CE certification for Mirror dinghies (EU Declaration of Conformity)

[Editors note - I am not an expert on this subject, so please let me know if any of the following is incorrect.]

According to the Düsseldorf Boat Show organisers, "...used boats and yachts built before 16 June 1998 and already put into service within the EU do not require a CE mark."  

So this would apply to any Mirror with a sail number below around 69915 according to our list of sail numbers against year of manufacture. The boat would have had been in service within the EU and excluding the UK. We have to exclude the UK because, following Brexit, the EU considers the time a vessel spent in the UK before the day the UK left the EU as no longer valid for the purposes of recognising certification.

For newer boats, and the situation regarding importing older boats into the EU, read on:

Boats built post 16th June 1998

During this time and until Brexit, the UK was part of the European Union, so GRP & GRP composite boats built by Widebeam Ltd., such as 69992 'Swan Lake'  had a plasic builders plaque with some CE conformity information on it. Details are as follows:

Widebeam was formed when Bell Woodworking went out of business in 1999. It's likely Bell Woodworking would had taken the same approach on boats they built after 16th June 1998.

GRP foam sandwich boats sold by Trident-UK while the UK was in the EU came with a EC Declaration Of Conformity to Directive 94_25_CE (same details as show above for Widebeam Ltd). These boats were introduced onto the market around 2002.

As far as I can work out, wooden boats built after 16th June 1998 (by professional builders like Duffin Marine, Trident-UK) or built by amateur builders, but then sold within 5 years of "entering service"  would also need CE conformity. Kit manufacturers Trident-UK provided a EC Declaration of Conformity Statement with their kits stating the panels are to the approved design of a Mirror. There are sections for professional and amateur builders to declare they have built the kit into a boat in accordance with the building instructions, so it will comply with the Directive. According to the Düsseldorf Boat Show organisers amateur built boats which are sold more than 5 years after they entered service do not need a Declaration Of Conformity.

GRP foam sandwich boats manufactured by Winder Boats while the UK was in the EU are classed as '...solely for racing... ' under the EU regulations, and have (or had) a RYA sticker on them saying that (see above). So I presume that means some/all of the regulations (e.g. around stability) don't apply. These boats were introduced onto the market around 2008.

Note: I think Winder Boats have choosen to go down this route, rather than test their Mirror for compliance with the Directive, presumably because most Winders are used for racing and they have probably taken the same decision with other, less stable, classes they manufacture (e.g. Merlin Rocket class dinghies). All Mirrors have the same hull shape (within small tolerences) and are similar weight. We know the Mk 3 Interior GRP foam sandwich boat built by Alkar Technology in Belgium was tested and complied with the Directive. It's hard to imagine why a Winder would not pass if it was actually tested.

According to Cloe Evans, Boating Information Officer at the RYA (2024):

'There is still a requirement regarding vessels which were in the UK at the time of Brexit, the 31st Jan 2020. The EU have stated that if the CE marked vessel was in the UK at the time of Brexit and it is to be sold back into the EU, then there will be a requirement for a re-certification of the existing CE mark.

If the vessel is to be used in the EU then it can be used under the Temporary Importation allowance for a limted time without re-certification.

Vessels built post 16th June 1998 are CE certified to show compliance to the requirements of the Recreational Craft Directive, this does not verify if a vessel is of a certain “class” or model outside of the fact that the manufacturer is giving it a name, such as “Mirror Dinghy”. The CE certification is demonstrated through the manufacturer completing a Declaration of Conformity document, a DoC, It may be that the International Mirror Class Association recognises the DoC as means of showing that the vessel is a Mirror Dinghy as the manufacturer has declared this on the certificate, but this is not validated. In addition the only organisations that can issue a CE mark or certification, aside from the manufacturer are EU notified bodies, and so the (UK Mirror Class or International Mirror Class) association would not be able to issue a CE certificate.'

Boats built prior 16th June 1998 being imported into the EU

It is unlikely that a pre-CE marked Mirror would be treated differently to a CE marked Mirror. This means it is more than likely to be considered as being placed on the EU market or put into service in the EU for the first time when taken into the EU by a purchaser. This would be the case if the Mirror dinghy had only ever been used in the UK prior to Brexit.

The purchaser would potentially need to get the dinghy re-certified by an EU notified body. I would suggest you contact your World Sailing Member National Authority (MNA) (e.g. Fédération Française de Voile, Swiss Sailing,...) and ask how to proceed.

Exactly how this is handled in different countries within the EU seems to vary. More information on the situation in Switzerland.