4. Obligations of manufacturers
A manufacturer is a person who manufactures a product, or has a product designed or manufactured, and markets that product under their name or trademark.
The obligations of manufacturers of products include:
1) Before making a product available on the GB market or putting them into service, the manufacturer must:
- a) design and manufacture it in accordance with the essential requirements set out in Schedule 1 of the Regulations and that they do not endanger the health and safety of persons, property or the environment, when used correctly as intended.
- b) decide which conformity assessment marking (UKCA, CE, or CE + UKNI) they intend the equipment to have when placed on the GB market.
- c) carry out or have carried out the applicable conformity assessment procedure referred to in Part 3 of the Regulations. Schedule 15 to the Regulations introduced by the Product Safety and Metrology etc. (Amendment etc.) (EU Exit) Regulations 2019 sets out all the different types of conformity assessment procedures.
- d) draw up the required technical documentation (Regulation 9 and Schedule 9).
2) When the product meets the requirements of the Regulations, and before placing on the GB market, a manufacturer must:
- a) draw up a declaration of conformity (UK DoC if UKCA marked, EU DoC if CE marked) in the model format set out in Schedule 4 (or for partly completed watercraft, in Schedule 3).
- b) ensure the declaration accompanies the product when the product is placed on the GB market.
c) affix the relevant conformity marking (see section 9 (or section 10 for Qualifying NI Goods)) on the product or where applicable, a watercraft’s builder’s plate or propulsion engine (for components where it is not possible or warranted to affix the marking to the product, it can be affixed to its packaging and accompanying documentation). The manufacturer must ensure that the conformity assessment marking is followed by the identification number of the approved body.
3) The manufacturer must keep the declaration of conformity up to date. The manufacturer must be able to provide the market surveillance authority (MSA) with the relevant technical documentation for 10 years after the specific product was placed on the GB market.
4) The manufacturer must also label products (or, where in the case of components it is not possible, on accompanying documentation or packaging) with their name, registered trade name or registered trademark, their address, and the type batch or serial number (or other information identifying the manufacturer). This applies to all products.
5) When placing products on the GB market, the manufacturer must ensure that they are accompanied by instructions and safety information in English.
6) The manufacturer must, when appropriate with regard to any risk posed to consumers, carry out sample testing of products they have placed on the market and investigate any complaints that the products are not in conformity with the relevant legal requirements in the Regulations and keep records of these complaints, as well as records of any products that are not in conformity and any products recalled.
7) Manufacturers must take action where they have reason to believe that any product is not in conformity with the Regulations (either to bring the product into conformity, withdraw it or recall it); where there is a risk to consumers, they must
inform the relevant MSA. In GB this is local trading standards authorities. Manufacturers must take appropriate corrective action and co-operate with the enforcement authority.
8) Manufacturers that require a manufacturer’s code (MIC) in relation to watercraft identification as set out in Schedule 1, 2.1 (3) (see below) must obtain one from British Marine who are authorised to issue MICs on behalf of the Secretary of State. Manufacturers who have a MIC from British Marine or the Secretary of State will not have to re-apply for a new code but can continue to use the code they have.
In the context of the Recreational Craft Regulations (RCR) 2017, Schedule 1, Section 2.1(3) specifies the legal requirements for the Manufacturer’s Identification Code (MIC).
This section mandates that:
• Mandatory Code: Manufacturers must obtain a unique identification code (MIC) for any watercraft required to have a Watercraft Identification Number (WIN).
• Issuing Authority: In Great Britain, this code must be obtained from British Marine, which is authorized to issue MICs on behalf of the Secretary of State.
• Exemptions: Craft exempted under Clause 4 of the RCR 2017, such as certain home- built boats, are not required to display a WIN and therefore do not require an MIC under this specific regulation.
• Existing Codes: Manufacturers who already possess a valid MIC issued by British Marine or the Secretary of State are not required to re-apply and may continue using their existing code.
Manufacturers wishing to place goods on the NI market should follow the Regulation as it applies to NI. Qualifying NI goods can be placed on the GB market without any additional approvals, although additional information as to the UK based importer may be required, if the goods have an importer based in the EU/EEA. See further detail in section 10 on Qualifying NI Goods.
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