Hovercraft, The Recreational Craft Directive (RCD) & CE Marks

added by russ on November 3, 2015 at 10:25

We often get asked whether our hovercraft are 'CE' marked or not – the answer isn't quite straightforward, read on to find out.

Background

In the EU, marine vessels sold new by a manufacturer for recreational or pleasure purposes have to conform with Directive 94/25/EC, known as the Recreational Craft Directive, or RCD. This directive sets out the minimum technical and environmental standards for marine vehicles between 2.5m and 24m, ensuring they are 'suitable' for sale within the EU. The RCD was amended in 2003 by Directive 2003/44/EC which brought personal watercraft (ie Jet bikes/Jet skis) into the RCD. The directive also includes marine engines and some components. From January 2016, a new Directive, 2013/53/EU, replaces the current legislation but is basically the same and is aimed at reducing emissions.

 Exclusions

 Below is a list of vessels excluded from the RCD (taken from the RCD text.)

 craft intended solely for racing, including rowing racing boats and training rowing boats labelled as such by the manufacturer; or

 canoe and kayak, gondola or pedalo; or

 sailing surfboard; or

 powered surfboard or other similar powered craft

 original, and individual replica of a historical craft designed before 1950, built predominantly with the original materials and labelled as such by the manufacturer; or

 experimental craft, provided it is not subsequently placed on the Community market; or

 craft built for own use, provided it is not subsequently placed on the Community market during a period of five years; or

 craft specifically intended to be crewed and to carry passengers for commercial purposes, regardless of the number of passengers or

 submersible; or

 air cushion vehicle; or

 hydrofoil.

See it down there second from the bottom? Hovercraft are air-cushion vehicles (ACV.) So, in short – neither we, nor any other manufacturer can CE mark our hovercraft under the RCD, as ACV's are not eligible. Having checked the forthcoming legislation, we can confirm that they remain excluded from the new 2013/53/EU directive as well.

 Options

Two years back, BHC approached the European authorities and opened a dialogue aimed at either including ACV's or allowing us to voluntarily claim compliance and plate our craft accordingly. However, the ACV market is too small to interest Europe and we were refused. So, we looked into other directives, the only one of which seemed at all relevant was the Machinery Directive 2006/42/EC. Again, following extensive discussions, the answer was a 'no.'

We lobbied the EU to include ACV's in the new legislation due to the growing market – but as stated above, ACV's remain excluded.

 So where does that leave us?

A number of boat builders have told us that we're lucky that we do not have to comply with the RCD and the inevitable administration that goes with it. However, our ambition for the hovercraft industry is such that we're looking at the big picture and the long term growth of both the industry and our own business. We've certainly lost a few sales over the years due to the fact we cannot claim compliance with the RCD, but generally this has been due to the misunderstanding that the craft should be compliant.

However, with very few exceptions, and in all the main areas of safety, our craft do comply with the standards of the RCD. The only area we may struggle is with the stipulated noise levels, marginal on the Snapper & Marlin but the Coastal-Pro is comfortably within limits.

So what's that CE plate I see on the dashboard then? 

Although – as established – we cannot claim compliance with the RCD, ACV's do still need to comply with the standards of the Electromagnetic Compatibility Directive 2004/108/EC. This directive basically confirms that a product sold within the EU is not causing excessive electromagnetic interference, nor is effected by the same. So, back in 2013, we put our craft through the necessary tests and compiled a conformance file. Following a meeting with Kent Trading Standards, we started to affix a compliance plate to all our craft.

Are BHC craft built to a standard? 

Of course! Back in 2012, we approached the MCA to introduce a set of standards for small hovercraft. Initially rebuffed, we eventually got our way, and together with Griffon Hoverwork of Southampton, we established a manufacturers association and got the MCA to the table to start work on the 'Hovercraft Code of Practice.' Three years, many hours, miles and meetings later and the code is due to be introduced anytime soon (it's currently going through public consultation) and sets out standards for small craft up to 24m in length. It's our fervent hope that the legislation will be adopted by other countries in due course.

All our craft are built to the standards of the HcoP and marked accordingly alongside the conformity statement for 2004/108/EC and this – in truth – is a more relevant build standard than the generic RCD could hope to provide. 

Conclusion

Hopefully, this document will explain what is possible, why hovercraft cannot be CE Marked, what standards BHC craft meet and what we've done to establish the build quality of our products.To the best of our knowledge, BHC manufacture the only hovercraft that conform to any formal standards - at least nobody else claims compliance with the HcoP or 2004/108/EC. We were the company that started the ball rolling to introduce the HcoP, we've discussed voluntary inclusion into the RCD , explored options and as such, we believe our products conform with all existing legislation and exceed the industry standards of the HcoP. 

If you need to know more, do please call us.

Sample Plate

 

 

Hovercraft Finance

added by russ on August 19, 2015 at 10:18


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