What is the Recreational Craft Directive (RCD)?
The Recreational Craft Directive (RCD) is the key legislation governing the safety and environmental performance of boats within the UK and the EU. Introduced to ensure a consistent standard across all member states, it applies to most recreational boats, personal watercraft, and even some sailaways used on inland waterways.

In simple terms, if you’re building, buying, or selling a boat in the UK or EU, the RCD is your guiding star. It sets the rules for everything from hull construction and stability to engine emissions and electrical systems. Think of it as the foundation for ensuring that every boat on the water is safe, reliable, and environmentally sound.

Who Needs to Comply with the RCD?
If you’re a manufacturer, importer, or even a private boat builder, the RCD applies to you. Whether you’re buying a brand-new boat, importing one from overseas, or fitting out a sailaway yourself, the boat must meet RCD standards before it can be legally placed on the market or put into service.

What Does Compliance Look Like?
Compliance with the RCD means that your boat will need to be CE marked (or UKCA marked for the UK), confirming that it meets all relevant safety and environmental standards. You’ll also need to have a Declaration of Conformity, which acts as a guarantee that the boat meets the required standards. For those of you building your own boats, there’s the option of a Post Construction Assessment (PCA) to ensure everything’s shipshape.

By following the RCD, you’re not just ticking boxes – you’re ensuring that your boat is safe, legally compliant, and future-proofed for resale.

Navigating UK Inland Waterway Regulations: CE Marking, Sailaways, and Post Construction Assessments Explained

It’s no secret that there’s a lot of confusion when it comes to interpreting the UK Recreational Craft Regulations (RCR) and the EU Recreational Craft Directive (RCD) – especially when it comes to sailaways and owner-built boats navigating the UK’s inland waterways. Many boats are out there without the conformity documents they should have, leaving owners scratching their heads.

We’re here to shed some light on it all – no more guesswork, just straightforward info.

The Basics: What You Need to Know
Let’s start with some facts everyone agrees on. If your boat is not specifically exempt from the regulations, it must comply with them. That means whether you’re putting it up for sale or taking it out on the water for the first time – whichever happens first – it has to meet the required standards.

And no, CE or UKCA marking isn’t optional. Claiming your boat meets a standard when it doesn’t is misrepresentation, and worse – it could even be seen as fraud.

Sailaways – Stretching the Rules?

What Is a Sailaway?
A sailaway is a boat that’s not fully complete, but still capable of navigating. It’s ready for you to sail, but not yet kitted out for everything you’ve got in mind.

Early Days of Sailaways
Back when the RCD was first introduced in 1996, the UK inland boating world decided that sailaways weren’t yet considered “recreational craft,” meaning they didn’t need a CE mark. It was then up to the owners who completed the boats to become the “manufacturer.” They could claim an exemption under this clause:

“Craft built for own use, provided they are not placed on the Community market for five years.”

So, for a while, it was accepted that if you finished your sailaway and held onto it for five years, you could skip the regulations.

Trading Standards Stepping In
Fast forward a few years, and Trading Standards started noticing something wasn’t adding up. There were boats navigating the waterways without any kind of conformity, including critical systems like fuel and electrics. They eventually ruled that any navigable boat was, by definition, a recreational craft and required compliance. The idea that a sailaway could be excluded was, as they put it, a figment of the inland boating industry’s imagination.

Partly Complete vs. Complete
Some in the industry tried to defend their position, pointing to RCD’s Annex III, which talks about compliance for boats that are handed over between manufacturers in a “partly complete” state. This required an Annex III declaration, confirming what had been done and which standards were applied – but not a CE mark.

Trading Standards disagreed. In their view, if the boat can be sailed, it’s “in service,” meaning it needs a full CE mark, and any additional work counts as modifying an existing boat. If you’re making major changes after sailing away, you’ll need to apply for Post Construction Assessment (PCA).

How Did the Industry Respond?
Manufacturers of sailaways took different approaches, with some providing an Annex III declaration, others offering a full Declaration of Conformity, and some skipping compliance altogether. Now, we’re left with a second-hand market full of boats that aren’t necessarily playing by the same rulebook.

Clearer Guidance from the EU Commission
The EU Commission cleared things up when it issued its RCD ‘application guide’. They stated that boats built for personal use must have been “substantially built by their future user,” and kit boats can’t be excluded under this exemption.

In short, if a pile of materials (a kit) can’t be excluded, a sailaway with an engine, fuel systems, and steering certainly can’t either. The message was clear: sailaways need a CE mark and a full Declaration of Conformity.

What About Non-Compliant Boats?
If you’ve got a boat that’s not compliant, it’s not the end of the world. While there’s sympathy for owners who thought they were following the rules, the only option now is to go through PCA and get that CE or UKCA mark in place.

Who’s Responsible?
If you bought a sailaway, it’s the seller’s job to have CE marked the boat. Once you start making modifications – adding on your customisations – you’ll need to get a PCA to cover the work you’ve done.

Brokers and surveyors don’t carry the responsibility for ensuring a boat’s compliance. Their role is to inform buyers and sellers of what they reasonably should know, but they’re not expected to be compliance experts.

The Costs of Compliance
Here’s the good news: PCA isn’t as scary as you might think. If your sailaway was already CE marked by the original manufacturer, the PCA will only focus on the modifications you’ve made. This reduces both the cost and time involved. Plus, a boat with certification is worth more, making it easier to sell.

The Bottom Line
Though things have shifted over time, the law itself hasn’t. It’s straightforward: either your boat was genuinely built for personal use and can be excluded, or it needs to go through PCA. No grey areas.

It is essential if you are buying a new narrowboat or a used narrowboat (that was not already in use in the EU on June 16th 1998) you understand the requirements of the RCD. If a narrowboat does not comply it may be impossible to use, insure or sell. You need to look out for the following:

• A builders plate – makers details and technical information
• A CE mark
• A Watercraft Identification Number (or previously CIN or HIN) – it is carried in two places on the boat; one should be hidden for security.
• An owners manual with information needed to use and maintain the boat safety
• A declaration of conformity (DoC)

CE marking is complex and a number of strict criteria have to be adhered to. Importantly the CE plate will have a hull identification number which is then registered with the Canal and River Trust for licensing purposes.

RCD is not only applicable to narrow boat builders, but also to anyone buying a sailaway narrow boat or completing a self build. There are special requirements for these type of boats.

New Regulations January 2017

As of 18th January 2017 canal boat builders will not be able to issue Annex lll(a) Declaration of Conformities for part-completed craft. A narrow boat sailaway must be sold CE marked with a full DofC. Canal boat shells sold to a professional boat builder for completion have to carry an Annex lll DofC. Further details of the changes can be found in the following section.

Exceptions

An eligible boat can only be exempt from the RCD requirements if its classed as a ‘home build’. This is a hull or sailaway that is completed by an individual who then keeps it for their private use for a minimum of 5 years (from when the boat is first used on the water). However, the narrowboat would still require a BSS certificate.

If you are buying a used self build narrow boat, you must ask for proof of the 5 year ownership including BSS certificates, licences, mooring invoices etc.