URGENT ATTENTION ALL EUROPEAN BASED OWNERS OF US BUILT MELGES 24'S
EU Marking & The Recreational Craft Directive - From IMCA Technical Consultant David Chivers - Owners who have imported boats into Europe from the US should know that they do not necessarily comply with the Laws of the European Union despite meeting the International Melges 24 Class rules.
Any vessel first entering the European Economic Area after 16th June 1998, irrespective of the age of that vessel must comply with the regulations of the Recreational Craft Directive (RCD). Please note that although the boats obviously all conform to the class rules, Devoti Sailing cannot issue the required Declaration’s of Conformity on boats not built by them. Equally Melges Boatworks have not issued a Declaration of Conformity for the boats they build. They are not able to issue these retrospectively and it is unlikely that they will start issuing these Declarations, as they do not directly sell to Europe. It is the sailors, who have imported second hand boats who are responsible for compliance.
If you do not ensure that your boat complies with the RCD, you run the risk of being prevented from sailing or having your boat refused entry at a border crossing - this has already happened in other classes and it is presumably only a matter of time before it affects our class. Unfortunately, the International Class Association can do nothing to help in this circumstance, as it is not in our jurisdiction.
At present, it is possible to “Self Assess” the boat individually without recourse to a notified body. This option ceases on 1st January 2006 after which it will be compulsory to use a notified body, incurring the expense that that will generate. Please be aware of this if you are planning to buy a boat for use in the USA and subsequently thinking of bringing it back to Europe.
For a boat to comply with the Recreational Craft Directive and to be consistent with the boats produced in Europe, which already comply, the boat will need to be certified to Category “C”.
You have several options.
You will need to produce a Declaration of Conformity and end up with a Builders Plate giving the necessary details on the boat itself.
Alongside the Declaration, you will need to produce a Technical File showing that the boats has been built to the necessary standards including stability, and an Owners Manual covering all aspects of the use and maintenance of the boat both afloat and ashore, including rigging and trailing. There are 3 options, which you may wish to consider.
1. You may produce this yourself, by researching the standards as necessary and producing the manuals as required.
2. You may employ the services of a consultancy. One Consultancy who specializes in this area is Ceproof, who would be able to put together a package for a number of owners. (Tel 02380 453245).
3. If there is enough owners that wish to ensure that there boats comply, I am willing to investigate the possibility of providing a package, which will include all the necessary documents for you to sign and a sticker to put on the boat. The boat will be deemed to have been self certified by you, but you will not have to spend the time researching all the details.
I cannot give a cost as yet, until I have more ideas of the number of boats involved. There is potentially a lot of work to solve this; whichever route you take and the costs will be proportional
If you have any further queries, please contact me and if you are interested in the possibility of a “Self Certification Package”, please let me know.
D. Chivers.
Technical Consultant