Marine Services

About Marine Services

CEproof is the global leader in CE marking for boats and related equipment, complying with the EU Recreational Craft Directive (RCD) and the Marine Equipment Directive (MED). With a reputation for customer excellence and an unparalleled technical knowledge of marine standards and legislation, CEproof is well positioned to provide standard and bespoke services for any requirement.

CEproof’s in-house team of naval architects, engineers and IT professionals ensures the company has the specialised personnel to solve all technical issues and provide a fully comprehensive service.

CEproof has developed Sonic Boom, a unique system for sound testing boats & engines which can be rapidly deployed in any location. CEproof has also designed its own award winning software package to dramatically simplify the process of compiling all mandatory documentation for the compliance of any boat that falls under the remit of the directives.

Marine Consultancy

CEproof has amongst its staff:

  • Naval architects
  • Marine engineers
  • Electrical engineers
  • Control & instrumentation engineers
  • Yacht surveyors
  • Ship surveyors
  • Ex-Yacht brokers
  • Ex-Notified Body staff
  • Ex-mariners
  • Ex-jet-ski champions
  • Computer programmers

CEproof is looking at different boats and boat builders all over the world every day. As a result, it is frequently exposed to new ideas and methods. This exposure to innovation, combined with the company’s training, skills and unrivalled knowledge of standards gives it the ultimate marine tool kit.

Expert Witness

CEproof has a wide range of experience amongst its staff (see the Consultancy tab for a list).

This experience has been employed as expert witness in disputes of many kinds, on commercial and recreational craft. Whereas most disputes centre upon experts’ opinions, CEproof’s regulatory knowledge can bring a basis of fact to the dispute: i.e. the issue at stake can be measured against standards, classification rules or national codes. This resolves cases more quickly and thus more cheaply than where one expert’s opinion is set against another.

CEproof’s staff carry membership for many professional institutions and some hold chartered engineer status.

Contact CEproof to have this ‘tool kit’ at your disposal.

Sound Testing

CEproof, Recreational Craft Directive consultants and suppliers of CE-Pro professional software for RCD Compliance, now has another tool to help boat builders meet the requirements of the amended RCD 2003-44-EC Directive.

The Sonic Boom™® has been invented by the company to make the process of sound testing semi-displacement and planning craft under 24m simple and cost effective.

The Sonic Boom™® consists of an inflatable boom that is 25m long with Type 1 approved sound measuring equipment mounted in a waterproof box at one end. To test a boat it is simply a case of the helmsman making a few port and starboard passes at the other end of the boom whilst the sound equipment is continually recording the results. It can be used free-floating or anchored, on inland or coastal water, and takes just minutes to inflate.

CEproof Sonic Boom

The Sonic Boom™®, whilst undergoing trials in Southampton Water, was inspected by Terry Egginton of Notified Body HPi, who commented: “The Sonic Boom™® will provide accurate and reliable results that we are very happy to accept.”

Craig Morris, managing director of CEproof. and inventor of the Sonic Boom™®, has confirmed that CEproof offices in strategic locations across Europe have ordered the Boom and will be able to carry out sound testing in various European countries.

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The Sonic Boom™® is a simple to use and accurate method of ensuring that your boat meets the requirements of ISO Standard 14509. The system does not rely on overly complicated electronics and ensures that the craft being tested is the correct distance away from the sound measuring equipment.

The Sonic Boom™® is available for purchase by boat builders and by surveyors offering compliance testing services in certain locations.

POA or contact us for price.

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CE Marking

About CE Marking

European Product Directives represent the minimum safety standards that products must conform to before they are allowed on the European market or before they are first put into service in the European Economic Area (EEA).

The famous ‘CE marking’ symbol indicates that a product has complied with all applicable Directives. A product complying with a directive in one EU nation must be allowed on the markets of all other EU nations, making the CE mark a vital ingredient in removing barriers to trade within the European single-market.

The EU does not have Directives for every single product, only those where differing national legislation within the member states created the perception of a barrier to trade. Only two European Product Directives are in force in the marine sector:

EU Recreational Craft Directive (RCD) 2003/44/EC as amended (originally 94/25/EC )
Recreational craft (boats) between 2.5m and 24m in length plus their key components

Marine Equipment Directive (MED) 2002/75/EC as amended
Safety & communication equipment carried by sea going vessels

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European Product Directives
European Product Directives

(Sometimes referred to as EU, EC, EEC or CE Directives.)

Contrary to popular belief, the principal goal of European Product Directives is not to improve levels of safety in European products. Indeed, many nations claim that the levels of safety imposed by such directives are inferior to their previous national requirements. The directives are born from the need to facilitate a single market between the EU member states.

Prior to the implementation of such directives, many or all EU member states will have had their own regime for regulating the products in question. Each regime was based upon a national perception of related safety hazards and has evolved in isolation from the other nations. This effectively created a barrier to trade – a product acceptable to some EU member states was not acceptable to another.

The European Product Directives are intended to create a single legal structure, within which products can be sold on the EU market – without having to submit to a multitude of national assessment and approval regimes in member states.

A product that is proven to comply with the appropriate directives in one EU member state must be accepted in all member states. A product must display the now-familiar CE marking (shown above) once this has been achieved.

As these directives are intended to overcome trade barriers, a directive has achieved its purpose once a product has been traded. Products falling within the scope of such a directive must comply at the first point of being put on the market or being put into service. Thereafter, the directive carries no bearing on the operation and maintenance of the product. Other types of European health & safety legislation or national regulations may, depending on the product, regulate these issues downstream of the point of sale.

New & Global Approach Directives

Current European Product Directives are written by the Commission incorporating two templates, known as the New Approach and the Global Approach. These lay down the way that standards are used to support the requirements of the directive, the methods used to assess conformity and where third-party certification is required.

New Approach - Harmonised Standards

Traditional legislation tended to include precise technical details and equations within the text of the legislative document. While this made assessment against the legislation easy, it has one big drawback: unforeseen developments. A new material or novel product, which was not foreseen at the time of writing the legislation, might not fit the technical requirements. If it could not comply it would be illegal, even if perfectly safe. In order to legalise the new product, the legislation would need to be updated.

The Commission’s current workload of new legislation is such that amending existing directives is low priority and can take a decade. During this time there would be a danger of non-EU competitors stealing a lead in technological development. To avoid this situation, the New Approach Directives now only list essential requirements in general terms. The precise technical details of conformity are left to the manufacturer to justify. The manufacturer is not without help. For each New Approach Directive, CEN, the European Standards Organisation, is mandated to draw-up a new range of standards to provide supporting technical detail. On completion, these standards must be adopted by each member state and any conflicting national standards of their own must be removed. In doing so, the standards become harmonised across the EU.

These harmonised standards provide the manufacturer with one solution for consideration. They are the easiest solution as, in becoming harmonised, as they have already been agreed as meeting the requirements of the directive. The standards, therefore, carry a presumption of conformity: an authority may question whether the standard has been properly applied; they cannot question the suitability of the standard itself.

A manufacturer is not obliged to apply a harmonised standard. If a solution, alternative to harmonised standards is used, the manufacturer must demonstrate equivalent safety. This is difficult to do and can always be questioned by an authority. CEproof’s services provide an effective solution to this problem.

Global Approach

The global approach lays down standard routes for conformity assessment. Each ‘route’ is called a module. There are 8 standard modules (see below) but these can be slightly altered in some directives. The European Pressure Equipment Directive (PED) is a significant example where there are many alterations to the modules. Other directives such as Machinery and Simple Pressure Vessels do not properly or explicitly define modules, although their prescribed conformity assessment procedures align closely to them.

Module Description

A  Internal Production Control
B  EC Type Examination
C  Conformity to Type
D  Production Quality Assurance
E  Quality Assurance for Final Testing
F  Product Verification
G  Unit Verification
H  Full Quality Assurance

Modules A, G & H are applied individually and module B, which covers only the design process, is applied in conjunction with one of modules C, D, E or F, which relate to the production phase.

A third party, known as a Notified Body, must verify conformity when a manufacturer applies all modules except A and C. It is clear then that these modules are only permitted for low risk products. Higher risk products are required to submit to outside verification of design (B) and/or quality audits (D, E & H) or inspection of samples of production (F) or inspection of every unit of production (G).  Each directive has its own system for categorising risk and assigning modules.

Further details of certain directives are given on this website but CEproof is able to help on a very wide range of European directives. Please contact CEproof for further details.

Overview / EEA Country List

Territories within the European Economic Area (EEA)

1. Products that fall within the scope of a directive must comply when first put on the market or put into service in any of the following areas.

2. The above statement implies that products that have been on the market or in service in any of the following areas, before the implementation of a directive, are excluded from scope.

European Union (EU) Members
  • Austria
  • Bulgaria (2007)
  • Belgium
  • Croatia (2013)
  • Cyprus (2004)
  • Czech Republic (2004)
  • Denmark
  • Estonia (2004)
  • Finland
  • France
  • Germany
  • Greece
  • Hungary (2004)
  • Ireland (Eire)
  • Italy
  • Latvia (2004)
  • Lithuania (2004)
  • Luxembourg
  • Malta (2004)
  • Netherlands
  • Poland (2004)
  • Portugal
  • Romania (2007)
  • Slovakia (2004)
  • Slovenia (2004)
  • Spain
  • Sweden (1995)
  • United Kingdom
Non EU Members within the EEA
  • Iceland
  • Norway
  • Liechtenstein
EEA Overseas Countries and Territories
  • Anguilla
  • Aruba
  • Azores
  • Bermuda
  • British Antarctic Territory
  • British Indian Ocean Territory
  • British Virgin Islands
  • Canary Islands
  • Cayman Islands
  • Falkland Islands
  • French Overseas Departments
  • French Polynesia
  • French Southern & Antarctic Territories
  • Greenland
  • Madeira
  • Mayotte
  • Montserrat
  • Netherlands Antilles
    • Bonaire
    • Curacao
    • Saba
    • Sint Eustatius
    • Sint Maarten
  • New Caledonia and Dependencies
  • Pitcairn
  • Saint Helena and Dependencies
  • Saint Pierre and Miquelon
  • South Georgia and South Sandwich Islands
  • Turks and Caicos Islands
  • Wallis and Futuna Islands

Common Mistakes

Switzerland is a member of EFTA but is not a member of the EEA.

The Channel Islands, Isle of Man and Gibraltar are not within the EEA.

The following states are EU applicants and may become EU members in the future:

  • Turkey
  • Macedonia
Marine Equipment Directive (MED)

wheelThe scope of the Marine Equipment Directive (MED) covers the equipment in the following categories carried by ships flagged with European Union member states:

  • Life-saving appliances
  • Marine pollution prevention
  • Fire protection
  • Navigation
  • Radio communication equipment

A full list of products covered by the Marine Equipment Directive.

The MED is the legislative tool used to ensure that equipment on EU ships conforms to international conventions such as SOLAS & MARPOL, as well as other safety and performance standards. Since ships regularly travel beyond the EU and since the conventions are International, a CE marking is not appropriate. The MED is unique, therefore, in not applying a CE marking. Instead products conforming to MED must apply the internationally recognised ‘wheel mark’, shown above.

Following the signing of a mutual recognition agreement on marine equipment between the USA and Europe in 2004, equipment certified to MED standards is acceptable for sale on both sides of the Atlantic.

CEproof’s Services for the Marine Equipment Directive (MED)

The directive requires products to be:

  • Documented against standards
  • Tested against standards
  • Certified

CEproof can write all documentation for your product. We have electrical and electronic test equipment and can perform a large proportion of the required testing. Where this is not possible, CEproof can help you arrange the correct laboratory testing. CEproof also has relationships with the majority of certifiers and will deal directly with them on your behalf.

Marine Equipment Directive (MED)

wheelThe scope of the Marine Equipment Directive (MED) covers the equipment in the following categories carried by ships flagged with European Union member states:

  • Life-saving appliances
  • Marine pollution prevention
  • Fire protection
  • Navigation
  • Radio communication equipment

A full list of products covered by the Marine Equipment Directive.

The MED is the legislative tool used to ensure that equipment on EU ships conforms to international conventions such as SOLAS & MARPOL, as well as other safety and performance standards. Since ships regularly travel beyond the EU and since the conventions are International, a CE marking is not appropriate. The MED is unique, therefore, in not applying a CE marking. Instead products conforming to MED must apply the internationally recognised ‘wheel mark’, shown above.

Following the signing of a mutual recognition agreement on marine equipment between the USA and Europe in 2004, equipment certified to MED standards is acceptable for sale on both sides of the Atlantic.

CEproof’s Services for the Marine Equipment Directive (MED)

The directive requires products to be:

  • Documented against standards
  • Tested against standards
  • Certified

CEproof can write all documentation for your product. We have electrical and electronic test equipment and can perform a large proportion of the required testing. Where this is not possible, CEproof can help you arrange the correct laboratory testing. CEproof also has relationships with the majority of certifiers and will deal directly with them on your behalf.

Recreational Craft Directive

Scope

The following craft are within the scope of the European Recreational Craft Directive (RCD):

  • Recreational Craft from 2.5m up to 24m in length
  • Personal Water Craft (PWC) – otherwise known as jet skis

Since 1st January 2006, the noise and exhaust emissions of propulsion engines of recreational craft in Europe have been part of the RCD scope.
In addition to craft, the following products (if prefabricated), fitted on European recreational craft, are also within the scope:

  • Propulsion engines for recreational craft and PWC as defined above
  • Ignition-protected equipment for inboard and stern drive engines
  • Start-in-gear protection devices for outboard motors
  • Steering wheels, steering mechanisms and cable assemblies
  • Fuel tanks intended for fixed installations and fuel hoses
  • Prefabricated hatches and port lights

European based vessels or components within the scope of the Recreational Craft Directive (RCD) must have a CE marking and conform to the directive. Some of the above components do not need CE marks if fabricated with the boat. Contact CEproof for details.

Exclusions

There are certain types of vessel excluded from the European RCD, including:

  • Craft intended solely for racing
  • Canoes
  • Kayaks
  • Pedaloes
  • Sailboards
  • Powered surfboards
  • Original and individual replicas of historical craft designed before 1950, built predominantly with the original materials
  • Experimental craft not subsequently put on the market
  • Craft built for own use, provided they are not sold for a period of five years from completion
  • Commercial and passenger vessels. (NOTE – a yacht chartered for recreational use is still a ‘recreational craft’ and in scope of RCD, regardless of the fact that money has changed hands)
  • Submersibles
  • Air cushion vehicles
  • Hydrofoils

New or second-hand vessels that were built/put into service/put on the market within the EEA before 16th June 1998 are exempt. Note that some second-hand vessels will have to comply if imported to the EEA after these dates.

More information on identifying if your vessel is exempt and advice on how to prove it can be found on our directive exemption certificates (DEC) page.

Responsibility

The person or company who first puts the completed product on the European market or into service is responsible for making the vessel compliant. This could be anyone from the builder to the owner. For second-hand imports, it must be the importer.

Design Categories
Category Significant Wave Height* Beaufort
A – Ocean Exceeding 4m** Exceeding 8
B – Offshore Up to & including 4m Up to & including 8
C – Inshore Up to & including 2m Up to & including 6
D – Sheltered Up to & including 0.3m Up to & including 4

* Significant wave height means the average height of the highest third of the waves over a given period. Waves of double that height may occasionally be experienced.

** The RSG, the Notified Bodies’ forum for the European Recreational Craft Directive, has recommended a wave of 7m be used for assessment purposes.

It is possible for a vessel to have a CE marking in more than one RCD design category provided all requirements for those categories are met.

Compliance & Documentation

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 for its clients and has written more TCFs than any other organisation in the world. Alternatively, the company’s CE-Pro software will allow its clients to compile all the required information themselves, in a simple and straightforward manner.

Essential Requirements

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.

Special Cases

Post Construction Assessment (PCA) - Imported Boats

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 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.

American Imports (ASB)

American boats have always been cheaper in the US than Europe but with the current low dollar, there have never been more boats crossing the Atlantic. For the most part, the imports are used sports boats.

Get Legal

Grey Imports are perfectly legal provided the official inspections and the documentation are carried out correctly. This means making sure your boat is certified for CE Marking as well as paying VAT and Import Duty. It is widely known that you can ‘grey’ import a car for instance but before you can register it you have to have various checks carried out. It is not that different for boats. Remember that a grey import simply means it has not been routed through an officially appointed dealer or distributor.

sea ray

Why?

If a boat is not certified for CE Marking when it should be, it is no longer a grey import, it is quite simply illegal. If you put an illegally imported boat into service or on the market within the EU you are committing a criminal offence with the maximum penalty being a £5000 fine and / or 3 months in prison. In some countries you run the additional risk that the boat will be impounded until CE Marking is carried out.

The Recreational Craft Directive (RCD) has been in operation since the 16th June 1998, but on the 1st January 2006, amendments to the Directive came into force. There are now specific rules about how CE Marking is to be carried out on existing and second-hand imported boats. Most significantly, there is now a need to obtain a report or certificate from a verification organisation known as a Notified Body. Additionally the boat must comply with new limits on noise levels and engine emissions. The effect of these changes is already leading to an increased level of surveillance from the industry itself and the regulators. Remember, if you break the law, you could end up with a criminal record. This is very different from paying a civic penalty like a parking fine.

Regardless of the legal implications, it makes a great deal of sense to have CE Marking, because without it, your asset is seriously devalued. More and more people are finding out that they have a boat that they cannot insure a boat or sell through a broker or dealer when they try to trade up. Many unsuspecting private buyers have landed themselves with a problem by accepting an illegal boat. Don’t be one of these people.

bowrider

How do I know if I need CE Marking?

Get good advice and do your homework. Answer the following questions:

  • Does the boat already have CE Marking? (It only ever needs doing once or when re-engined).
  • Is the boat less than 8ft (2.5m) long?
  • Is the boat designed and used exclusively for racing?
  • Is the boat a hydrofoil, submarine or a hovercraft?
  • Is the boat a one-off or individual replica designed before 1950?
  • Was the boat in the EU / EEA before 16th June 1998?

If the answer to all the above questions is “No” you need CE Marking. You can see that the age of the boat is only relevant if it was designed before 1950. Any other advice is not accurate.

fourwinns
Exemption Certificates (RCD)

If you can prove that a second-hand yacht from a third country has been in service, or has been sold in any of the regions listed below, before 16th June 1998 you are in a position to claim exemption from the requirements of the RCD.

Qualifying evidence could be in the form of invoices / receipts or other documents or combination of documents.

The Directive Exemption Certificate (DEC) has been developed by CEproof to bring together this evidence into a single authoritative document. The DEC has proved effective where the RCD status of a vessel is not obvious and where the alternative might be to make the vessel compliant.

  • Clarifies status of a vessel in relation to the RCD
  • Justifies absence of a CE marking
  • Can have a useful function in the legal sale of a vessel from a Third Country into the EU / EEA
  • Resists restrictions being imposed on the use of a vessel according to assumed or perceived Categories
  • Guards against discrimination and loss of value of non CE marked vessels at point of sale
  • Carefully worded and designed, with texts clearly stated in the principal languages of the EU
  • Facility for the issue of HIN for those vessels not currently inscribed with a Hull Identification Number
  • Certificate is linked to the vessel by the HIN and stays with the vessel for its lifetime i.e. not another form of Registration.
  • Weatherproof Certificate for durability in a marine environment.
  • Once off payment
  • Recorded on a secure database for rapid verification of authenticity of Certificates even from remote locations
  • Provides reassurance in the event of qualifying documents being inadvertently discarded

Note: The DEC is not a legal document and may not prevent national rules being applied because the vessel is not CE marked.

Note: There are over 70 separate countries / territories around the world that are within the EU / EEA. At least 55 of these countries have extensive coastlines and ports in which a vessel may have been in service. Proof of any such service before June 16th 1998 may be adequate to establish exemption from the requirements of the Recreational Craft Directive

Boats Built For Own Use in EU
Home-Built Boats (built for one’s own use) do not need to comply with RCD but the boat may not be change ownership until the boat is 5 years old i.e. 5 years after completion. Before the 5 years have passed, the boat is not exempt from the RCD. Exemption certificates may not be issued to home built-boats until they are 5 years old.

Cost of Exemption Certificates
Exemption Certificates for all boats are issued for a one-off fee of £275
(+20% VAT = £330 where applicable. EU clients must supply a VAT number to be exempt from VAT.)

Clients

Simple, intuitive with massive impact on collaboration and productivity. Plus flawless and timely support.”

Paul Cunningham,
Managing Consultant, Bluebarn Consulting

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