Rcd (recreational craft directive) brexit hot mess

[Avocet]

So what is the issue. We can export to the whole of the EU using one set of rules ( which having used for years are no problem to us).

Yes, that's true. Although you must remember that the regulatory framework is constantly evolving, so the idea that we've "used it for years and it's no problem" needs treating with care! (We'll also gloss-over the fact that we have lost our say in the content of any new EU regs...).

However, what we CAN'T do, is to sell in our own country with that same set of approvals! Currently, we have an interim situation where, in order to sell in volume in our own country, we have to first obtain an EU type approval and then use that with DfT, to apply for a "Provisional" GB National Type Approval (because 6 years after leaving, they haven't got round to drafting our own yet)! Sadly, we used to be able to get an EU type approval from our very own Vehicle Certification Agency - one of the biggest, and best-respected approval authorities in the EU). Unfortunately, having voted to stop them being an EU type approval authority, we now have to go to Sweden (or any EU27 country) for that.... So, basically, just an utterly pointless duplication of paperwork and application fees, and a huge increase in lead time. Once we get the "full" GB National Type Approval regs drafted, we'll have to see how much, and in which areas, they diverge from the EU ones, before we know how much (if any) extra testing we're going to need... (...to sell in our own county - did I mention that)?! Likewise, the format and layout of the documents, and certificates, so we can see what can be copied and pasted and what has to be drafted from scratch. Then, of course, there's the maintenance of those approvals (each time we change something or each time the regs change), and then there are the periodic audits (which will, of course, be one from the EU approval authority (Sweden in our case) and one from the GB authority). I've already taken on an extra graduate just due to the extra red tape from the provisional scheme...

One has to remember that carrying all this data meant hours of manual work. These days most of it can be produced by computer at the press of a key.

Ah yes... the "type approve me a car" button... . Just out of curiosity, do they have another button for when you want to extend the approval?

I do not see any boat builders likely to set up as a result of our leaving the EU though. We just do not have the market & it will soon become saturated leading to a slump in sales. Even if we did have easy access to EU markets a new builder would have to find a "niche" to get established & they are few & far between.

HOWEVER, we can now export to other countries using better trade tariffs etc. Good move I would have thought.

I need to be careful not to sidetrack this too much on to cars, but the EU regulatory framework for boats won't be too dissimilar. The problem is that if we agree a tariff reduction with another market that works to different rules, it doesn't help much. We have to re-engineer (and re-homologate) the car in order to comply with their rules. Depending on the extent of the differences, we'd have to be sure of selling quite a lot of them (or a huge tariff reduction) to get those costs back!

I hope that I am not drifting to "BREXIT" & in the wrong section- I think perhaps a moderator may interfere soon

I'm sure they'll let us know...

 

[Kurrawong_Kid]

We still do but not in the mass production market, we have a company only 20 miles away from us that is successfully competing, (Swallow Yachts) they are at present their production facilities), but it would be great to see a U.K. manufacturer entering the volume production market, we have the designers and the skills, but we never seem to successfully manage to marry the two with an enterprising industrialist.

We did, Westerly, Sadler, Moody etc. but the end of the low £ and the replacement by the high £ killed them off! Only very high end yachts and motor boats have been able to weather the storm and even they have had financial reconstructions of various types. All manufacturing, not just boats, faces an uphill struggle. No natural resources to speak of, high fuel and power costs, an island nation with increased transport costs and a financial system that does not support long term investment, but just wants a quick buck. An economy based on rising house prices caused by restricted planning consent is not only a Ponzi economy but it also kills off manufacturing capability because people concentrate on making money from capital gains from housing, the service industries that support housing rather than making things and government and civil servants who just dont understand the effect of the complexities of regulations they make because they have never worked in manufacturing.

 

[Avocet]

Some years ago a friend of mine home built an old gaffer, starting from a GRP hull.
He wanted it to comply with the RCD plus Lloyds etc, so he paid someone to come & certify it throughout the build.
I am sure he never paid anything like the sums being quoted.
I expect that as time goes by there will be those who become qualified in such issues ( bit like freight handling services) & the costs will be much reduced & become simpler. Designers will be clued up & figures will drop off the computer as needed. Inspections will just be routine. It will, of course take time.

No matter how cheap and easy they get, they're up against £0. That's how much the extra certification to sell into the EU as well as the UK used to cost us!

 

[Avocet]

The big issue may be things like engine emissions. Most of us have diesel engines which have been discontinued by their suppliers as no longer meet current RCD emissions regulations.
Replacing a 5 year old diesel with a new one to meet emissions regulations will never be cheap.

I'm still unsure as to how this could be applied (and policed) retrospectively! Avocet's engine is 30+ years old and well and truly obsolete now. At least emissions can be done by the engine manufacturer, independently, so he'd be selling a new emissions-certified engine if I were to buy a brand new replacement. But of course, I probably wouldn't be buying a brand new replacement!

 

[Avocet]

the regulating bodies could have just taken a leaf out of Norway's book who accept the CE mark and don't write their own standards, even Iceland who left the EU like the UK still retain CE within the EEA, but the UK cronies had to be different and write some new red tape nonsense thats going to put us back many years to the silly nuances of old dissimilar standards with no benefit to the consumer.

And that's the crux of it - be it for car or boats (or, I expect, a lot of other things, as time goes by). [Inappropriate quoted content removed]

 

[Daydream believer]

Yes, that's true. Although you must remember that the regulatory framework is constantly evolving, so the idea that we've "used it for years and it's no problem" needs treating with care! (We'll also gloss-over the fact that we have lost our say in the content of any new EU regs...).

Actually if all what you said was really so true then how come Rustler, Oyster, Sunseeker, et aliam are still trading since we left the EU. They seem to have solved the issue in the interim & the example of a car is a poor one considering the thousands of components. Stick to boats & I do not believe that it is anything as bad as you try to paint. I suggest that given 2-3 years & it will all settle down once industry learns how to work the systems, as will most of the issues we have with the EU.
I was very active in a trade body in my younger days & whenever something new was introduced it caused mayhem with companies panickingabout how they would deal with it. whether it was VAT, selective employment tax, the 714 certificates, or some other legislation. Given time and it all became a way of life & no one really worried much.
It will all right on the night

 

[Black Sheep]

Actually if all what you said was really so true then how come Rustler, Oyster, Sunseeker, et aliam are still trading since we left the EU.

Gosh. You do realise that the UK only left the single market in January this year?

 

[Daydream believer]

Gosh. You do realise that the UK only left the single market in January this year?

So they have not sold any boats for 10 months !!

 

[Black Sheep]

So they have not sold any boats for 10 months !!

I don't have access to their sales data.
But you seemed to be pointing to the fact that the companies were still trading post-Brexit as evidence that Brexit has had no impact on their business. Apart from the fact that "still trading" is a pretty low bar, I'm merely pointing out that it would be catastrophic indeed for them to have gone bankrupt in just 10 months.

 

[Poignard]

I don't have access to their sales data.
But you seemed to be pointing to the fact that the companies were still trading post-Brexit as evidence that Brexit has had no impact on their business. Apart from the fact that "still trading" is a pretty low bar, I'm merely pointing out that it would be catastrophic indeed for them to have gone bankrupt in just 10 months.

And they may have been delivering orders placed before Brexit.

 

[Daydream believer]

I don't have access to their sales data.
But you seemed to be pointing to the fact that the companies were still trading post-Brexit as evidence that Brexit has had no impact on their business. Apart from the fact that "still trading" is a pretty low bar, I'm merely pointing out that it would be catastrophic indeed for them to have gone bankrupt in just 10 months.

The fact is that they have got round it so far & orders placed before brexit will still have to comply at the time of export. Furthermore they would not have suddenly stopped taking orders.
You are just putting imaginary barriers up. These firms are not run by idiots. They will find solutions. That is what they have always done.

 

[Black Sheep]

You are just putting imaginary barriers up.

On the contrary - I voted not to put barriers up.

These firms are not run by idiots. They will find solutions. That is what they have always done.

I agree that the firms are not run by idiots.
And if there are solutions to be found, I'm sure many of them will find those solutions. They will do everything they reasonably can to save their businesses. Whether they all succeed, only time will tell. History is littered with British boatbuilders who haven't done so in the past.

 

[Avocet]

Actually if all what you said was really so true then how come Rustler, Oyster, Sunseeker, et aliam are still trading since we left the EU. They seem to have solved the issue in the interim & the example of a car is a poor one considering the thousands of components. Stick to boats & I do not believe that it is anything as bad as you try to paint. I suggest that given 2-3 years & it will all settle down once industry learns how to work the systems, as will most of the issues we have with the EU.

Of course "mitigation" measures will be put in place. It's what we're doing right now, in the car industry! But it might be worth you asking yourself some questions about why we even need to "mitigate" against the effects of something that was supposed to be "better"? This additional red tape puts us at a competitive disadvantage when selling UK-manufactured products into the EU against EU-based competitors. YEs, I expect we will "cope" and "survive" but that's not really setting the bar very high, is it. Was that your aspiration for British industry?

I was very active in a trade body in my younger days & whenever something new was introduced it caused mayhem with companies panickingabout how they would deal with it. whether it was VAT, selective employment tax, the 714 certificates, or some other legislation. Given time and it all became a way of life & no one really worried much.
It will all right on the night

Yes... we keep hearing that... mainly from people who don't have to actually do it though...

 

[Avocet]

The fact is that they have got round it so far & orders placed before brexit will still have to comply at the time of export. Furthermore they would not have suddenly stopped taking orders.
You are just putting imaginary barriers up. These firms are not run by idiots. They will find solutions. That is what they have always done.

Orders for new boats isn't the issue here. New boats would have had to comply anyway!

As I understand it, (OP, correct me if I'm wrong). This is something to do with importing second hand boats from the EU into the UK?
To be honest, I don't fully understand the problem. The current published version of the RCD appears to be 2013/53/EU, so nothing has changed on the RCD itself, since 2013. I'm therefore assuming the problem is with some new piece of UK legislation? Stork linked to the 2017 UK regulations, and it seems they have been amended recently, so the problem might be within the amendment. I'd have to find a copy to comment further.

However, I have just stumbled across this, whilst searching:

https://assets.publishing.service.g...to-recreational-craft-regulations-2017-tp.pdf

(See Section 8 on "Private importers"). It also seems to suggest that the CE mark will be sufficient for something "placed on the marked" before 31/12/21 (See Section 10), so there is still hope if the OP and the vendor can move quickly enough!

If the problem is one created by an amendment to some GB regulations, I would have imagined that British Marine and RYA would have been consulted / should have been aware of the public consultation, so I can't understand why it has not been challenged. However, I'm not going to "cast the first stone" as I know how difficult it can be to keep an eye on everything that's changing at once!

 

[st599]

If the problem is one created by an amendment to some GB regulations, I would have imagined that British Marine and RYA would have been consulted / should have been aware of the public consultation, so I can't understand why it has not been challenged. However, I'm not going to "cast the first stone" as I know how difficult it can be to keep an eye on everything that's changing at once!

They were, they did: https://www.rya.org.uk/news/rya-and...tial-new-costs-of-trading-second-hand-vessels

The main worry from the article though is "Howard Pridding, RYA Director of External Affairs, said: “This is yet another unanticipated and unwelcome aspect of Brexit"" - why did the RYA not anticipate it, I know we were discussing the effect on type approvals at work in early 2017.

 

[dunedin]

They were, they did: https://www.rya.org.uk/news/rya-and...tial-new-costs-of-trading-second-hand-vessels

The main worry from the article though is "Howard Pridding, RYA Director of External Affairs, said: “This is yet another unanticipated and unwelcome aspect of Brexit"" - why did the RYA not anticipate it, I know we were discussing the effect on type approvals at work in early 2017.

I suspect that when Mr Pridding referred to as “unanticipated” he meant that the politicians and promotors of the B initiative hadn’t thought about it, and voters had not been warned about it - which seems fairly accurate. Many did warn about the complexities and adverse consequences but were dismissed by some Project F- word.
We now need To deal with these adverse consequences.

 

[dunedin]

Actually if all what you said was really so true then how come Rustler, Oyster, Sunseeker, et aliam are still trading since we left the EU. They seem to have solved the issue in the interim & the example of a car is a poor one considering the thousands of components. Stick to boats & I do not believe that it is anything as bad as you try to paint. I suggest that given 2-3 years & it will all settle down once industry learns how to work the systems, as will most of the issues we have with the EU.
I was very active in a trade body in my younger days & whenever something new was introduced it caused mayhem with companies panickingabout how they would deal with it. whether it was VAT, selective employment tax, the 714 certificates, or some other legislation. Given time and it all became a way of life & no one really worried much.
It will all right on the night

Daydream, as others have said, the big issue being highlighted in this thread is the impact on buying and importing SECOND HAND boats due to them needing to be assessed against the CURRENT rules, not those of the date of original build (loss of “grandparent” exemptions) - leading to major costs such as replacing an otherwise good engine, for example.

With NEW boat industry, the need for extra certification for extra / different standards will certainly increase costs for UK boat builders - but provided the UK standards don’t divert materially from CE, this should be marginal for high priced boats of the type mentioned. Indeed they may get a boost from UK buyers choosing to buy expensive new boats to be delivered outside the UK - avoiding paying UK VAT. However, this will adversely impact UK boat service companies, as owners cannot then bring their boats to the UK for mooring, maintenance, refurb etc (and of course, less VAT paid by rich UK residents might not help our hospitals and schools).
For the new boat industry, the impact will be felt more at the other end of the scale - the low volume small boat builders. They won’t have the resources and turnover to cover the costs of researching and certification for multiple sets of rules. Therefore an occasional EU export boat may not be viable, resulting in lost business for these small and fragile enterprises.

 

[Daydream believer]

Yes... we keep hearing that... mainly from people who don't have to actually do it though...

Well referring to my post. I had to do it & I managed it quite well. On top of that , because of my position, I spent a lot of time speaking in industry on how etc; whilst MD of a reasonably sized business at the same time . If I was the same age & involved in industry now, I would be doing the same, I expect. I enjoyed the challenge actually. There will be others, there always is.

 

[Black Sheep]

Well referring to my post. I had to do it & I managed it quite well. On top of that , because of my position, I spent a lot of time speaking in industry on how etc; whilst MD of a reasonably sized business at the same time . If I was the same age & involved in industry now, I would be doing the same, I expect. I enjoyed the challenge actually. There will be others, there always is.

Here we go again. Spot the logic flaw:
1. Current circumstances mean change.
2. I've dealt with change in the past, and my company was OK.
3. Therefore current circumstances are fine. All companies will be OK.

 

[NormanS]

Here we go again. Spot the logic flaw:
1. Current circumstances mean change.
2. I've dealt with change in the past, and my company was OK.
3. Therefore current circumstances are fine. All companies will be OK.

Well, at least Ddb isn't being negative and defeatist, unlike some others.