TALKING POINT on IBI
Non-certified products – Is the existing certificate still valid?All watercraft and all components listed under Annex II of the Recreational Craft Directive (RCD) are placed on the market in the EU with an individual Declaration of Conformity (DOC) and must bear a corresponding conformity mark. The same applies to the UK, but here with reference to the Recreational Craft Regulations 2017 (RCR).
In most cases, these products are certified in accordance with Module B after passing an assessment by an EU Notified Body (Approved Body in the UK). The manufacturer receives the CE certificate (UKCA certificate in GB) for his type from the certifier, which he guards with great care.
The manufacturer in turn issues a DOC for each product delivered, which establishes a link between the individual product and the type certificate and confirms their equality. The content of the certificate is mirrored by each individual DOC.
Now, however, the manufacturer wants to change the type, whether significantly or not. The wish to change is triggered, for example, by a model update or a customer request.
According to EU Decision No. 768/2008/EC, Module B, Paragraph 7, in this case the manufacturer is basically obliged to inform his certifier of this change, so that both can find out together whether the type has to be completely, partially or not at all re-assessed. If he does not do this, he runs the risk that his modified type may no longer be covered by the existing certification and that he will bring noncertified products onto the market!
Here are only a few examples below of planned changes to a type:
You should consult your certifier before making any changes.
