HIN

[Midnight]

Prompted by another thread. 

I don't think Midnight has a HIN certainly no obvious builder's plate.
Built by John White in 2002, but because of delays with extras wasn't delivered until 2003 as a 57ft shell. We spent a year fitting out on dry land before dropping it in the water and registering with British Waterays in August 2004. Never thought about a HIN until looking at the thread in General Boating about a reg number. Before I took delivery John White arranged for the shell to be spray-foamed so it's possible the plate is somewhere but covered with the insulation.  It's also possible I just forgot seeing it as it is 20 years since the fit out was done. Would I have needed to have it when regestering for the first license? There's no mention of HIN on the My Trust page.
Is anyone familiar with John White boats who could give me an idea of where to look?

 

[MtB]

If you were the customer buying the shell new, did he write in on the invoice?

 

 

[Midnight]

22 minutes ago, MtB said:

If you were the customer buying the shell new, did he write in on the invoice?

 

 

Invoice? I was lucky to get the shell never got an invoice

[MtB]

24 minutes ago, Midnight said:

Invoice? I was lucky to get the shell never got an invoice

 

Ah, maybe you as "the builder" (under the terms of the RCD) can allocate it your own HIN.

 

 

[Alan de Enfield]

1 hour ago, Midnight said:

Is anyone familiar with John White boats who could give me an idea of where to look?

 

 

If you bought it as a sailaway, did you get the RCD approval to the stage it was sold at ?

 

 

A boat (built to RCD compliance) must have the HIN / CIN marked in two places, the RCD specifies the 'public place' and the other should be in a hidden location only known to the hull builder.

From memory the 'public' HIN / CIN must be made so it is incapable of being removed (ie stamped into the hull) at the stern on the starboard side. Typically it should be on the 'outside' of the boat, but I have known of them 'inside' the transom.

 

The builder should be able to provide you with the HIN from their records (I don't think they are supposed to divulge the hidden location as you could have stolen the boat and tamper with the marking).

 

 

The HIN should also be specified on the Bill of Sale, the Declaration of Compliance and in the Owners manual.

 

Example of the HIN on the Declaration of Compliance (under technical data)

 

 

 

 

The format should be :

 

 

 

 

 

Edited November 29, 2023 by Alan de Enfield

[MtB]

Next, Midnight will be telling us his boat isn't RCD certificated! 

 

<Shock horror>

 

 

[Alan de Enfield]

2 minutes ago, MtB said:

Next, Midnight will be telling us his boat isn't RCD certificated! 

 

<Shock horror>

 

 

 

It sounds like it may not be - <shock horror> 

[MtB]

4 minutes ago, Alan de Enfield said:

 

It sounds like it may not be - <shock horror> 

 

He's gorn awfully quiet, do you think he's been arrested and executed to death? 

 

 

[Midnight]

6 hours ago, MtB said:

 

He's gorn awfully quiet, do you think he's been arrested and executed to death? 

 

 

Sorry I'm in British Columbia so on different time. When the shell was being built John White, an honourable chap, had a stroke. His manager wasn't so honourable. I paid for extras that didn't materialise until it all got a bit acrimonious. I eventually got the shell after sorting my own transport, but received nothing else. The company ceased trading years ago. Maybe I need to sort out my own HIN etc. I'll have to look into it. I'm not thinking of selling, but maybe it needs sorting for the future.

[Tony Brooks]

6 hours ago, Midnight said:

Sorry I'm in British Columbia so on different time. When the shell was being built John White, an honourable chap, had a stroke. His manager wasn't so honourable. I paid for extras that didn't materialise until it all got a bit acrimonious. I eventually got the shell after sorting my own transport, but received nothing else. The company ceased trading years ago. Maybe I need to sort out my own HIN etc. I'll have to look into it. I'm not thinking of selling, but maybe it needs sorting for the future.

 

I fear that you may need a Post Construction RCR/RCD Assessment, and that needs far more than a HIN. Practically, as long as you will be happy for an eventual private sale I doubt not having a HIN or a RCD will matter a jot.

[matty40s]

3 hours ago, Tony Brooks said:

 

I fear that you may need a Post Construction RCR/RCD Assessment, and that needs far more than a HIN. Practically, as long as you will be happy for an eventual private sale I doubt not having a HIN or a RCD will matter a jot.

Unfortunately John, that view is not shared by the senior Brokerages hierarchy, who are now trying to insist everything from 1998 that should be in place, IS in place by all member brokerages.

[Tony Brooks]

12 minutes ago, matty40s said:

Unfortunately John, that view is not shared by the senior Brokerages hierarchy, who are now trying to insist everything from 1998 that should be in place, IS in place by all member brokerages.

 

I don't doubt that, we have had sufficient reports that some like to poo poo.

 

You will note that I specifically said "Practically, as long as you will be happy for an eventual private sale I doubt not having a HIN or a RCD will matter a jot. " I emphasize PRIVATE sale, how many private sellers have been prosecuted for not having an RCD/RCR to date? what reasons do you have to believe this will alter in the foreseeable future?

[Alan de Enfield]

2 minutes ago, matty40s said:

Unfortunately John, that view is not shared by the senior Brokerages hierarchy, who are now trying to insist everything from 1998 that should be in place, IS in place by all member brokerages.

 

 

I hear the same from the coastal brokers and is certainly quite strongly enforced.

 

Mind you there are members on here that'll tell you you are wrong and it cannot be enforced. But, it is easy enough for all brokers en masse to say "no RCD/RCR paperwork, no sale".

Brokers are part of the supply chain and I have argued for some time that they are required to ensure RCD/RCR compliance.

 

Extract:

The only question being "do Brokers make the product available on the market?"

I believe that Brokers have decided that they do, hence this new purge on RCD ? RCR paperwork.

 

3.4 Distributor’s obligations The distributor is any natural or legal person in the supply chain, other than the manufacturer or the importer, who makes the product available on the market. Distributors have a key role to play in the context of market surveillance. A distributor must act with due care and their obligations are detailed in Article 10 of the Directive. Before making a product available on the market, the distributor must verify that:

• The product bears the CE marking as required in Article 17

• It is accompanied by the following documents: EU Declaration of Conformity, instructions and safety information, the owner’s manual in the appropriate language for the craft and the engines if installed

• It meets the product identification and traceability requirements, the manufacturer’s identification or the importer’s identification if applicable Where the distributor has reason to believe that a product is not in conformity, he must not make the product available on the market until it has been brought into conformity. Where the product presents a risk, the distributor must inform the manufacturer or the importer as well as the relevant market surveillance authorities

 

If your boat is not compliant then you either have a PCA or it just leaves private sales via Gumtree, Apolo Duck etc.

 

 

The BMF (of which many inland brokers are members) state :

Members shall comply fully with all statutory and regulatory requirements applicable to their business, products and services, including but not limited to all safety regulations; in particular with regard to the requirement to certificate (CE mark) craft in accordance with the Recreational Craft Directive 2003/44/EC as amended from time to time.

 

The ABYA (of which some inland brokers are members) state :

The Member should ascertain and, if possible, obtain at an early stage from the vendor the documentation he has available to prove title, compliance with the RCD (if relevant)..........................

 

[David Mack]

The RCR places obligations on those who "make (a craft) available on the market" and those who "place (a craft) on the market", the latter being defined as when a craft is first offered for sale by the manufacturer, importer or distributor. 

The distributor options apply to "making available", so this would appear to cover both new and second hand boat sales, whereas the obligations on manufacturers and importers only apply to "placing" I.e. new (or newly imported) craft.

“placing on the market” means the 

Edited November 30, 2023 by David Mack

[Alan de Enfield]

1 hour ago, David Mack said:

The RCR places obligations on those who "make (a craft) available on the market" and those who "place (a craft) on the market", the latter being defined as when a craft is first offered for sale by the manufacturer, importer or distributor. 

The distributor options apply to "making available", so this would appear to cover both new and second hand boat sales, whereas the obligations on manufacturers and importers only apply to "placing" I.e. new (or newly imported) craft.

“placing on the market” means the 

 

Since 2017 there is an additional category :

While the “old” Directive considered the action of “placing on the market and/or putting into service”, the new Directive broadens the scope to the action of “making available”. All three concepts are now defined by the Directive. A product is made available on the market when supplied for distribution, consumption or use in the course of a commercial activity, whether in return for payment or free of charge.

 

It is most certainly this definition that brokers would fall into, as by advertising the boat they are 'making it available' for purchase, they are a commercial activity, they charge for their services.

[Midnight]

12 hours ago, Tony Brooks said:

 

I fear that you may need a Post Construction RCR/RCD Assessment, and that needs far more than a HIN. Practically, as long as you will be happy for an eventual private sale I doubt not having a HIN or a RCD will matter a jot.

 

It's 20 years since Midnight was craned into the water so I was thinking of getting a survey next year, and of course the BSS is also due again. I will ask the surveyor who has done every BSS since 2008 about a Post Construction Assessment. I do have all the fit out drawings and photo's of each stage. As I'm in no hurry to sell and would probably use Apollo Duck if I did, I'm not too concerned right now. Of course being 73 doesn't help so depending on cost I'll probably go for it.

[Alan de Enfield]

8 minutes ago, Midnight said:

I will ask the surveyor who has done every BSS since 2008 about a Post Construction Assessment.

 

Only RCD / RCR approved surveyors can do a PCA. It has to be someone with a detailed knowledge of the RCD / RCR and who can look behind closed doors wall panels and floor boards, as you don't have the Annex IIIA documents from the Hull builder the details of the Hull design, steel used, stringers, hull structural drawings etc need to be evaluated as strong enough etc etc etc.

You need to submit your request for a PCA to the 'notified body'.

 

You need to write the Technical manual 

 

Your 'run of the mill' BSS examiner is unlikely to be sufficiently qualified.

 

 

The person who places the product on the market and/or puts it into service must apply to a notified body to conduct the conformity assessment by examining the 120 individual product and its documentation. This person should submit to a notified body all the documents and information (including the information on the use of product) which ensure assessment of conformity of the product to the Directive. However, the technical documentation is required in case of private imports (as stated in Article 12 of the Directive). The technical documentation shall be obtained either from the original manufacturer or drawn up by private importer using appropriate expertise. Private importer may have it drawn up by a technical expert. Copy of the technical documentation or available technical file that has been submitted to the notified body for the PCA assessment, has to be kept by the person who is placing such a product on the market or putting it into service at the disposal of the national authorities. Where the content of the technical documentation is described in Annex IX of the Directive, the technical file required to be demonstrated by persons described in Article 19(3) and 19(4) of the Directive should incorporate all the available documents referring to the product’s first placing on the market or putting into service. These documents may include ownership papers, the manufacturer’s certificate, surveyors’ reports, the boat’s original owner’s manual, engine and other component manuals, specifications, drawings, stability booklet etc.

 

I'd suggest that after 20 years you are going to be in an impossible situation having to remember all the details (wire size, gas pipe sizes etc etc) or have the original manuals for the appliances.

 

A PCA will cost you around £3000 and that is assuming that everything is compliant, if anything 'fails' then it could involve a rebuild.

 

I have a booklet (283 pages) entitled "For general application of the conformity assessment procedures by Notified Bodies and Manufacturers" you are welcome to a copy.

 

I'd keep it as it is, when you come to sell it if there is any kick-back you can either make a decision at that time to have a PCA or try and sell it as a private sale and maybe give them a 'price they cannot refuse'.

 

Good luck either way.

[Momac]

 

Surely none of this is necessary.

As a  self build it is exempt from RCD providing it is not sold  within 5 years. As the boat is 20 years old there is no requirement now to do anything.

As the boat has a BSS then that's all good.

[Alan de Enfield]

24 minutes ago, MartynG said:

 

Surely none of this is necessary.

As a  self build it is exempt from RCD providing it is not sold  within 5 years. As the boat is 20 years old there is no requirement now to do anything.

As the boat has a BSS then that's all good.

 

The RCD / RCR is now for the life of the boat, the '5 year thing' is (apparently) no longer accepted. 

Brokers are refusing DIY builds/fitouts without a compliance certificate or PCA and there have been a couple of threads on here from folks trying to sell and have been refused.

 

There was also someone selling a self fit out on ebay and it was withdrawn from sale. (I had registered an interest and she kept me up to date with developments) she told me she was contacted by the BMF and told she could not sell it without a PCA which she agreed to have done at an estimated cost of £2000 + any work that needed doing to achieve compliance.

[Midnight]

1 hour ago, Alan de Enfield said:

 

Only RCD / RCR approved surveyors can do a PCA. It has to be someone with a detailed knowledge of the RCD / RCR and who can look behind closed doors wall panels and floor boards, as you don't have the Annex IIIA documents from the Hull builder the details of the Hull design, steel used, stringers, hull structural drawings etc need to be evaluated as strong enough etc etc etc.

You need to submit your request for a PCA to the 'notified body'.

 

You need to write the Technical manual 

 

Your 'run of the mill' BSS examiner is unlikely to be sufficiently qualified.

 

 

The person who places the product on the market and/or puts it into service must apply to a notified body to conduct the conformity assessment by examining the 120 individual product and its documentation. This person should submit to a notified body all the documents and information (including the information on the use of product) which ensure assessment of conformity of the product to the Directive. However, the technical documentation is required in case of private imports (as stated in Article 12 of the Directive). The technical documentation shall be obtained either from the original manufacturer or drawn up by private importer using appropriate expertise. Private importer may have it drawn up by a technical expert. Copy of the technical documentation or available technical file that has been submitted to the notified body for the PCA assessment, has to be kept by the person who is placing such a product on the market or putting it into service at the disposal of the national authorities. Where the content of the technical documentation is described in Annex IX of the Directive, the technical file required to be demonstrated by persons described in Article 19(3) and 19(4) of the Directive should incorporate all the available documents referring to the product’s first placing on the market or putting into service. These documents may include ownership papers, the manufacturer’s certificate, surveyors’ reports, the boat’s original owner’s manual, engine and other component manuals, specifications, drawings, stability booklet etc.

 

I'd suggest that after 20 years you are going to be in an impossible situation having to remember all the details (wire size, gas pipe sizes etc etc) or have the original manuals for the appliances.

 

A PCA will cost you around £3000 and that is assuming that everything is compliant, if anything 'fails' then it could involve a rebuild.

 

I have a booklet (283 pages) entitled "For general application of the conformity assessment procedures by Notified Bodies and Manufacturers" you are welcome to a copy.

 

I'd keep it as it is, when you come to sell it if there is any kick-back you can either make a decision at that time to have a PCA or try and sell it as a private sale and maybe give them a 'price they cannot refuse'.

 

Good luck either way.

 

 

I think my surveyor may be qualified (MIIMS, MABSE, RMS, DipMarSur(YS)) and fortunately I do have the appliance and electrical equipment manuals. As the wiring was done by Loomtech I also have the wiring specs. The gas pipework was DIY and checked off by a Corgi registered surveyor in 2004. I'm sure it was 3/8" but it's accessible under the well deck gunwhale if it needs checking. The structural stuff may be a problem as I received no paperwork at all from John White. If the technical spec requires the fit-out details and sizes I can write a fairly detailed spec from memory. Around £2000 isn't a deal breaker when it comes to selling. With crossing the Wash in mind I had a professional valuation earlier this year at £60,000 for insurance purposes.

[Alan de Enfield]

7 minutes ago, Midnight said:

 

 

I think my surveyor may be qualified (MIIMS, MABSE, RMS, DipMarSur(YS)) and fortunately I do have the appliance and electrical equipment manuals. As the wiring was done by Loomtech I also have the wiring specs. The gas pipework was DIY and checked off by a Corgi registered surveyor in 2004. I'm sure it was 3/8" but it's accessible under the well deck gunwhale if it needs checking. The structural stuff may be a problem as I received no paperwork at all from John White. If the technical spec requires the fit-out details and sizes I can write a fairly detailed spec from memory. Around £2000 isn't a deal breaker when it comes to selling. With crossing the Wash in mind I had a professional valuation earlier this year at £60,000 for insurance purposes.

 

That's not so bad then. And, whatever you decide I hope it goes thru smoothly for you.

 

The 'Notified Body' chooses the surveyor from their list. He may well be on it, but I don't think you get any say in who they use.

 

If you go ahead with a PCA your experiences may make a very useful post / record for any others who find themselves in a similar position.

[Midnight]

17 minutes ago, Alan de Enfield said:

 

That's not so bad then. And, whatever you decide I hope it goes thru smoothly for you.

 

The 'Notified Body' chooses the surveyor from their list. He may well be on it, but I don't think you get any say in who they use.

 

If you go ahead with a PCA your experiences may make a very useful post / record for any others who find themselves in a similar position.

 

I will be contacting the surveyor early in the new year regarding the BSS and mention the situation. i also have a close friend who is a boat builder so may be able to get some advice there.

 

[Momac]

How can anyone say that any used boat is in the same condition as it should be if it was built new today. I believe a  PCA is  assessed to standards on the day of the assessment and not assessed  taking account of standards at the time the boat was constructed. (Do let me know if that is not correct).

 

Especially a problem for a 20 year old boat.

eg. A 20 year old boat is unlikely to pass an emissions test required for a new boat.

 

This requirement has , since Brexit,  killed off the import of used boats into the UK. So naturally  enough it will be equally impossible without expensive modification  to achieve a PCA pass in the boat that is the subject of this post.

 

The only possibility of a used boat passing a PCA without modification would be a nearly new boat that has not fallen behind current standards in any relevant way due to the passage of time.   Or an older boat that has been fitted with a new engine with emissions to current standards.

 

 

 

 

 

[Alan de Enfield]

7 minutes ago, Midnight said:

I will be contacting the surveyor early in the new year regarding the BSS and mention the situation. i also have a close friend who is a boat builder so may be able to get some advice there.

 

Maybe the advice will be 'don't worry about it, see what happens if you decide to sell' who knows, things may have changed by then and the RCR has been scrapped

 

 

 

4 minutes ago, MartynG said:

How can anyone say that any used boat is in the same condition as it should be if it was built new today. I believe a  PCA is  assessed to standards on the day of the assessment and not assessed  taking account of standards at the time the boat was constructed. (Do let me know if that is not correct).

 

 

Is a 20 year old car tested to the MOT standards of 20 years ago, or is it tested to todays standards ?

Edited November 30, 2023 by Alan de Enfield

[Momac]

4 minutes ago, Alan de Enfield said:

 

Is a 20 year old car tested to the MOT standards of 20 years ago, or is it tested to todays standards ?

It is tested to the standards in place at the time it was built.

 

But we are not talking about MOT's on cars .