• 2020-Jan-27

TALKING POINT on IBI

My sailboat is definitely too small for an air conditioner. Besides, I wouldn’t have enough power in the electrical system to operate it.
Because the watercraft was built in 1975, it needs neither a CE mark nor a Declaration of Conformity (DoC).
However, what is the situation for watercraft covered by the Recreational Craft Directive (RCD)?
For many years, air conditioning systems, depending on their layout, have fallen under one or more EU directives, e.g.:
• 2014/35/EU – Low Voltage Directive
• 2006/42/EC – Machinery Directive
• 2014/68/EU – Pressure Equipment Directive
• 2014/30/EU – Electromagnetic Compatibility Directive
• 2011/65/EU – Restriction of Use of Certain Hazardous Substances in Electrical and Electronic Equipment Directive 
Each of these directives requires the CE marking of the device after certification and the issuance of a DoC.
Well, that’s settled, but what does that have to do with watercraft and their DoCs?
The RCD requires in Annex IV that all relevant harmonisation requirements of the Union have been complied with and are listed on the vehicle’s DoC. If an air conditioning system is installed, this must be therefore indicated on the DoC of the craft when bought to the market!
The market surveillance authorities of the EU agreed in June 2016 already on a specimen DoC, which has an extra (but indeed too short) line for it.
It should be filled out!