ENVIRONMENTAL COMPLIANCE - EIAPP CERTIFICATION

[Crazyboatingfox]

My boat was built in 2006. It has two diesel engines of 400+hp. I understand it requires EIAPP certificates but we don’t have any in the comprehensive file we got with the boat. Builders were advised engines had to be compliant from 2000 and ours are. However, the requirement for the certificates seems to have come in in 2008 and applied retrospectively (backdated) to 2000. My guess is that there are a lot of compliant engines fitted to boats between 2000 and 2008 that don’t have the EIAPP certificates. My interpretation is that makes them illegal?

I have two questions and hope someone can help:

1. Are we technically illegal having no EIAPP certificates?
2. Are many people in the same situation?
3. Has anyone got experience of how to secure certificates retrospectively from the engine manufacturers?

Any help/advice gratefully received.

 

[Mr Googler]

Welcome to the forum. What engine make/model are we talking?

 

[Crazyboatingfox]

Good Morning,

Thanks for getting in touch. It was a generic question really as lots of people must be affected but our engines are CAT3126.

The generic stuff on the internet is all over the place from ‘ignore it’ to ‘you will go to jail if you don’t have the certificates’. MGNs don’t really help. There seems to be a big gap from 2000 to 2008 where manufacturers were supplying compliant engines but not issuing EIAPP certificates - because they were not required to. Then in 2008 came the legislation backdating the requirement for certificates to 2000!

On a personal level I’ve written to Cat and they are looking into it but the whole thing seems to be a mess and the clear guidance doesn’t seem to be there.

 

[Tranona]

Where are you located? AFAIK EIAPP only applies to commercial ships of 400GRT+ so unlikely to affect any boat with CAT 3126 engines. It does not apply to small commercial or Pleasure craft which are covered by either EU or US regulations which are not retrospective unless the boat is imported when it must comply with the current legislation.
assets.publishing.service.gov.uk/media/5a7ce41c40f0b65b3de0bc75/msn1819.pdf

 

[Crazyboatingfox]

Where are you located? AFAIK EIAPP only applies to commercial ships of 400GRT+ so unlikely to affect any boat with CAT 3126 engines. It does not apply to small commercial or Pleasure craft which are covered by either EU or US regulations which are not retrospective unless the boat is imported when it must comply with the current legislation.
assets.publishing.service.gov.uk/media/5a7ce41c40f0b65b3de0bc75/msn1819.pdf

Thank you for your response. I’ve read MSN1819 (and the others) but am still a bit confused. We are UK based but may sail into EU waters. I have to say my reading is that EIAPP is not restricted to vessels over 400GST but I hope I am wrong.

 

[dunedin]

Thank you for your response. I’ve read MSN1819 (and the others) but am still a bit confused. We are UK based but may sail into EU waters. I have to say my reading is that EIAPP is not restricted to vessels over 400GST but I hope I am wrong.

I haven’t read beyond page 3 so may have missed a lot, but on this page in the definitions it says
Relevant ship means (1) a UK platform or (ii) a ship, other than a platform, of 400 GT or above.

So as ever, looks like Tranona’s comment was correct

 

[Crazyboatingfox]

I haven’t read beyond page 3 so may have missed a lot, but on this page in the definitions it says
Relevant ship means (1) a UK platform or (ii) a ship, other than a platform, of 400 GT or above.

So as ever, looks like Tranona’s comment was correct

Thanks very much.

 

[st599]

Where are you located? AFAIK EIAPP only applies to commercial ships of 400GRT+ so unlikely to affect any boat with CAT 3126 engines. It does not apply to small commercial or Pleasure craft which are covered by either EU or US regulations which are not retrospective unless the boat is imported when it must comply with the current legislation.
assets.publishing.service.gov.uk/media/5a7ce41c40f0b65b3de0bc75/msn1819.pdf

There's some confusion over this in the new Sport and Pleasure vessel code. It doesn't have the 400 GRT limit (it says All vessels), but then seems to have a clause later on removing the requirements if the boat was designed solely for recreation.

 

[Tranona]

There's some confusion over this in the new Sport and Pleasure vessel code. It doesn't have the 400 GRT limit (it says All vessels), but then seems to have a clause later on removing the requirements if the boat was designed solely for recreation.

Presumably that is because recreational craft are covered by the RCD which has its own emission standards for engines.