RCD Update: Major Craft Conversion guidance

Since the EU’s Recreational Craft Directive (RCD) was formerly brought into UK legislation, through the Recreational Craft Regulations 2017, British Marine has been undertaking work to help clarify certain aspects of the regulations.

Most recently this work has centred on clarification on the requirements associated with Major Craft Conversion, Clause 3 – 1 (F). Here we provide an update on this work.

This work has been led by the Recreational Craft Sectoral Group (RSG), which is composed of a number of interested stakeholders i.e. notified bodies, representatives of the European Commission, members of the recreational craft industry, user organisations and European standards bodies.

This group was established to assist in the uniform application and interpretation of the RCD by all notified bodies and other parties with a valid interest, such as national enforcement agencies (e.g. our own Trading Standards).

The group publishes an annual guidance document that offers interpretations to all areas of the RCD in which there may be points of difficulty, to propose possible solutions and agree on a common solution.

At the end of September, the RSG met in Italy for a 3-day discussion, where there was considerable discussion regarding the definition and interpretation of ‘Major Craft Conversion’.

The Group came to the following conclusions:
If the RCD defines a ‘major’ conversion then there must be such a thing as a ‘minor’ conversion. In which case, it cannot be true that ANY change constitutes a major craft conversion

If a recreational craft (having been put on the market/into service) is outside the scope of the RCD, then no modification can bring it into the scope. (i.e. a pre-RCD boat need not be brought into scope by a modification)

The person responsible for putting the modified boat back into service/on the market is responsible for the decision about whether the modification is major or minor

The decision as to whether the modification is major/minor shall be based upon a risk assessment 

Further discussions on this subject will be had and we will update all members as they progress and further conclusions are agreed.

At this stage, we must highlight that should a craft undergo a modification or change, it is important to carry out an assessment to ascertain if the conformity of the vessel with any of the 32 essential requirements that make up the RCD has changed, and if so contact a notified body to discuss the ramifications.

If you have any questions about the RCD or would like to know more about British Marine’s work in this area, please contact Simon Vayro at: svayro@britishmarine.co.uk