Up to £5000 fees to sell your boat in the EU

[dk]

According to the MIN today:
Following the release of the UK – EU Trade and Cooperation Agreement, British Marine and the Royal Yachting Association (RYA) have been working to understand the impact of various aspects of the agreement on both the marine industry and recreational boat owners.
It’s not good news. ‘Post construction assessments’ will be needed to sell pre-owned CE marked recreational craft to the EU, and vice versa. The assessments, say a joint statement, are going to cost owners between £500-5000 (dependent on the vessel).
As Howard Pridding, RYA director of external affairs, says: “This is yet another unanticipated and unwelcome aspect of Brexit which could affect many owners financially through no fault of their own. We are working in partnership with industry to better understand and mitigate the situation and potential cost burden.”
British Marine and the RYA say the new information comes from the EU Commission and the UK Department for Business, Energy and Industrial Strategy (BEIS). It focuses on the trade of pre-owned CE marked recreational craft between the UK and EU following the UK’s exit from the European Union.
Both the UK and EU have confirmed that any vessel being traded second-hand between the UK and EU will be required to meet the obligations set out in either the Recreational Craft Directive (RCD) in the EU, or the Recreational Craft Regulations (RCR) in the UK, when placed on either market after the 1 January 2021.
Therefore, this means that a pre-owned vessel being imported from the EU to be placed on the UK market will, after 1 January 2022, be required to obtain a new UK Conformity Assessed (UKCA) mark in line with the requirements of the RCR. In order to obtain a UKCA mark, a boat will require a post construction assessment and third-party verification.
Similar rules will apply when selling vessels into the EU. Pre-owned CE marked vessels which were in the UK at the time of departure, 11pm on the 31 December 2020, when exported to the EU will be required to undergo a recertification of the CE mark when being placed on the EU market. This means a boat will require a post construction assessment in line with the RCD and third-party verification.
Boat brokerages, distributors, boat owners and buyers may well be heavily affected by this post-Brexit position, as the responsibility will fall upon them to ensure a vessel meets the applicable requirements before buying and selling second-hand boats between the UK and EU. Estimated costs of post construction assessments and verification are between £500-5000 dependent on the vessel.
British Marine and the RYA are currently liaising with the European Boating Industry association in order to raise concerns with this position in Europe whilst also directly engaging with BEIS in the UK.
“As a consequence of Brexit, this is a complex and potentially difficult situation,” says Lesley Robinson, CEO of British Marine. “Faced with the process of individual boat re-certification, boat builders, brokers and consumers will be impacted in terms of both time and cost when selling and buying second-hand boats cross borders. At this stage in time, British Marine is working hard to represent affected members and seek clarification of the exact ramifications of these regulations.”

 

[Graham376]

Much will depend on whether boat being sold will be keeping it's flag or being registered in new country. If a UK boat based in Europe is being sold to UK buyer I doubt there will be any problems. I know of a couple of sales in progress at the moment, one changing to local registration so will be interesting to see what happens.

 

[RupertW]

Much will depend on whether boat being sold will be keeping it's flag or being registered in new country. If a UK boat based in Europe is being sold to UK buyer I doubt there will be any problems. I know of a couple of sales in progress at the moment, one changing to local registration so will be interesting to see what happens.

The flag and the registry cant be relevant. The act of selling in one country to base in another will either have to be an import and therefore pay out for RCR to RCD, or the owner (and only if UK resident) could just visit EU for 18 months at a time. But sell to and EU resident who wants to keep in the EU then there is no choice but to pay up and say thanks Brexit.

 

[Keith 66]

Surely a boat that was built to the RCD & CE marked as such should not be penalised in this way, I cannot for the life of me understand why this needs to happen. The RCD was always a complete waste of time, it never made boats safer & it was pure beaurocracy for beauocracy's sake.

 

[westhinder]

Am I right in thinking that would also apply to a boat built in the U.K. under RCD and any local regulations that might be applicable, which was originally sold to continental Europe and now sold second hand to a U.K. buyer?

 

[RupertW]

Surely a boat that was built to the RCD & CE marked as such should not be penalised in this way, I cannot for the life of me understand why this needs to happen. The RCD was always a complete waste of time, it never made boats safer & it was pure beaurocracy for beauocracy's sake.

Yes, we chose to leave the RCD and replace it with one of our own with no commitment to stick to EU standards. So inevitably we are being treated as if our boats come from a third country. Our choice and if there is a small downside it needs to be weighted against the upsides.

 

[Deleted member 36384]

Anyone outside the EU who imported a new or old boat had to comply with the RCD, with some exceptions. It stops any old crap being brought into the EU. We now have the same standard which will apply from anywhere to UK. At first it reads as if it only applies to new build boats but it also talks about any boat being imported.

The 2017 Regulations set out the requirements that must be met before products can be placed on the GB market. The purpose of the legislation is to ensure safe products are placed on the GB market by requiring manufacturers to show how their products meet the ‘essential requirements’.
This guidance is relevant to manufacturers, importers (including private importers) and distributors of recreational craft, personal watercraft and certain engines and other specified components. It will also be of interest to consumers and approved bodies.

Regulations The Recreational Craft Regulations 2017
Guidance https://assets.publishing.service.g...to-recreational-craft-regulations-2017-tp.pdf

 

[TernVI]

The RYA may think this is an unexpected outcome. It's not.
Not sure it's totally a Brexit thing, more an EUSSR-UK thing of more bureaucracy affecting boats.
It was on the cards before, importing between UK and EU will be like importing from USA to EU used to be.
Everyone should have expected that.
It's much the same if you import a vehicle, you need an inspection to show it meets type approval standards.

 

[JumbleDuck]

Surely a boat that was built to the RCD & CE marked as such should not be penalised in this way, I cannot for the life of me understand why this needs to happen.

RCD compliance only applies on the day the boat is put into use. After that you can do what you like to it. There is therefore no guarantee that a boat which was compliant when put into use in the UK when new will still be compliant when put into use in the EU later on. This was an entirely foreseeable issue.

 

[Seven Spades]

As ever this RYA seems to have stired up a hornets nest of trouble for no reason. Before Brexit any CE marked boats imported from the Caribbean for example did not have to be re-validated only VAT needed to be paid. But if you imported a boat built to US standards. There is no reason for boat from the UK to be treated any differently to CE marked boats in the Caribbean or elsewhere.

 

[Graham376]

The flag and the registry cant be relevant. The act of selling in one country to base in another will either have to be an import and therefore pay out for RCR to RCD, or the owner (and only if UK resident) could just visit EU for 18 months at a time. But sell to and EU resident who wants to keep in the EU then there is no choice but to pay up and say thanks Brexit.

I am an EU resident and my (UK registered) VAT paid boat based here long before 31/12, is in free circulation. I don't see any problem selling it to someone who wants to keep it in the EU, regardless of their country of residence. It will not be a post Brexit import.

 

[RupertW]

I am an EU resident and my (UK registered) VAT paid boat based here long before 31/12, is in free circulation. I don't see any problem selling it to someone who wants to keep it in the EU, regardless of their country of residence. It will not be a post Brexit import.

Absolutely - I thought this thread was about the RYA article on cross-border sales.

 

[sailaboutvic]

I can't see how a EU resident can have a UK registered boat unless its part 1 .
My understand and I know it's correct unless they are a resident in the UK having a boat registered under SSR was against the rules.

 

[Graham376]

I can't see how a EU resident can have a UK registered boat unless its part 1 .
My understand and I know it's correct unless they are a resident in the UK having a boat registered under SSR was against the rules.

Have you never heard of dual residence?

 

[sailaboutvic]

Have you never heard of dual residence?

Yes I have heard of dual residence , but that not what you wrote ,
"I am an EU resident"
You see Graham we can all play that game of taken what people write out of context.

 

[EugeneR]

On the basis that the UK and EU standards, at the point of Brexit, were identical, boats complying with one should, logically, be considered compliant with the other - at that point.

All that is needed is to state that formally i.e. we accept RCD compliance at that point as criteria for ongoing UK standard compliance at that point. It's not rocket science. And RCD compliant boats remain RCD compliant, again stating the obvious.

Sure, our UK standard might deviate over time, but that can only be applied to new boats being certified. Even there, you might still accept EU RCD plus evidence of only the deltas, to get UK certification. QED.

It seems like someone wants to create another scary Brexit issue as opposed to deal with things sensibly.

 

[TernVI]

RCD compliance only applies on the day the boat is put into use. After that you can do what you like to it. ....

Not sure that's entirely true,
Were there not rumblings about re-engining boats and emission standards some years ago?
For instance.

 

[Seven Spades]

On the basis that the UK and EU standards, at the point of Brexit, were identical, boats complying with one should, logically, be considered compliant with the other - at that point.

All that is needed is to state that formally i.e. we accept RCD compliance at that point as criteria for ongoing UK standard compliance at that point. It's not rocket science. And RCD compliant boats remain RCD compliant, again stating the obvious.

Sure, our UK standard might deviate over time, but that can only be applied to new boats being certified. Even there, you might still accept EU RCD plus evidence of only the deltas, to get UK certification. QED.

It seems like someone wants to create another scary Brexit issue as opposed to deal with things sensibly.

That's exactly what I said above.

 

[JumbleDuck]

And RCD compliant boats remain RCD compliant, again stating the obvious.

They do not. That's the whole problem.

 

[EugeneR]

They do not. That's the whole problem.

Yes, in that one needs to confirm compliance when put into use or into the EU market from the UK; but, does the problem need to be a mountain?

Say a boat was RCD certified in the UK just before Brexit. Do you really need to check everything again, or could you sensibly ask whether anything has changed on the boat or in the standard, and then just check that? Could the owner self-certify if none of the relevant elements have changed? Up to £5k which is max for a complete RCD post-construction check today?

I have seen CE consultants have a cup of tea on board imported US boats and certify them without any checks beyond whether the boats are the same model as what is already certified by the official importer. Is that wrong... or just sensible?

Can we not agree a sensible approach between us and the EU?

(Above is not aimed at JD ... )