Since 1st January 2006 the RCD has included a specific conformity assessment process for craft being CE marked after build, without the involvement of the craft’s manufacturer. The process requires each individual boat to be certified by a Notified Body, regardless of category and size and even if the boat is brand-new and unused. This is because a private importer may not be technically minded and in no position to declare the compliance of a boat without verification. PCA is also mandatory where a home-builder sells the boat before the the 5 year exclusion-qualifying period is complete.
PCA still requires the boat to carry documentation, just like any other craft and the importer must sign the Declaration of Conformity, but even a 3m long category D imported boat needs full certification from a Notified Body. The boat will be issued with new identification numbers that point towards the certifier so that authorities wanting to check compliance know where to find the documentation.
Be aware however, that the importer carries the liability for the initial compliance of the boat – even after selling it. Thus the importer could be held liable for an accident on a boat that was later found to be non-compliant, even if he/she was not the owner the boat at the time. The certificate is some mitigation in this scenario but if a certifier is found to have issued a certificate in error, it does not absolve the importer from having imported the dangerous boat in the first place. This sounds frightening but the liability is easily minimised by conducting the RCD inspection and diligently generating all documentation.
There are some individuals offering CE marking without an inspection of the boat. They will issue the documents simply on the basis of the boat being a “known” model. But what if something has broken or has been modified between build and import? What if the boat was supplied by the builder with a mistake? Once the boat is imported, the error would now be the fault of the importer, not the builder. To pay for CE paperwork and not have the protection of a visit is not only a false economy, it could be deemed reckless in a court of law.
CEproof staff always inspect the boats whose CE marking we help oversee and what’s more, we always select the certifiers with great care. CEproof works with a number of certifiers and we have obtained more certificates from more Notified Bodies than any other organisation. We only work, however, with those we feel add value to the process – i.e. they do their job diligently and help to minimise the liability for us all… at a fair price.
Do it properly with CEproof and you can enjoy your boat in full confidence that your boat and your paperwork will stand up to any scrutiny.