|Does My Narrowboat need
Unless the boat is being built by you, for your own use then the
directive does apply in full. DIY builders or those fitting out
a shell should be aware that if they choose to apply the
exclusion and then later find that they need to sell the craft
then they could be faced with a mandatory ‘Post Constructional
Assessment’ which is very likely to incur large professional
fees running into several thousand pounds.
What happens if I don’t make
my boat comply?
The offence of not complying rests with the ‘responsible person’
who is normally the builder or the person who project manages
the build. The DIY boat fitter is also considered as the
‘responsible person’. Failure to comply can be deemed as a
criminal act on the part of the ‘responsible person’ and is
punishable by a stiff fine and custodial sentence.
Does it just apply to new
No, not exclusively, it applies to all pleasure craft when they
are first ‘put on the market or put into service ‘ within the
European Economic Union. So this includes craft imported from
outside the EU and any commercial craft converted for pleasure
use wherever they are sourced. As such commercial narrowboats,
barges, fishing vessels, Tugs, work boats and passenger boats
which were in a commercial capacity after 16th June 1998 are all
required to comply with the Recreational Craft Directive when
they are ‘put on the market or put into service ‘ as a
What must I do in order to
There are administration requirements for the ‘responsible
person’ to compile a file of technical information about how the
craft satisfies the ‘Essential Requirements’ of the directive
and in addition a detailed Owners manual must be produced so as
to inform the owner on how to operate the craft and its
equipment in a safe fashion.
Ultimately a completed craft which satisfies the requirements
must be marked with the ‘CE’ logo and be fitted with a builders
plate indicating how many passengers, crew and luggage may be
carried aboard the boat.
For barges and other craft intended to be cruised in non
‘Sheltered waters’ proving compliance can be more elaborate.
What Essential Requirements are applicable to narrowboats?
All the ER’s must be satisfied irrespective of the craft type,
however achieving compliance can be less difficult for
narrowboats than for example a transatlantic sailing yacht.
Do I have to employ
Not necessarily, depending on your craft type, For inland
waterways craft which are not intended to be used at sea then
self certification is possible and relatively easily achieved by
someone competent enough to carryout the fitting out process.
For craft that may put to sea or operate in some estuaries then
the involvement of a notified body may be required for various
aspects of the process.
How much does compliance
It can be free! Depending on your craft type, and how you choose
to go about the process. However to embark on the process alone
may prove to be arduous and some professional guidance may well
be money well spent. Beware of becoming bemused by the chatter
of some ‘professionals’ who in some cases have been known to
deliberately emphasise the difficulties before offering up their
own trouble free one stop solution at a cost of hundreds or even
thousands of pounds, equally beware of those who claim all you
need is an owners manual and offer a ‘one size fits all’ as
these is rarely the only or the most cost effective options and
both may come back to haunt you, compliance is rarely that
simple or that complicated , its normally a little time
consuming and elaborate.
Is a Boat Safety Scheme
If the certificate was correctly issued prior to 1st April 2005
then in general terms where the BSS regulations cover the same
areas of the craft as the RCD then the requirements of the RCD
were less stringent than those of the BSS. However with the new
look BSS (post 1st April 2005) then many of the BSS requirements
fall far below the statutory requirements of the RCD.
In addition BSS examiners and participating surveyors are not
permitted to issue a BSS certificate to any craft which is not
CE marked but which it is intended will become so in the future.
What standards can I use
for my Narrowboat?
With a few exceptions any standard can be used to declare
compliance with the Essential Requirements providing they
suitably cover the requirements of directive. This would include
where appropriate ‘custom and practice’ or a bespoke testing
procedure providing there is sufficient documentation in
builders technical file and the relevant Essential Requirements
have been adequately satisfied.
There are specific ISO standards which have been written for use
with the RCD, these are known as ‘Harmonised Standards’ and full
compliance with these standards assumes conformity with the
Can I fit an old
‘traditional’ engine to my new narrowboat?
Very little of the RCD has been clarified by the courts, however
current thinking on this matter is that any engine which was in
existence within the EU before 1st January 2006 may be fitted
into a new craft and need not comply with the emissions
regulation concerned with particle emissions. The reasoning
being that the new approach directives, which cover all CE
marked products and of which the RCD is one, do not and must not
apply to second hand goods except in the case of items imported
Getting this wrong could result in a requirement to remove a non
compliant engine and its replacement with one which is complaint
followed by an additional need for a post constructional
assessment. This would be highly costly and as such professional
advice from an RCD specialist should be sought before a
non-compliant engine is selected for installation.
Do I have to CE mark my
self build boat before I can take it into the waterways of
No, it is not a legal requirement, but it can be a difficult
task to convince the European customs officer of that fact!
Where Can I Get Help With
The British Marine Federation and the Royal Yachting Association
are both able to offer some limited and very general guidance on
the Directive but it is unlikely to be a perfect match with the
specifics of your boat.
You can seek help from a professional surveyor experienced in
this field, but be sure that they have got the experience
required to assist you in selecting the best compliance options
to suit you and your boat rather than persuading you to adapt
your boat the way of claiming compliance which is the most cost
effective to them.