Definitive paperwork required to purchase a Widebeam for safety compliance

[David Mack]

3 minutes ago, MartynG said:

That's clearly not an issue with boats already in the UK and to remain in the UK as many used boats have been sold in 2022 and  we  would have heard if there was an issue.

Exactly my point. The advertising for sale in GB of used boats which are already in the country does not constitute "placing on the GB market", and thus sellers and brokers acting on their behalf, are not required to comply with the rules for new and newly imported craft.

[MtB]

3 minutes ago, David Mack said:

Exactly my point. The advertising for sale in GB of used boats which are already in the country does not constitute "placing on the GB market", and thus sellers and brokers acting on their behalf, are not required to comply with the rules for new and newly imported craft.

 

Let's hope the OP is finding all this crystal clear, and is now completely satisfied with their answer!

[Momac]

9 minutes ago, David Mack said:

Exactly my point. The advertising for sale in GB of used boats which are already in the country does not constitute "placing on the GB market", and thus sellers and brokers acting on their behalf, are not required to comply with the rules for new and newly imported craft.

I agree 100%.

Otherwise , as an example, a used boat would have to comply with emission requirements in force at the date of the sale which would put a stop on sales of all boats more then a few years old.

All this has effectively put a stop on importing older than a few years  used boats from the EU which the narrowboat world is shielded from due to narrowboats being so very specific to the UK.

Edited December 24, 2022 by MartynG

[Momac]

I would say  to the OP

Buying a boat was the best decision of my entire life . My boat isn't  a narrowboat but the type and form of the boat is  irrelevant.

Boating  under power and under sail has been key to my wellbeing over the last several years. (Under sail only to a lesser extent due to crew preferences).

Go for it and enjoy!

 

 

 

[TheBiscuits]

32 minutes ago, David Mack said:

Exactly my point. The advertising for sale in GB of used boats which are already in the country does not constitute "placing on the GB market", and thus sellers and brokers acting on their behalf, are not required to comply with the rules for new and newly imported craft.

 

Be aware that the scope of RCD/RCR has changed from "first placed on the market" to "placed on the market"

 

I think Alan is correct under the new rules.  Offering a second hand boat that's within scope of the RCR for sale now counts.

 

That's pretty much any boat built after 1997, with the exception of the self build 5 year exemption ones.

 

It specifically does not apply to out of scope boats, so no pre-1997 boats need to comply.

[TheBiscuits]

50 minutes ago, David Mack said:

So anyone selling a boat built under the old EU RCR rules could place that on the GB market until 31 December 2021 (i.e. a year ago).  So what happens when the owner of such a boat wants to sell it on as a used boat. Are you saying it can no longer legally be sold in GB? Because that is the implication if "placed on the GB market" includes used boat sales.

 

No, it's just that new boats this year onwards need to be marked UKCA not CE, with an grace period for those already in build last year until the end of this month.  It's pretty much CE with the serial numbers filed off anyway as they didn't change the specification just the badge.

 

Note that specific section only applies to manufacturers, not distributors - and only relates to CE marking and assessment.

[Barneyp]

1 hour ago, MtB said:

 

 

And does anyone give a monkey's chuff except for you? 

 

 

 

Well the thread is now 4 pages long with multiple contributors including you so clearly the answer is yes they do.

41 minutes ago, MtB said:

 

Let's hope the OP is finding all this crystal clear, and is now completely satisfied with their answer!

You see you're still here even after your previous post.

I think what is clear is that there is no definitive answer, while the regulations/law may be clear the enforcement isn't.

[MtB]

.

 

Edited December 24, 2022 by MtB
Changed my mind.

[David Mack]

5 hours ago, TheBiscuits said:

No, it's just that new boats this year onwards need to be marked UKCA not CE, with an grace period for those already in build last year until the end of this month. 

The grace period to the end of this year allows boats already in build to have the UKCA marking applied to the documentation rather than the boat itself. But all boats placed on the GB market since the beginning of this year have required a UKCA marking. The grace period for boats with a CE marking expired at the end of December last year.

Edited December 24, 2022 by David Mack

[Murflynn]

17 hours ago, Barneyp said:

Well the thread is now 4 pages long with multiple contributors including you so clearly the answer is yes they do.

You see you're still here even after your previous post.

I think what is clear is that there is no definitive answer, while the regulations/law may be clear the enforcement isn't.

 

not many rules and regulations are enforced in Modern England; mind you, DVSA operates an Enforcement Site in Abingdon, which somehow sounds a bit like a South American Nazi establishment.   I wish they would enforce the rules affecting bikes and scooters.   Happy Xmas everybody !!!

 

https://www.google.co.uk/maps/@51.6695711,-1.3134402,3a,17.1y,56.91h,90.12t/data=!3m6!1e1!3m4!1sRqCOQBX_pOuEVshL7K2URA!2e0!7i16384!8i8192

Edited December 25, 2022 by Murflynn

[Tony Brooks]

2 hours ago, Murflynn said:

 

not many rules and regulations are enforced in Modern England; mind you, DVSA operates an Enforcement Site in Abingdon, which somehow sounds a bit like a South American Nazi establishment.   I wish they would enforce the rules affecting bikes and scooters.   Happy Xmas everybody !!!

 

https://www.google.co.uk/maps/@51.6695711,-1.3134402,3a,17.1y,56.91h,90.12t/data=!3m6!1e1!3m4!1sRqCOQBX_pOuEVshL7K2URA!2e0!7i16384!8i8192

 

It is probably where they inspect HGV and PCVs (HGV & PSV) for compliance and safety. Probably no need for court action for  most offenders who just pay up to get back on the road and if they don't they lose their various licenses. Much more difficult to enforce against random public who are not required to carry or show any identification whatever.

[Momac]

20 hours ago, TheBiscuits said:

 

Be aware that the scope of RCD/RCR has changed from "first placed on the market" to "placed on the market"

 

I think Alan is correct under the new rules.  Offering a second hand boat that's within scope of the RCR for sale now counts.

 

That's pretty much any boat built after 1997, with the exception of the self build 5 year exemption ones.

 

It specifically does not apply to out of scope boats, so no pre-1997 boats need to comply.

You are misunderstanding the term ''placed on the market''

https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain#:~:text=A product is placed on the market when an offer,physical transfer of the product.

 

p

 

[Momac]

On a bit of a drift the grace period for acceptance of CE marking for construction products which was due to expire at the end of this month has been extended to June 2025. This is largely because suppliers from outside the UK can't be arsed to update to UKCA for the relatively small UK construction market. I dare say the date will be  extended further in due course .

The construction industry is very slow at adopting change as is the marine industry.

 

 

https://www.building.co.uk/news/two-and-a-half-year-respite-for-construction-products-as-government-finally-provides-ce-mark-clarity/5120869.article

 

[Alan de Enfield]

1 hour ago, MartynG said:

You are misunderstanding the term ''placed on the market''

https://www.gov.uk/guidance/placing-manufactured-goods-on-the-market-in-great-britain#:~:text=A product is placed on the market when an offer,physical transfer of the product.

 

There is a difference between "making available" and "placing on the market"

 

 

11) ‘making available on the market’ means any supply of a product for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge;

12) ‘placing on the market’ means the first making available of a product on the Union market

[manxmike]

OMG,

I would have been perfectly happy to buy a second hand boat, with or without the correct paperwork, but now I think I'll stick with my Motorhome.

I loved my narrow boat, no previous paperwork, just a survey from someone I trusted. Now, I think I'd run a mile.

The mere thought of entering into litigation because someone has used the wrong thickness wire, or the glass in the windows doesn't meet BSS whatever is a nightmare. Whatever happened to "Buyer Beware", or the latin version "Caveat Emptor".

You pays your money, you takes your choice.

Ah well, merry Christmas and pass another (ANOTHER?) glass of the amber nectar.

[PaulD]

UKCA will be another nail in our brexit international trading coffin.
 

A lot of foreign suppliers are not going to appoint the “Authorised Representative” needed to rewrite the technical files, obtain UKCA certification and hold the files for 10 years just for the small UK market.  It will be CE mark or US ANSI or forget it.
 

It will wipe out all sorts of our industries using imported components not just construction. I think / hope the delay until 2025 will mean the next government will just abandon UKCA.

 

[Momac]

6 hours ago, Alan de Enfield said:

 

There is a difference between "making available" and "placing on the market"

 

 

11) ‘making available on the market’ means any supply of a product for distribution, consumption or use on the Union market in the course of a commercial activity, whether in return for payment or free of charge;

12) ‘placing on the market’ means the first making available of a product on the Union market

Any reference to the union market is no longer relevant as far as sales of used boats already legally  in the uK and not for export are concerned.

Edited December 25, 2022 by MartynG

[Alan de Enfield]

40 minutes ago, MartynG said:

Any reference to the union market is no longer relevant as far as sales of used boats already legally  in the uK and not for export are concerned.

 

The RCR (UK) regulations are currently identical to the RCD (EU) and until they are updated they continue to retain the references to 'the Union'.

 

There has been a 'guidance update' with some new terms issued in November 2022, but the actual RCR 'regulation' (as written and in force) remain the 2017 version.

Edited December 25, 2022 by Alan de Enfield

[MtB]

Long in the past I bought a boat that should have had a RCD but didn't.

 

Firstly, I've still not been arrested and put in prison but I worry every time I hear a door knock.

 

But the point is that I decided to RCD it myself and on contacting the shell builder (a medium sized volume builder) for an Annex III declaration, he point blank refused and actually told me to "Fuck off, I'm not signing nothing" on the phone when I proposed printing one out myself for him to authorise. 

 

So rather annoyed, I made a formal complaint to Trading Standards, who told me the same but more politely. Nice chap at TS told me they had "far bigger fish to fry" than some no-mark boat builder flouting the law over RCD, and they definitely would not be taking any action over it.

[Momac]

Alan

For the avoidance of doubt are you suggesting that all used boats  already legally in the UK must comply with the RCR at the point they are sold , even if they are to remain in the UK after the sale?

[MtB]

This is why I'm so scathing about RCD.  Even when TS were presented with a simple slam-dunk win under the regs, they refused to take action saying it was all too trivial. 

[Alan de Enfield]

35 minutes ago, MartynG said:

Alan

For the avoidance of doubt are you suggesting that all used boats  already legally in the UK must comply with the RCR at the point they are sold , even if they are to remain in the UK after the sale?

 

Yes - any boat in the UK that was subject to either the RCD or RCR when it was built and is legally in the UK, is subject to having the correct RCD / RCR paperwork (certification it still complies) if it is sold in the UK.

As already explained several times in this thread.

 

Before making a product available on the market, distributors shall verify that the product bears the CE marking, as referred to in section 17, that it is accompanied by the documents required in section 7(7), section 15 and point 2.5 of Part A of Annex I, point 4 of Part B of Annex I and point 2 of Part C of Annex I a

 

Definition of a distributor :

‘distributor’ means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the market;

 

 

Any RCD built boat, legally in the UK,  does not need to be re-approved to the RCR - unless - it has had a 'Major engine modification' or a "major craft conversion" and has not had a PCA to bring the paperwork into line.

 

Its all in the RCD - all you need to do is read it.

 

Existing CE marked stock

The UK will allow CE marked products that have been either self-declared as compliant (where permissible) or where compliance must and has been demonstrated through assessment by an EU-recognised conformity assessment body (notified body) to be placed on the GB market until 31 December 2021. Products lawfully placed on the market with a CE marking by 31 December 2021 can continue to circulate on the GB market after this date.

[MtB]

On the other hand there is perhaps about one boat sale per day (my estimate) contravening the RCD (arguably). And since 1997 TS have managed four prosecutions, AFAIK. 

 

Hardly being treated seriously by the authorities, is it! 

 

 

 

 

 

 

[David Mack]

13 minutes ago, Alan de Enfield said:

 

Yes - any boat in the UK that was subject to either the RCD or RCR when it was built and is legally in the UK, is subject to having the correct RCD / RCR paperwork (certification it still complies) if it is sold in the UK.

As already explained several times in this thread.

 

Before making a product available on the market, distributors shall verify that the product bears the CE marking, as referred to in section 17, that it is accompanied by the documents required in section 7(7), section 15 and point 2.5 of Part A of Annex I, point 4 of Part B of Annex I and point 2 of Part C of Annex I a

 

Definition of a distributor :

‘distributor’ means any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes a product available on the market;

 

 

Any RCD built boat, legally in the UK,  does not need to be re-approved to the RCR - unless - it has had a 'Major engine modification' or a "major craft conversion" and has not had a PCA to bring the paperwork into line.

 

Its all in the RCD - all you need to do is read it.

 

Existing CE marked stock

The UK will allow CE marked products that have been either self-declared as compliant (where permissible) or where compliance must and has been demonstrated through assessment by an EU-recognised conformity assessment body (notified body) to be placed on the GB market until 31 December 2021. Products lawfully placed on the market with a CE marking by 31 December 2021 can continue to circulate on the GB market after this date.

Except placing a product on the GB market refers only to when it is first placed on the GB market. So used boat sales are not subject to the same requirements.

[Momac]

17 minutes ago, Alan de Enfield said:

 

Yes - any boat in the UK that was subject to either the RCD or RCR when it was built and is legally in the UK, is subject to having the correct RCD / RCR paperwork (certification it still complies) if it is sold in the UK.

As already explained several times in this thread.

 

I am possibly not understanding you .

Having the original RCD certificate is not the same as complying with the standards at the point it is  sold as a used boat say 20 years later.

Do you mean a boat  should still comply 20 years later with the standard that was in force  when it was new?

Edited December 25, 2022 by MartynG