• 2023-May-16

TALKING POINT on IBI

In May 2023, the RSG will meet under the auspices of the European Commission for its spring meeting, this time in Italy. The RSG, which consists of all Notified Bodies and other parties with valid interest, was established to support the uniform application and interpretation of the current version of the Recreational Craft Directive (RCD).
To this end, it publishes the RSG Guidelines annually, which provide extremely useful interpretations of the RCD and the ISO TC 188 standards applied within its framework, and are important for certifiers, manufacturers, and regulators.

It is really quite astonishing which topics are still on the agenda despite the RCD having been around for decades!

Here is a small selection of topics on the agenda:

• Is a marinised, former automotive engine that is installed in a boat in its second life considered a “propulsion engine built for own use”?
• Does a pedalo, which is propelled by a musclepowered generator via a connected battery and further by an electric drive via propeller, still fall under the exception “pedalo” or is this now recreational craft within the meaning of the RCD?
• Can engine rooms on catamarans be accessible only through a stern hatch or does this conflict with ISO standards?
• Is a barcode displayed directly under the watercraft identification number in compliance with the regulations?
• Is replacing a conventional lead-acid battery with a lithium battery already considered a “major watercraft conversion” under the RCD?
• Can a portable petrol tank be used below deck?
• Can a battery be considered as basically “ignition protected”?

There are also many other questions to be discussed and answered at the meeting. It is really quite astonishing which topics are still on the agenda despite the RCD having been around for decades!
The above topics may not be of a purely technical nature, but also or only of a legal nature. RSG may only deal with the technical side of the issues. Legal interpretations will therefore end up later on the table of the EU Member States, which will then discuss them separately.
Both together, however, can finally be found in the RSG Guidelines as so-called Endorsed Recommendations for Use (ERFU).

It is therefore worthwhile to follow the guidelines on www.rsg.be very closely.