RCD Module B certification for commercial vessels
Vessels used exclusively for commercial purposes are excluded from the Recreational Craft Directive requirements.
However, there are occasions when commercial vessels are also used for recreation. These do fall within the scope of the regulations.
There are also cases where a vessel once used for commercial purposes is used for recreation in the future. At this point, it will need to be compliant with the RCD requirements for use in the EU, including the UK.
If you have a vessel that is (or may be) used for both recreational and commercial purposes, we can use the Recreational Craft Directive Module B as a route to demonstrate structural compliance.
This gives manufacturers and importers peace of mind that every eventuality is covered. It can also help you cut certification duplication and costs.
Are commercial craft always exempt from CE marking?
One of the most common questions we’re asked is “are commercial boats exempt from the RCD?”
The answer is not always straightforward.
The RCD state:
- The following shall be excluded from the scope of these Regulations/Directive: …… craft specifically intended to be crewed and to carry passengers for commercial purposes.
As a result, many people assume all craft being used for “commercial purposes” are excluded. But the EU Commission’s guidance document on the RCD also states:
- Chartered, i.e. hired, recreational craft are covered by the Directive, as are recreational craft used for recreational boating training. In both cases, the activity is not a commercial passenger transport activity but one for sports or leisure purposes, even if the craft is hired with crew.
This means that a boat is not excluded simply because money is exchanging hands for the use of the boat. Further, it is not necessarily exempt if there is a paid crew on board the hired craft.
The key is to focus on the use of the boat. If it is clearly being used for recreation, ie simply for the pleasure of passing some time afloat, then it is in scope. This is regardless of money or crew. If the hired boat is being used only as a mode of transport, or for racing, then it is excluded. Note also that education/training is not excluded if it relates to using the craft recreationally.
A boat is NOT exempt from RCD because it has approval as a commercial vessel
If a commercial boat, which has been excluded from RCD, is sold into the recreational market later in its life it will need to be CE (or UKCA) marked at this stage.
The commercial and CE marking regimes overlap. We help boat builders to save costs by dealing with both at the outset to avoid duplication.
Getting commercial and recreational approvals at the same time also helps to reassure potential buyers that the vessel is future-proof.