to be:

"A product must comply with the legislation at the point it is first sold or put into service in the territory"

Does 'territory' in this context mean the EU territory in which the product was first sold or put into service?

Or, does the whole compliance process refresh if it is then sold in another territory?

The former interpretation would seem to be more likely because manufacturers can't be expected to certify items that have been outside their control for a period of time.

HMRC guidance includes the following (my emphasis):

"8. Obligations of private importers​

A private importer is any natural or legal person (e.g. a company) established in the UK who imports in the course of a non-commercial activity a product from a country outside the UK with the intention of putting it into service for their own use.

The obligations of private importers include:

• If a private importer imports a product that has not previously been placed on the GB market, where the manufacturer has not carried out the relevant conformity assessment procedure, the private importer will have to carry out a post construction assessment to demonstrate conformity with the Regulations,..."

The EU is one standards territory, the UK is another.

Your emphasis matches what was said in the article. The relevant confrmity assessment is against the new version of the RCD. Previous assessments are not relevant.

 

[jon and michie]

They did a huge U-turn to allow an EU RCD v3 certificate as proof of RCR, but that doesn't allow previous RCD versions to be used.

So just for arguments sake - there is only 1 place in the UK to inspect the Vessel - if I went down the route of getting a boat from Europe and got it inspected with the EU RCD v3 cert then would then that be allowed as it meets the criteria ?

 

[st599]

So just for arguments sake - there is only 1 place in the UK to inspect the Vessel - if I went down the route of getting a boat from Europe and got it inspected with the EU RCD v3 cert then would then that be allowed as it meets the criteria ?

It would, if it's possible. The PBO article seems to state that you can only get the assessment done in the territory in which you live.

 

[Tranona]

So just for arguments sake - there is only 1 place in the UK to inspect the Vessel - if I went down the route of getting a boat from Europe and got it inspected with the EU RCD v3 cert then would then that be allowed as it meets the criteria ?

That is a moot point in cases like the boat you are looking at because it would not meet the latest standards particularly with regard to the engines and quite possibly on basic design criteria such as stability where the requirements have changed around the boundaries between categories.

 

[jon and michie]

Well there is another way around the Targa 43 UK Prices coming back to reality - Just keep waiting.

 

[benjenbav]

They did a huge U-turn to allow an EU RCD v3 certificate as proof of RCR, but that doesn't allow previous RCD versions to be used.


The EU is one standards territory, the UK is another.

Your emphasis matches what was said in the article. The relevant confrmity assessment is against the new version of the RCD. Previous assessments are not relevant.

Thanks. Do you know where it is set out in the legislation (or perhaps in court cases since) that the relevant conformity assessment is against the current RCD?

I genuinely don’t know and am not trying to argue one way or another. But, if that’s right it’s pretty monstrous and means that for most purposes UK buyers shouldn’t waste time looking at importing any 20 y/o boat.

 

[st599]

Thanks. Do you know where it is set out in the legislation (or perhaps in court cases since) that the relevant conformity assessment is against the current RCD?

I genuinely don’t know and am not trying to argue one way or another. But, if that’s right it’s pretty monstrous and means that for most purposes UK buyers shouldn’t waste time looking at importing any 20 y/o boat.

The relevant conformity assessment for the UK is the UKCA RCR (which happens to be the same as the EU RCD version 3 but with new covers). Recreational Craft Regulations 2017: Great Britain

Because it is the same (at the moment, it may not be in future), the UK Government after pressure from British Marine, RYA, CA and others reluctantly accepted current CE marking (against RCD 3) as compliance with UKCA RCR.

 

[benjenbav]

The relevant conformity assessment for the UK is the UKCA RCR (which happens to be the same as the EU RCD version 3 but with new covers). Recreational Craft Regulations 2017: Great Britain

Because it is the same (at the moment, it may not be in future), the UK Government after pressure from British Marine, RYA, CA and others reluctantly accepted current CE marking (against RCD 3) as compliance with UKCA RCR.

Thank you. I’m sorry to have put you to the trouble of proving something that you clearly know very well but it does seem a really important point.

 

[oldgit]

Have all my Thames Forum posts uploaded and may be gone for bit.



The inmates did take over the asylum but things might be about to change and the grown ups will again finally take charge ?

 

[Parabolica]

With a 25 year old boat no 2 craft are ever the same. In very general terms I would say the Med boat is likely to be in a worse state due to the harsh environment and cost / limited access to decent maintenance.

I would argue that the availability of high quality maintenance on the island of Mallorca is for the most, as good as any you’ll find the world over. On the downside, you do pay for it !