New Member question regarding imported engines and CE Marking

[Nykona]

Good morning all,
Not even sure this is the right place ot ask but I work for a small european company who has river boats. Currently my employer is looking to purchase generators and engines for a new craft (not personal use) from outside the EEA.

It is my understanding so far that those engines and generators will need to be CE certified and marked as such, complete with emissions ino, on the engine plates as per either Machine Directive or RoHS.

Does anyone have any experience of CE marking when it comes to engines/gensets/etc. imported form outside the EEA for commercial use?


I have so far advised against purchasing said equipment whilst I try and dig a little deeper on what is required. Normally CE is only required when "bringing a product to market" but that is also defined as "putting a product into service within the community". Since these would be used on passenger carrying commercial boats in sheltered waters I would like to be as belts and braces abotu this as possible.

Thanks in advance for any advice!

 

[Portofino]

The joy of EU membership .
You gonna need CE marked components. Ask the supplier .If they can’t supply goods CE marked / certified then it’s a none starter for you in the EU .

 

[Rappey]

The joy of EU membership .

You can buy five new 4 cylinder 40hp marine diesels from asia for the cost of a similar eu one. But we are not allowed.
We are not allowed to buy 2 strokes...
A lot of items for eu sale seems a lot more expensive than the rest of the world

 

[Tranona]

Good morning all,
Not even sure this is the right place ot ask but I work for a small european company who has river boats. Currently my employer is looking to purchase generators and engines for a new craft (not personal use) from outside the EEA.

It is my understanding so far that those engines and generators will need to be CE certified and marked as such, complete with emissions ino, on the engine plates as per either Machine Directive or RoHS.

Does anyone have any experience of CE marking when it comes to engines/gensets/etc. imported form outside the EEA for commercial use?


I have so far advised against purchasing said equipment whilst I try and dig a little deeper on what is required. Normally CE is only required when "bringing a product to market" but that is also defined as "putting a product into service within the community". Since these would be used on passenger carrying commercial boats in sheltered waters I would like to be as belts and braces abotu this as possible.

Thanks in advance for any advice!

You are right. you cannot import engines for any type of use into the EU/EEA (or even the UK) without meeting the requirements for EU emissions and being CE marked. Almost certainly the engines you are looking at do not meet EU specs otherwise the makers would get them certified and sell them here. Reputable Asian manufacturers such as Kubota, Mitsubishi, Perkins etc do make to EU spec. There is no point looking for a third party to certify the engines if they do not meet the requirements.

 

[Nykona]

Thank you all for the replies. I thought this was the case and have presented this and the possible risks of doing so but I am now being asked "WHY" and asked in a second language to point exactly where it tells me that engines/gens/gearboxes need this CE marking and apart from just pointing at the Machine Directive, which is vague about what it defines as a machine, I cannot say that a 600hp diesel engine form china just does not cut it. Similarly with the 150kw genny.

I am trying to not rock the boat too much at the company (pun not intended) but everything I have researched over the last week to try and bring everythign into compliance ha sbeen met with "Its never been a problem before" and "Where doe sit say the engine/genny needs CE marked".

 

[westernman]

Thank you all for the replies. I thought this was the case and have presented this and the possible risks of doing so but I am now being asked "WHY" and asked in a second language to point exactly where it tells me that engines/gens/gearboxes need this CE marking and apart from just pointing at the Machine Directive, which is vague about what it defines as a machine, I cannot say that a 600hp diesel engine form china just does not cut it. Similarly with the 150kw genny.

I am trying to not rock the boat too much at the company (pun not intended) but everything I have researched over the last week to try and bring everythign into compliance ha sbeen met with "Its never been a problem before" and "Where doe sit say the engine/genny needs CE marked".

RCD II/2013. Emissions requirements.
DocsRoom - European Commission
Page 111 and onwards.

I don't think it needs to be CE marked, but it needs to be certified to satisfy the requirements of the tests which are specified to determine whether it meets the emissions standards or not. If it does meet those standards it will almost certainly be CE marked.

If it is not CE marked, it almost certainly means it does not meet those standards, or at least has not been certified by a recognised body to meet the required standards.

 

[Seastoke]

Could you not register the boats outside eu.

 

[Nykona]

RCD II/2013. Emissions requirements.
DocsRoom - European Commission
Page 111 and onwards.

I don't think it needs to be CE marked, but it needs to be certified to satisfy the requirements of the tests which are specified to determine whether it meets the emissions standards or not. If it does meet those standards it will almost certainly be CE marked.

If it is not CE marked, it almost certainly means it does not meet those standards, or at least has not been certified by a recognised body to meet the required standards.

I believe the RCD only covers recreational craft below 24m in length and with a passenger capacity of around 24 passengers. The ship it is being installed on is considerably larger with a capacity of around 200.

 

[westernman]

Could you not register the boats outside eu.

Does not change anything as the boats would be "put into service" in the EU which requires conformity. There is a precise definition of what "put into service" means in the document I linked to.

 

[Alicatt]

Could you not register the boats outside eu.

Not if your company is a legal entity in the country you are operating in, same goes for a citizen of the said country.

 

[westernman]

I believe the RCD only covers recreational craft below 24m in length and with a passenger capacity of around 24 passengers. The ship it is being installed on is considerably larger with a capacity of around 200.

Then you are even more screwed.

 

[westernman]

Then you are even more screwed.

You might want to start looking here:-

Inland Waterways Transport Sector Stage V FAQ​

But this stuff is way beyond my pay grade.

 

[Nykona]

Could you not register the boats outside eu.

unfortunately no, they would be "put into service" within the EU and therefore fall under EU directives and guidelines.

Then you are even more screwed.

Yeah I am certainly trying to present this to the employers that everything needs multiple certification like IMO and such but that the equipment will certainly require CE certification also I just cannot find a definitive reference and they seem to be reluctant to just ask a solicitor.

I am also trying to put across that importing to the EU from china comes with risks because even IF the item had CE certification from the manufacturer you as the importer become the defacto "Manufacturer" in EU law. Meaning that if the documents are false, if the manufacturer changed components after recieving CE (to reduce production costs) or the details on the documents are not complete or incorrect then you as the importer are entirely liable.

As a business I understand it can have some hefty reprecussions. Such as things as low as insurance being invalid, ships taken out of service until a rather pricey certification is obtained all the way to the director of the company facing a large fine and actual jail time.

 

[Nykona]

You can buy five new 4 cylinder 40hp asian marine diesels for the cost of a similar eu one. But we are not allowed.
We are not allowed to buy 2 strokes...
A lot of items for eu sale seems a lot more expensive than the rest of the world

Exactly this, the same engine imported form China is around 20k. If we bought from an EU supplier we would be looking at 70k. Quite the difference but whenever I see something too good to be true I go digging and Id ont think Im too popular at the moment for pointing all this out.

 

[Rappey]

My engine is old. I priced up rebuilding mine and enquired how much just buying a already rebuilt only to discover they are not allowed to sell me another rebuilt engine as that is classed as adding a polluting engine but i can submit my old engine for a rebuild..
The price we pay to have a healthy environment?

 

[john_morris_uk]

You can buy five new 4 cylinder 40hp marine diesels from asia for the cost of a similar eu one. But we are not allowed.
We are not allowed to buy 2 strokes...
A lot of items for eu sale seems a lot more expensive than the rest of the world

I was led to believe that there are exceptions to the ‘no two stroke’ rule if it’s for commercial purposes.

 

[westernman]

I was led to believe that there are exceptions to the ‘no two stroke’ rule if it’s for commercial purposes.

I don't think there is any limitation on two strokes.

There is a limitation on emissions and simple two strokes with oil mixed into the petrol are not even close to meeting the emissions.
You can make clean two stroke engines with clean emissions - but they are complex beasts.

There are a few compliant two stroke engines, but not many.

For instance:-

Evinrude, the 2-stroke outboards meet the new European directive

 

[john_morris_uk]

I don't think there is any limitation on two strokes.

There is a limitation on emissions and simple two strokes with oil mixed into the petrol are not even close to meeting the emissions.
You can make clean two stroke engines with clean emissions - but they are complex beasts.

There are a few compliant two stroke engines, but not many.

For instance:-

Evinrude, the 2-stroke outboards meet the new European directive

However it appears my suggestion is correct.

Advice & Buy Best Price New COMMERCIAL USE 2 STROKES Yamaha Mercury Mariner

(We bought our Tohatsu 9.8 from the Channel Islands while we were en route for warm waters.)

 

[Nykona]

Many thanks Westernman diggin into that link and the regulations it covered cam up with this regarding EU Certification for engines and more specifically the certificate of conformity.

 

[Rappey]

There are a few compliant two stroke engines, but not many.

I changed from a 90hp mariner 2t to a evinrude etec 90 (direct injection 2t) .wow. the extra power from the evinrude was remarkable.
A lot of new enduro bikes around 300cc are now fuel injected 2t giving over 50 hp.