Following the release of the UK – EU Trade and Cooperation Agreement, British Marine and the Royal Yachting Association (RYA) have been working to understand the impact of various aspects of the agreement on both the marine industry and recreational boat owners.
It’s not good news. ‘Post construction assessments’ will be needed to sell pre-owned CE marked recreational craft to the EU and vice versa. The assessments say a joint statement, are going to cost owners between £500-5000 (dependent on the vessel).
As Howard Pridding, RYA director of external affairs, says: “This is yet another unanticipated and unwelcome aspect of Brexit which could affect many owners financially through no fault of their own. We are working in partnership with industry to better understand and mitigate the situation and potential cost burden.”
British Marine and the RYA say the new information comes from the EU Commission and the UK Department for Business, Energy and Industrial Strategy (BEIS). It focuses on the trade of pre-owned CE marked recreational craft between the UK and EU following the UK’s exit from the European Union.
Both the UK and EU have confirmed that any vessel being traded second-hand between the UK and EU will be required to meet the obligations set out in either the Recreational Craft Directive (RCD) in the EU, or the Recreational Craft Regulations (RCR) in the UK, when placed on either market after the 1 January 2021.
Therefore, this means that a pre-owned vessel being imported from the EU to be placed on the UK market will, after 1 January 2022, be required to obtain a new UK Conformity Assessed (UKCA) mark in line with the requirements of the RCR. In order to obtain a UKCA mark, a boat will require a post construction assessment and third-party verification.
Similar rules will apply when selling vessels into the EU. Pre-owned CE marked vessels which were in the UK at the time of departure, 11pm on the 31 December 2020, when exported to the EU will be required to undergo a recertification of the CE mark when being placed on the EU market. This means a boat will require a post construction assessment in line with the RCD and third-party verification.
Boat brokerages, distributors, boat owners and buyers may well be heavily affected by this post-Brexit position, as the responsibility will fall upon them to ensure a vessel meets the applicable requirements before buying and selling second-hand boats between the UK and EU. Estimated costs of post construction assessments and verification are between £500-5000 dependent on the vessel.
British Marine and the RYA are currently liaising with the European Boating Industry association in order to raise concerns with this position in Europe whilst also directly engaging with BEIS in the UK.
“As a consequence of Brexit, this is a complex and potentially difficult situation,” says Lesley Robinson, CEO of British Marine. “Faced with the process of individual boat re-certification, boat builders, brokers and consumers will be impacted in terms of both time and cost when selling and buying second-hand boats cross borders. At this stage in time, British Marine is working hard to represent affected members and seek clarification of the exact ramifications of these regulations.”
