The person or company who first puts the completed product on the European market or into service is responsible for making the product compliant and generating the mandatory paperwork.
This is usually the manufacturer but may also be the importer.
RCD II has defined roles and responsibilities for everyone involved in the supply of products that fall into the scope of the RCD. These explicitly include:
This means that distributors, dealers and even brokers have a role to play in ensuring compliance with RCD.
When placed on the market or put into service, craft must be accompanied by a Declaration of Conformity. This attests that the vessel meets the Essential Requirements (ER) contained in the Directive.
A Technical Construction File (TCF) must be produced and maintained by the Manufacturer/Authorised Community Representative. This file must be kept whilst a particular model is in production and for a minimum of ten years beyond production of the last vessel.
The TCF describes how the vessel meets the Essential Requirements. It is a large document that works through every clause of every applicable standard, proving compliance.
The vessel must have an owner’s manual. This has to contain information about the safe operation of the vessel and other contents as prescribed in the technical standards used to create the TCF. The Declaration of Conformity accompanies the owner’s manual and should stay with the boat if ownership is transferred.
CEproof specialises in writing these documents and offers its customers all advisory and supporting activities related to the Recreational Craft Directive 2013/53 / EU.
Not all the ERs are in fact safety related. There are thirty Essential Requirements set out in the directive. Not all ERs may be applicable to some small simple boats.
The ERs are intentionally non-prescriptive to allow maximum freedom of design.
For example, ER 3.1 requires the boat to ‘be strong enough in all respects’. To provide the missing detail, the ERs are supported by harmonised standards but it is perfectly legal to apply other standards if you can show equivalence. It can be difficult, however, to prove equivalence without expert help.