As of 11th April 2023, the process of registering non-EU vessels in Poland has become more complicated and expensive, making the country less attractive as a flag state for non-EU yachts.
Previously, it was relatively simple to register a vessel in Poland that was coming from outside the EU and did not have a CE Declaration of Conformity. All that was required was a Certificate of Deletion from the non-EU flag state, a survey, and a technical data sheet issued by the shipyard or other formal document stating the basics of the vessel.
However, the Polish government has recently introduced changes to these regulations, meaning that non-EU vessels without a CE Declaration of Conformity will now have to undergo a physical compliance assessment before the application for registration can be submitted. This assessment involves a notified body conducting an extensive survey to determine if a CE Declaration of Conformity can be issued. This process can cost between €7000 and €10000, depending on the type of vessel and measurements.
What is a CE Declaration of Conformity for Yachts?
A CE Declaration of Conformity represents a mandatory document in the European Union (EU) for all products, including yachts, which are sold or promoted within the EU. This declaration aims to prove that the yacht adheres to the fundamental health, safety, and environmental standards specified in the applicable EU Directives. The CE Declaration of Conformity pertaining to yachts usually encompasses details about the yacht’s design, fabrication, and testing, along with information on any pertinent standards or regulations followed during its construction.
Understanding the New Compliance Requirements
After completing the assessment, the notified body will issue a hull identification number (WIN) and a manufacturer’s plate, which must be affixed to the vessel by the owner. The manufacturer’s plate should contain the following information:
- the manufacturer’s name or business name, registered trade name or registered trademark, and a contact address;
- CE marking;
- vessel design category;
- maximum load recommended by the manufacturer;
- the number of persons the craft is designed to carry as recommended by the manufacturer;
- the maximum engine power recommended by the manufacturer (in the case of an outboard engine);
- CE mark and identification number of the notified body (but only if compliance assessment modules D, E, F, G or H have been used).
The new regulations apply to second-hand vessels imported from outside the European Union by private importers (natural or legal persons). The requirements for recreational craft and personal watercraft imported from outside the EU and introduced for use in the EU for the first time can be found in the RCD Directive, implemented into national law by the provisions of the Ordinance of the Minister of Development dated June 2, 2016.
In summary, the registration process for non-EU vessels in Poland has become more complex and costly due to the new regulations requiring a physical compliance assessment and a CE Declaration of Conformity. This change in regulations is likely to make Poland less attractive as a flag state for non-EU yachts.
