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Wrong HIN number advice


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8 hours ago, David Mack said:

Without a valid HIN number and RCD paperwork you won't be able to export the boat to another EU country, register it on the Small Ships Register or take out a marine mortgage on it

You don't need an RCD to register it on small ships register (SSR)

I have registered my cruiser without any paperwork or a HIN number.

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1 hour ago, WotEver said:

And did they say that they issue the HIN as claimed above (which I doubt) or did they say the builder issues it?

I can tell you that the builder makes it up and issues it. I fitted a new shell in 99/2000 when the new-fangled EU crap came in to being and I did it to rcd standard with all relevant paperwork guided by and overseen by a marine surveyer. I was registered as the " Boatbuilder " and issued the number.

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43 minutes ago, mrsmelly said:

I can tell you that the builder makes it up and issues it. I fitted a new shell in 99/2000 when the new-fangled EU crap came in to being and I did it to rcd standard with all relevant paperwork guided by and overseen by a marine surveyer. I was registered as the " Boatbuilder " and issued the number.

Xactly as I thought.  

The hull builder and the boat builder are not the same 'person'. This is prolly where the confusion lies. The boat builder issues the HIN 

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50 minutes ago, mrsmelly said:

I can tell you that the builder makes it up and issues it. I fitted a new shell in 99/2000 when the new-fangled EU crap came in to being and I did it to rcd standard with all relevant paperwork guided by and overseen by a marine surveyer. I was registered as the " Boatbuilder " and issued the number.

Thanks, I thought the claim that "The RYA issues them" was rubbish. 

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5 hours ago, Phil Ambrose said:

Are you right about the SSR? Our last boat was registered but had no HIN or RCD and we never had any issues at all when we sold it on brokerage.

Phil 

Not absolutely sure to be honest. I was trying to make the point that a lack of HIN has few practical consequences.

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Some RCD advice here

http://www.rya.org.uk/knowledge-advice/legal/buying-a-boat/Pages/recreational-craft-directive.aspx

http://www.boatshedsupport.com/article/128-recreational-craft-directive-rcd

If a boat was built since June 1998 and sold as complete boat , not a self build , it is required to have a CE plate and certificate of conformity.

If the boat was a  self build and not sold until after it was 5 years old it would be exempt from the recreational craft directive.

Presumably the boat in question has a  Boat Safety Certificate . How the BSS certificate  has been issued without having a CE plate  is a matter of concern. A non CE compliant craft never gains legality through the passing of time. 

Unless the boat was exempted by being built for own use and then not sold for 5 years it does required ce certification and it may not be legally sold. 

It may be possible to illegally sell the boat  to someone who doesnt care but that is another matter . The potential penalty for such illegal action is described in the second of the above two links.

 

 

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4 minutes ago, MartynG said:

Presumably the boat in question has a  Boat Safety Certificate . How the BSS certificate  has been issued without having a CE plate  is a matter of concern. A non CE compliant craft never gains legality through the passing of time

Two incorrect assumptions here I believe. Firstly, the BSS has nothing to do with CE marking. If the boat complies with the BSS regs then it passes. 

Secondly, as everyone else has said, if the boat isn't CE marked there's no problem with selling it once it's over 5 years old. This is confirmed by the second of your two links which states that a boat is exempt from the RCD if it is a

watercraft built for own use, provided it is not subsequently placed on the Community market during a period of five years

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Well unless things have changed, the requirement to comply with the RCD only applies when the craft is first placed on the EU market. So second hand craft are not required to comply. After all nobody checks for changes since the  boat was built which could affect its compliance.

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10 minutes ago, MartynG said:

Unless the boat was exempted by being built for own use and then not sold for 5 years it does required ce certification and it may not be legally sold. 

Seeing as he's had it for 9 years (assuming I'm understanding the OP correctly) then it's way past 5 years since it was built. 

3 minutes ago, David Mack said:

Well unless things have changed, the requirement to comply with the RCD only applies when the craft is first placed on the EU market. So second hand craft are not required to comply. After all nobody checks for changes since the  boat was built which could affect its compliance.

Exactly. For our purposes all that matters is that it has a BSS certificate. 

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7 hours ago, Mike the Boilerman said:

 

Thats odd. I was sure when I investigated RCDing one of mine I would have been deemed to be taking on the role of "Builder" and responsible for assigning my own HIN. I decided mine was going to be "1".

But events overtook me and I sold the boat to a another bloke who wanted the boat and didn't care a stuff about RCD. There are a lot of us about! 

https://en.wikipedia.org/wiki/Craft_Identification_Number

I was partly wrong.  

The RYA only issues numbers for amateur built/completed craft.  

For professionally built craft the BMF is the managing body.  But in all cases the HIN (or CIN) must comply with the required format, which is 14 digits, not 5 as suggested somewhere in this thread.  A professional boatbuilder will be allotted a code by the BMF which will appear in the numbers issued for his craft.

If you look at the CE plate on your boat the number stamped on it should be 14 digits long.

The Wiki link uses the term 'marine' but of course all craft in the EU must comply whether salty or just muddy.

Edited by Murflynn
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There is clearly a misunderstanding on the 5 year rule. That  5 year rule only applies to a boat built for own use and not sold until after 5 years old. It does not apply to boats sold when new as complete.

The BSS examiner is required to check for a CE plate if the age of the boat dictates that it should have one. Unfortunately not all BSS examiners have equal understanding of their duties.

A boat that should have needed a CE plate when new is required to retain  that CE plate throughout its life. The passage of time does not exempt this requirement. If you dont believe me just read the information in the links I posted earlier.

 

 

 

 

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14 minutes ago, MartynG said:

The BSS examiner is required to check for a CE plate if the age of the boat dictates that it should have one.

Could you point me to where that is listed in the BSS regs?

https://www.boatsafetyscheme.org/media/268789/ecp-private-boats-ed3_rev2_apr2015_public_final.pdf

16 minutes ago, MartynG said:

That  5 year rule only applies to a boat built for own use and not sold until after 5 years old. It does not apply to boats sold when new as complete.

So I go to a builder and ask him to build me a boat for my own use. How does that not comply with 'a boat built for own use'?

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3 minutes ago, WotEver said:

Guidance for examiners is at the following link

https://www.boatsafetyscheme.org/professionals/examination/examination-guidance/recreational-craft-directive/

 

.

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11 minutes ago, MartynG said:

Thanks. Where in there does it say that an examiner cannot examine a boat that doesn't have a CE plate? I can't see that written anywhere. 

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44 minutes ago, MartynG said:

There is clearly a misunderstanding on the 5 year rule. That  5 year rule only applies to a boat built for own use and not sold until after 5 years old. It does not apply to boats sold when new as complete.

The BSS examiner is required to check for a CE plate if the age of the boat dictates that it should have one. Unfortunately not all BSS examiners have equal understanding of their duties.

A boat that should have needed a CE plate when new is required to retain  that CE plate throughout its life. The passage of time does not exempt this requirement. If you dont believe me just read the information in the links I posted earlier.

 

The links you posted earlier are not the RCD, they are interpretations of the RCD requirements. Clearly those involved in the trade as manufacturers, importers, distributers or brokers of boats have to take a cautious line in understanding the requirements and implementing them in the course of business. So it is not surprising that they stress the compliance aspect. But if you look more carefully even these documents don't state the position is as absolute as you do.  For example:

"The best advice is to look for the 5 items listed in the opening paragraph above (Builder's plate, CE mark, Hull identification mark HIN or Craft Identification number CIN, Owner's manual, Declaration of conformity). If they are not present then ask why not. All new recreational craft must comply with the Recreational Craft Regulations 2004."

"Although the owner's manual is a legal requirement under the RCD, it only applies when the craft is new or first placed on the market."

"The RCD only covers any craft when first placed on the market. It does not apply to any subsequent placing on the market. Put simply the RCD applies when the craft are 'new'. It does not apply to used craft but the requirements of the GPSD do."

"Any vessel that does not comply may be still able to be marketed but only under clear information and certain process. In such cases please contact  support@boatshed.com"

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23 minutes ago, WotEver said:

Thanks. Where in there does it say that an examiner cannot examine a boat that doesn't have a CE plate? I can't see that written anywhere. 

I did not say the boat could not be examined.The advice says as follows ...

 

Actions to be taken by examiners where an owner of a boat commissions a BSS examination, and the boat appears to warrant retrospective CE-Marking

In the role as a BSS examiner, you should offer no advice or commentary as to the legal status of the vessel or its compliance with the RCD.

In the circumstances that a boat appears to fit the need for Post Construction Assessment examiners should:

a) refer the boat owner to the Royal Yachting Association, CAB Consumer Advice, their local Trading Standards or a competent CE marking consultant for further advice;

B) keep a note in their records that this advice has been given;

c) report the circumstances to the BSS Office.

 

Therefore the owner of the boat in question should have been advised accordingly by the BSS examiner .

 

.

 

 

 

 

 

 

 

 

 

45 minutes ago, WotEver said:

 

So I go to a builder and ask him to build me a boat for my own use. How does that not comply with 'a boat built for own use'?

 

it intends to mean a self build boat which you build for your own use  - not a boat that is built for you by a boat builder.

In this case the boat in question is a boat built by a boat builder and sold when newly built.

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20 minutes ago, MartynG said:

it intends to mean a self build boat which you build for your own use  - not a boat that is built for you by a boat builder.

In this case the boat in question is a boat built by a boat builder and sold when newly built.

Fair enough. However, the OP has nothing to worry about because "The RCD only covers any craft when first placed on the market. It does not apply to any subsequent placing on the market. Put simply the RCD applies when the craft are 'new'. It does not apply to used craft"

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8 hours ago, WotEver said:

Fair enough. However, the OP has nothing to worry about because "The RCD only covers any craft when first placed on the market. It does not apply to any subsequent placing on the market. Put simply the RCD applies when the craft are 'new'. It does not apply to used craft"

However if the boat built after June 1998 never did have a valid RCD certification and CE plate  the fact that it was sold new as a complete boat remains an illegal act and any subsequent sale, in the EU, remains illegal. We are still in the EU ,by the way, and most likely the RCD with remain a requirement after Brexit.

 

 

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18 minutes ago, MartynG said:

However if the boat built after June 1998 never did have a valid RCD certification and CE plate  the fact that it was sold new as a complete boat remains an illegal act and any subsequent sale, in the EU, remains illegal. We are still in the EU ,by the way, and most likely the RCD with remain a requirement after Brexit.

 

 

So anybody guilty of the heinous act of selling a unmarked boat would feel the full force of the law for their illegal act?

Phil 

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8 minutes ago, MartynG said:

However if the boat built after June 1998 never did have a valid RCD certification and CE plate  the fact that it was sold new as a complete boat remains an illegal act and any subsequent sale, in the EU, remains illegal. We are still in the EU ,by the way, and most likely the RCD with remain a requirement after Brexit.

 

 

My  cruiser was built by a professional boatyard in 2003 for a ‘private individual’

It has no RCD plate, it has no HIN / CIN number, it does not even have a ‘shell number’, and, it has no manual.

I have all of the ‘Bills of Sale’ and the original ‘VAT Paid’ invoice.

It is SSR Registered (I registered it and in the ‘hull number’ section quoted ‘NVN - NA, as in No Visible Number - Not applicable, for boat description I put 'unknown')

It has been, and still has, a BSSC

It is Insured for all areas included on the attached map.

When I get home in the next few days, I'll scan my SSR documentation and prove it.

 

It is frustrating when well meaning 'experts' pronounce on subjects in which they have no experience.

 

 

Cruising Range map.png

  • Greenie 1
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1 minute ago, Alan de Enfield said:

My  cruiser was built by a professional boatyard in 2003 for a ‘private individual’

It has no RCD plate, it has no HIN / CIN number, it does not even have a ‘shell number’, and, it has no manual.

I have all of the ‘Bills of Sale’ and the original ‘VAT Paid’ invoice.

It is SSR Registered (I registered it and in the ‘hull number’ section quoted ‘NVN - NA, as in No Visible Number - Not applicable, for boat description I put 'unknown')

It has been, and still has, a BSSC

It is Insured for all areas included on the attached map.

When I get home in the next few days, I'll scan my SSR documentation and prove it.

 

It is frustrating when well meaning 'experts' pronounce on subjects in which they have no experience.

 

 

Cruising Range map.png

3 minutes ago, Phil Ambrose said:

So anybody guilty of the heinous act of selling a unmarked boat would feel the full force of the law for their illegal act?

Phil 

Many laws seem not to be enforced. But yet there is 

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15 minutes ago, Alan de Enfield said:

My  cruiser was built by a professional boatyard in 2003 for a ‘private individual’

It has no RCD plate, it has no HIN / CIN number, it does not even have a ‘shell number’, and, it has no manual.

 

 

It is frustrating when well meaning 'experts' pronounce on subjects in which they have no experience.

 

 

 

your boatbuilder was committing an offence.  full stop.

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Just now, Murflynn said:

 your boatbuilder was committing an offence.  full stop.

Quite probably - but it was not an offence to sell it (after 5 years), it was not an offence for me to buy it, and it is not an 'illegal' boat.

It was also said that without a RCD plate / HIN number the boat could not :

Have a BSSC

Be Insured

Be SSR Registered

 

When plainly that is not true.

  • Greenie 1
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