There are only 2 types of boat component in Europe:
- Those that MUST be CE marked under scope of RCD
- Those that MAY NOT be CE marked under the scope of RCD
But nothing is straight-forward in Europe: it is possible for a component, which may not be CE marked under RCD, to require CE marking under the scope of a different Directive e.g. Electro-Magnetic Compatibility. We’ll deal with these in the second category.
1. Components that MUST be CE marked
The RCD’s Annex II has a list of those components that must be CE marked under the scope of this Directive. Rather unimaginatively, the industry refers to these as ‘Annex II Components‘:
- Ignition-protected equipment for use in petrol engine & tank spaces.
- Start-in-gear protection devices for outboard engines.
- Steering wheels, steering mechanisms and cable assemblies.
- Fuel tanks intended for fixed installations and fuel hoses.
- Prefabricated hatches and portlights.
So any product that is sold for such use is in the scope of RCD and must be CE marked.
Note that item 3 refers to steering mechanisms. This is understood to mean ‘system’ so that an electronic joystick for steering would be considered part of the mechanism, so in need of a CE mark. On the contrary, a fuel filter is part of a fuel system but only tanks and hoses are referenced above: not the system. So a fuel filter may not be CE marked under the scope of RCD.
In addition, the Directive also includes engines that are to be fitted on recreational craft. To earn their CE mark, all engines must meet exhaust emissions criteria and if the engine has an integral exhaust (eg an outboard or sterndrive) then it must also meet noise limits. If the engine does not have an integral exhaust and is fitted to a high speed boat, then the boat manufacturer must demonstrate that the boat & engine together meet the noise limits.
Conformity Assessment & Certification
Engines and Annex II Components require a CE mark and must be certified by a Notified Body such as HPiVS: this is called EU Type Approval. This usually requires testing which may either be done in an accredited laboratory or if done elsewhere, must be witnessed by a HPiVS inspector.
2. Components that MAY NOT be CE marked
If a component is not listed in Annex II of RCD (see no. 1 to the left) then it may not be CE marked under RCD but it may have to conform to standards that are mandated under RCD.
For example, a fuel filter is not listed in annex II but the RCD’s harmonised standard for fuel systems (EN ISO 10088) has requirements for fuel filters. So the fuel filter manufacturer should ensure that the product conforms to the standard and would be well advised to advertise this by adding ‘conforms to EN ISO 10088’ on the product label.
The RCD sets requirements and thus has standards, for nearly all systems on-board. The following systems, however, do not fall within the scope of RCD:
- Fresh water systems
- Hydraulic systems (other than steering)
- Any part of the rigging (other than chainplates)
Voluntary Certificates of Conformity
Formal EU Type Examination certificates may only be issued for Annex II Components. Notified Bodies such as HPiVS may, however, issue a voluntary ‘certificate of conformity’ as third-party verification for a product conforming to any standard, on the condition it does not give any implication that it is a formal CE-certificate. HPiVS can issue such certificates. HPiVS is only willing, however, to issue certificates for products that are within the scope of a standard mandated under a Directive for which we are an accredited Notified Body. We do not approve of companies that certify products that do not fall within their accredited scope of expertise.
Components that require CE marking under directives other than RCD
It is too complicated to list here, all the boating components and the EU Directives with which they may have to comply. To do this, one would have to read the scope and exclusions of each and every directive. But if you have a specific product in mind, it is not so difficult to look through the titles of the EU Directives and short-list those that might apply.
While it is difficult to be precise, there are 2 other Directives of particular note for boating components:
The Machinery Directive applies to all products that have actuating parts (e.g. a pump) but excludes products for ‘sea going vessels’. So a pump may need CE marking under this directive if it is to be fitted on boats for inland waters.
The EMC Directive deals with all electrical and electronic products that could suffer from EMC radiation or that could emit radiation about the prescribed limits.