Guide
Does Boat Hardware Need CE Marking Under the Recreational Craft Directive?
CE marking is the mark a manufacturer fixes to a product to declare that it meets the EU law that applies to it. General information, not legal advice: this guide summarizes the European Commission's application guide to the Recreational Craft Directive 2013/53/EU, published in 2018, and does not replace advice on your own product. Short answer: ordinary deck hardware such as cleats, hinges and rail fittings is not on the Directive's list of components that need their own CE marking, but the boat must meet the essential requirements, so hardware suppliers are regularly asked for documents that support the boat builder's file.
By Saola Manufacturing engineering team · Published · Updated
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Does ordinary boat hardware, such as a cleat or a hinge, need its own CE marking?
The guide's reading of Annex II lists only five component types that need CE marking when they are sold separately, and cleats, hinges and rail fittings are not among them.
The Commission's guide states that the Directive's requirements apply to the components in Annex II when they are placed separately on the Union market and are intended for installation on or in recreational craft, and that those components are subject to conformity assessment and CE marking before they are sold (European Commission application guide, 2018). Where a boat manufacturer makes a component and installs it in its own craft, the component is not placed on the market separately, and it is covered by the boat's declaration of conformity and technical documentation.
The consequence for hardware is that CE marking mostly happens at the boat level. A recreational craft in scope is a boat intended for sport and leisure with a hull length from 2.5 m to 24 m, per the guide, and the boat must meet the essential requirements whatever hardware is fitted. That is why a boat builder or distributor may ask a hardware supplier for supporting documents even though the part itself carries no CE mark.
One caution on classification: the guide lists prefabricated hatches and port lights, so a complete hatch is on the list, while a hinge or latch sold alone is not named. If your product sits near a listed category, ask your compliance adviser before deciding.
Which components do need CE marking, and how are they assessed?
Five Annex II component types need CE marking when sold separately, and each needs an EU declaration of conformity and a conformity assessment that involves a notified body.
The guide says notified-body involvement is obligatory for the Annex II components, that the manufacturer may use module B (EU type-examination) with C, D, E or F, or module G or module H, and that a component manufacturer can use neither module A nor module A1 (European Commission application guide, 2018). The EU declaration of conformity must accompany components placed on the market separately, per Article 15 of the Directive as quoted in the guide.
The guide also narrows the list in places: portable fuel tanks of any capacity and tanks that are an integral part of the boat's structure are excluded from Annex II, and cables sold separately are not Annex II components, only cable assemblies, meaning cables with end connections.
| Annex II component | Related requirement in the Directive | Harmonized standards named in the guide |
|---|---|---|
| Ignition-protected equipment for inboard and sterndrive petrol engines and petrol tank spaces | Annex I.A points 5.1.1 and 5.2.2 | EN ISO 8846 (electrical devices, ignition protection) |
| Start-in-gear protection devices for outboard engines | Annex I.A point 5.1.4 | EN ISO 11547 |
| Steering wheels, steering mechanisms and cable assemblies | Annex I.A points 5.4.1 and 5.4.2 | EN ISO 8847, 8848, 9775, 13929, 15652 and 25197 |
| Fuel tanks for fixed installation and fuel hoses | Annex I.A point 5.2.2 | EN ISO 10088 (fixed tanks); EN ISO 7840 and 8469 (hoses) |
| Prefabricated hatches and port lights | Annex I.A point 3.4 | EN ISO 12216 |
Who counts as the manufacturer when a brand has its hardware made in Asia?
The party that has a product made and markets it under its own name or trademark is the manufacturer under the Directive, and an importer who sells under its own name takes on the same duties.
The guide defines the manufacturer by two cumulative conditions: the person manufactures or has the product made, and markets it under their own name or trademark; subcontracting does not discharge the manufacturer from responsibility (European Commission application guide, 2018). Article 11, as quoted there, makes an importer or distributor a manufacturer if it places a product on the market under its own name or trademark, or modifies a product so that compliance may be affected.
For the importer role the guide lists duties that matter to a supplier relationship. The importer must ensure the manufacturer has drawn up the technical documentation and that the product is accompanied by the required documents, must show its name and address on the product or, for components where that is not possible, on the packaging or a document, and must keep a copy of the declaration for 10 years after the product is placed on the market. Manufacturers must also ensure products bear a type, batch or serial number or other element allowing identification. For hardware, that last point is the reason lot or batch marking on parts is worth putting on the drawing.
What do the harmonized standards add for cleats, fittings and through-hull parts?
They give a presumption of conformity for the boat-level requirements they cover but remain voluntary; for deck hardware the guide names EN ISO 15084 for strong points and EN ISO 9093 for seacocks and through-hull fittings.
The guide explains that products made in accordance with harmonized standards are presumed to conform to the requirements those standards cover, and that a manufacturer may instead meet the essential requirements by other means if it documents the solutions in its technical documentation (European Commission application guide, 2018). Under the anchoring, mooring and towing requirement, the guide names EN ISO 15084. The Estonian standards record shows the 2018 edition valid from 16 October 2018, covering strong points for chains, cables and lines used for anchoring, mooring and towing of small craft up to 24 m hull length, without defining anchor weights or chain lengths (EVS record for EN ISO 15084:2018). That page does not mention cleats by name, so whether a specific cleat design falls under it is a question for the boat builder.
For seacocks and through-hull fittings, the guide lists EN ISO 9093-1 and 9093-2. BSI shows that BS EN ISO 9093:2021 combines those two parts, supersedes the 2018 editions, and sets material and corrosion-resistance requirements for parts below the maximum load waterline (BSI record for BS EN ISO 9093:2021). Because the Commission guide dates from 2018, check the current list of harmonized standards in the Official Journal to see which edition applies, and ask the boat builder which one their file uses.
What should a hardware supplier give a boat builder or distributor?
Give documents that describe the part and its material accurately and let the builder trace it, and leave the declaration of conformity to the manufacturer of record.
A practical package for ordinary deck hardware, which is not a CE-marked component, looks like this:
- The drawing revision, with the alloy by grade and UNS number, the condition and the finish.
- A material certificate per heat, agreed in advance; the guide on the EN 10204 3.1 versus 2.2 certificate explains the difference.
- A lot or batch number on the part or the packaging, so the builder can trace a failure to a lot.
- A certificate of conformance to the drawing and purchase order, kept distinct from an EU declaration of conformity; see certificate of conformance requirements.
- Test records for any strength or load claim the part makes, written by the party that owns the claim.
- Substance statements the buyer asks for, such as REACH or RoHS material control; see RoHS and REACH for metal parts.
- The country of origin and the producing site on the documents.
Do not put a CE logo on a part because a distributor asks for it. In the guide, CE marking declares conformity with the essential requirements after the conformity assessment procedures have been applied, so the logo belongs to the manufacturer who has done that work, and an Annex II component needs the notified-body route described above.
What should the RFQ and drawing say, and what can Saola supply?
State who the manufacturer of record is, which documents you need, and the material, finish and marking; Saola makes parts to your drawing; the EU declaration of conformity stays with the manufacturer of record.
Put the compliance owner on the RFQ in plain words: your company as manufacturer or importer of record, the boat builder or distributor who asked, and the list of documents above. Add the lot marking, the material callouts, and the stainless callouts you need; the guides on 316 versus 316L and passivation of machined stainless parts cover those. Surface finishing steps are arranged at partner plants Saola manages.
Bar parts such as pins, bushings, studs and fittings are quoted as CNC turning and CNC milling work from your drawing, and the written quote states the material, the production site and the country of origin. Whether the finished boat or an Annex II component needs notified-body work stays with the manufacturer of record and its adviser.
Frequently asked
Do I need CE marking to sell cleats in the EU?
The guide's Annex II list does not name cleats, so a cleat is not a listed component in its own right. The boat it goes on must meet the Directive, and your customer may ask for documents. Confirm your own case with a compliance adviser; this is general information, not legal advice.
Does a hatch or port light need CE marking?
Prefabricated hatches and port lights are on the Annex II list, so they need CE marking when sold separately. The guide refers to Annex I.A point 3.4 and EN ISO 12216 for them (European Commission application guide, 2018).
What if a distributor asks for a CE mark on a hinge?
Ask which provision of the Directive they rely on and whether the part falls in an Annex II category. If it does not, offer the document package instead of a CE logo, and have the request confirmed in writing.
Is an EU declaration of conformity the same as a certificate of conformance?
No. The EU declaration is a legal statement by the manufacturer, who assumes responsibility for compliance under Article 15. A certificate of conformance is a supplier statement that parts meet the drawing and purchase order. Do not use one in place of the other.
Is the 2018 guide still current?
Treat it as a starting point. Check the consolidated Directive on EUR-Lex and the current list of harmonized standards in the Official Journal, since standards are revised and the BSI record shows ISO 9093 was reissued in 2021.
Sources
- Application guide for Directive 2013/53/EU on recreational craft and personal watercraft, European Commission (PDF hosted by IMCI), 2018
- EVS-EN ISO 15084:2018, Small craft - Anchoring, mooring and towing - Strong points (record page), Estonian standards body, 2018
- BS EN ISO 9093:2021, Small craft - Seacocks and through-hull fittings (record page), BSI, 2021