EN    EN  
 EUROPEAN COMMISSION 
Brussels, 26.7.2011 
SEC(2011) 958 final 
  
COMMISSION STAFF WORKING PAPER 
IMPACT ASSESSMENT 
Accompanying the document 
Proposal for a  
DIRECTIVE OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL  
amending Directive 94/25/EC on the approximation of the laws, regulations and 
administrative provisions of the Member States relating to recreational craft, as 
amended by Directive 2003/44/EC. 
{COM(2011) 456 final} 
{SEC(2011) 959 final}  
 
EN 2   EN Contents:  
 
1. Introduction           4  
1.1 Overview of the EU legislati on for Recreational Craft     4 
1.2. Overview of the Recreational Cr aft market in the EU     4 
 
2. Procedural issues and consultation of interested parties     5 
 2.1 E x t e r n a l  e x p e r t i s e           5  
 2.2 Consultation of external stakeholders       6 
 2.3 Consultation of the Commission services       6  2.4 Internet public consultation        6 
2.5 Consultation with SMEs representatives       7 2.6 Opinion of the impact assessment board       7 
 
3. Problem definition          8 
 3.1 Exhaust emissions caused by recreational craft      8 
3.1.1 Effects on environment and health      8 
3.1.1.1 Impact of emissions to the air      8  
                                   3.1.1.2 Impact of emissions to water     12                           
3.1.2 The international context - emi ssion regulations in the US  12 
                                   3.1.2.1 EU-US trade relations for RCD    12                         3.1.2.2 Different EU/US emission regulations   13 
3.1.3 The EU Internal Market context-ri sk of diverging national standards 15 
3.2 Noise emissions from recreational marine engines    15 3.3 Safety and design concerns       15 3.4 Who is affected?         16 3.5 Legal certainty and simplificatio n - alignment with the NLF   16 
 3.6 Consistency with EU Policies       17  3.7 Does the EU have right to act       18  3.8 How the current situation is likely to evolve     18  
4 .  O b j e c t i v e s            1 9  
 5. Policy options          20  
 5.1 Policy options discarded early in the impact assessment process   20 
                       5.1.1 Self regulation for exhaust emissions     20                        5.1.2 Discontinuing existing EU action     21             5.1.3 Modification of esse ntial requirements on safety and design  22 
 5.2 Policy options retained fo r further analysis     22 
  5.2.1 Exhaust emission limits for engines     22   5.2.2 Noise emission limits for engines     25   5.2.3 Alignment of the RCD with the New Legislative Framework  26 
 
6. Analysis of impacts         26  
 6.1 Impact of stricter exhaust emissions limits     26 
                       6.1.1 Option 1 - No change of limits      26 
6.1.2 Option 2 - Stage II of the exhaust emissions limits   26 
 
EN 3   EN 6.1.3 Option 3 - Stage II of the limits with mitigating measures  30 
6.2 Impact of stricter noise emissions limits      38 6.3 Impact of the measures aligning the RCD with the NLF    42 
 
7. Monitoring and evaluation        42  G l o s s a r y            4 4    Annexes 
 
Annex I Overview of recreational craft a nd engines for recreational craft sector 45   
Annex II  Public consultation on a possibl e approach to revision of the RCD  49 
Annex III Schematic representation of diffe rent drive principles for boat engines 52 
Annex IV Annual average air concentrations in Europe - affected locations  53 
Annex V Overview of the exhaust and noise emissions limits in the EU and the US 54 
Annex VI Analysis of 5 different scenarios      58 Annex VII Methodology used for environmental impact analysis   60 
Annex VIII The calculation of the exhaust emission reductions    61 
Annex IX  Monetization of envi ronmental benefits     63 
Annex X  Methodology and assumptions used for economic impact  
analysis, calculation of compliance costs     65 
Annex XI Assumptions made to estimate e nvironmental noise impact–typical cases 74
 
Annex XII  Share of compliance costs in turnover, impact on competitiveness  76 
Annex XIII Impact of price effects on the number of jobs    77 A n n e x  X I V  S M E  t e s t          7 9  
 
 
           
 
EN 4   EN 1. INTRODUCTION 
1.1 Overview of the EU legislation for Recreational Craft 
This Impact Assessment concerns the revision of  EU legislation relevant for the recreational 
craft sector - the Recr eational Craft Directive1 (RCD) was adopted in 1994 to regulate the 
placing of pleasure boats on the European market. It first laid down essential safety 
requirements that manufacturers shall respect wh en designing crafts in order to place it on the 
EU market. The manufacturers must fulfil severa l obligations in order to show that their 
product complies with the Directiv e, including a Declar ation of Conformity of the craft with 
the essential requirements of the Directive,  affixing the CE marking on the product and 
providing the users with information on th e use and maintenance of the product. 
The amended Directive 2003/44/EC introduces speci fic requirements for propulsion engines, 
for both the compression ignition (CI) engines and the spark ignition (SI) engines. The 
Recreational Craft Directive covers pollutant s from engines exhaust emissions such as 
particulate matters (PM), nitrogen oxides ( NOx) and hydrocarbons (HC). It does not address 
CO 2 or other green house gas (GHG) emissions . Currently no inventory or data is available on 
GHG emissions from recreational craft engines.  Nevertheless, GHG em issions from engines 
in the recreational craft sector might be addressed in the future in line with developments in the road sector.  
Directive 2003/44/EC also provide s for a review clause (Article 2) asking the legislator to 
take account in a future revision of the need to  further reduce emissions  of air pollutants and 
noise in order to meet environment protection requirements. At the same time the vulnerable 
position of the SMEs should be taken into account  as the recreational cr aft sector consists 
mainly of small and medium enterprises (m ore than 95% of businesses are SMEs).  
The Commission issued a report in 2007 (COM ( 2007/313) in which it  describes several 
options to further reduce the exhaust emission  limits of recreationa l marine engines and 
announces to assess the impacts thereof.  
1.2. Overview of the Recreational Craft market in the EU 
The recreational marine activities across Eu rope involve some 37 000 companies which 
represent a wide range of aactivities such as marinas, boatyards, marine equipment 
manufacturers, hire charter a nd sailing schools, marine solicitors , insurance brokers etc. The 
sector directly employs some 272 000 workers and its annual turnove r is estimated at 23.4 
billion €. The approximately 2 600 EU boat builder s are established in 12 Member States with 
Italy being by far the most important boat builder in value terms, while France is the leading 
builder in terms of number of boats (see details in Annex I). 
Manufacturers of marine engines can  be separated in two main cat egories: the original engine 
manufacturers and the so-called marinisers. Wh ile original engine ma nufacturers are mainly 
large international companies, marinisers ar e exclusively very small companies (ca. 25 
employees), producing on average 500 units per year. The latter adapt engines which are 
                                                
 
1 Directive 94/25/EC of the European Parliament and of the Council of 16 June 1994 on the 
approximation of  the laws, regulations and administrative provisions of the Member States relating to 
recreational craft (OJ L 164, 30.6.1994; p.15) 
 
EN 5   EN originally produced for other purposes such as automotive engines and convert these for 
marine use. The EU counts some 40 e ngine manufacturers and marinisers.  
The recreational craft manufacturing sector is strongly export orie nted with the U.S. being the 
main market followed by the EU market. 
2.  PROCEDURAL ISSUES AND CONSULTATION OF INTERESTED PARTIES 
Lead Directorate General:  DG Enterprise & Industry 
Other involved services:  SG, DG ENV, DG ECFIN, DG TREN, DG JRC, DG SANCO, DG 
MARE 
Agenda planning / WP reference:  2009/ENTR/010 
2.1 External expertise:  
Several external studies have been commi ssioned to examine further improvements of 
environmental characteristics of recreational marine engines and the impact thereof. The 
studies are publically available on the Europ ean Commission’s website , DG Enterprise and 
Industry, Maritime Industries. 
• TNO2 “Stocktaking study on the current stat us and developments of technology and 
regulations related to the environmental pe rformance of recreational marine engines 
– Final Report”, January 2005.  (“Stocktaking study”). The Commission requested 
this study after having intr oduced environmental require ments in the Recreational 
Craft Directive. Its objective was to evaluate the environmental impact from 
propulsion engines used in recreational cr aft. The study identif ied four possible 
options for further emission reduction meas ures, taking into account the overall air 
emissions of each option (for details see: p.21). 
• European Confederation of Nautical Industries3 “Study on The Feasibility and 
Impact of Possible Scenarios for Further Emission Reduction Measures for 
Recreational Craft Engines in the Context of Directive 94/25/EC, as amended by 
Directive 2003/44/EC: Impact Assessment Report – Final Report”, 26 October 2006”.  
This study identified and measur ed in detail the impacts and distributive effects of the 
four possible scenarios for emission reduc tion measures as identified in the TNO 
study. It was concluded that each of the scenar io options investigated would result in a 
relatively low emission reduction, and would en tail disproportionate  cost for certain 
European SMEs.  
• ARCADIS4 “Complementary Impact Assessm ent Study on possible emission 
reduction measures for recreation al marine engines” – June 2008.  Following the 
results of the previous st udy, the Commission launched a nother study in order to 
                                                 
2 Stocktaking study on the current status and developments of technology and regulations related to the 
environmental performance of recreational marine engines – Final Report, January 2005, TNO for DG 
Enterprise; http://ec.europa.eu/enterprise/sectors/maritime/documents/index_en.htm   
3 Study on the Feasibility and Impact of Possible Sc enarios for Further Emission Reduction Measures for 
Recreational Craft Engines Impact Assessm ent Report”, 26 October 2006, ECNI”. 
http://ec.europa.eu/enterprise/sectors/maritime/documents/index_en.htm  
4 Complementary Impact Assessment Study on possible emission reduction measures for recreational 
marine engines, June 2008, ARCADIS for DG Enterprise 
http://ec.europa.eu/enterprise/sectors/maritime/documents/index_en.htm   
 
EN 6   EN identify and assess new scenarios which w ould take into account the peculiar position 
of SMEs in the recreational craft sector . This study assessed the impact of four 
scenarios (including a baseline scenario) taking into account SMEs. It identified the most ambitious, yet feasible, scenario to maximise the emission reduction potential of 
recreational craft engines a nd to mitigate social and economic impacts on SMEs. 
2.2 Consultation of external stakeholders:
 
Five Standing Committee meetings  were organized in the period between October 2008 and 
December 2009 with the particip ation of the national public  authority experts, the 
representatives of indus try, customer associations, standard isation bodies, representatives of 
conformity assessment bodies and Ministries of Environment. The objective of the meetings 
was to present the methodology and possible ways on how to improve the environmental characteristics of the recreational marine engine s and to collect the opinions and comments of 
the main stakeholders. Stakeholders contribu ted by identifying the most suitable scenario 
which further restricts the exhaust emissions of marine engines and accounts for necessary 
measures to mitigate the impact on SMEs. This scenario is analysed in the report among other 
options. 
Five Working Group meetings  took place in the period between October 2008 and April 
2009 to identify the list of technical  issues which need to be re vised in the Recreational Craft 
Directive. The participating e xperts – representatives of mark et surveillance authorities, 
notified bodies and industry associations - addressed recommendati ons to the Commission 
services which mainly dealt with obligations of private importers and self-builders, conformity assessment for the second-hand boats. 
2.3 Consultation of th e Commission services:
 
In line with the guidelines of the Impact Assessment (IA) an Inter Service Steering Group 
(ISSG) was set up and the following services activ ely participated in the preparation of the 
IA: SG, DG ENV, DG JRC, DG SA NCO, DG MARE .Other servi ces were informed about all 
steps taken, but did not atte nd ISSG meetings: LS, DG ECFI N, DG TREN. Meetings were 
held on the following dates: the 19th November 2009, 28th January 2010, and 10th March 
2010. The report of the last ISSG meeting re flects the main concer ns and conclusions 
expressed by the services.  
2.4 Internet public consultation:  
A public internet consultati on was organized between 11th May and 19th July 2009. The 
Commission services received 32 responses to  the questionnair e published in English only. 16 
replies were sent on behalf of various instit utions, 9 from enterprises and 7 on behalf of 
individual citizens. The contributions came from  12 different countries (11 EU states and 1 
EEA state). 
The main objective of th e internet public consultation was to seek views a nd opinions of 
citizens, the representatives of enterprises and the public authority’s representatives on various issues that may need to be addre ssed in a draft proposal to further amend the 
Directive. The consultation revealed overall su pport to introduce more restrictive limits for 
exhaust emissions while taking into account the specific position of the SMEs. The 
respondents indicated that limits should be co mmon not only for the EU/EEA states but also 
for other parts of the world, the United States in particular. The survey confirmed that a 
 
EN 7   EN further reduction of noise limits of marine engi nes would not effectively solve the problem of 
excessive noise in the exposed areas. Respondent s suggested that local restrictions on the use 
of boats will better address this problem.   
The consultation highlighted that the specificities  of the recreational ma rine sector should be 
better reflected in the EU legislation. Concerns were raised with regard to the very active 
second hand market as well as self-built boats. It also highlighted the need to clarify the 
obligations of economic operators including priv ate importers as well as competences of the 
national enforcement authorities. A summary of the consultation is provided in the Annex II. 
2.5 Consultation with SMEs representatives  
• Meetings with SMEs 
• Consultation with SMEs via Internet Public Consultation 
• Round table discussions with the represen tatives of SME engine manufacturers 
• A special SME assessment in the complementary Impact Assessment Study, 
ARCADIS 2008  
2.6 Opinion of Impact Assessment Board (IAB):  
The IA was submitted to the IAB on 22nd March 2010. The IAB conclu ded that the IA report 
presents an analysis of econom ic, environmental and social im pacts while the assessment is 
not yet sufficiently clear and needs to addr ess a number of analytical issues. The IAB 
recommended that report should be amended to clarify the problem, to better justify the options and to better explain the expected  impacts and the basis of estimates and key 
assumptions. Additional information is needed on the EU market and trade in recreational craft, and on health and environmental imp acts of emissions. The justification of the 
emissions option needs particular work, info rmed by a clear EU-US comparison. The impact 
analysis should cover all objectives. The view s of stakeholders should be described more 
consistently, and views of health a nd environment stakeholders included. 
On the base of the 1
st IAB opinion the problem definition has been redrafted in order to 
clearly explain both the envir onmental and economic concerns with regard to the exhaust 
emission limits. The description of the impact of each option was completed by the monetization of enviro nmental impacts which allowed the direct comparison with the 
compliance costs. The qualitative evaluation of the options has been strengthened. The 
definition of the problem and the impact analysis is completed by the description of environmental and health impacts of the reflec ted air pollutants and by  the indication of its 
levels of hazard. A comparison of the current EU emission limits with the US limits has been provided as well as the comparis on with other relevant EU legi slations. The assumptions and 
methodology used for the calculations are addresse d in the main text. An evaluation of how 
the policy options meet the objectives has b een added. The stakeholders’ opinions are 
reflected throughout the IA and in its analytic al part. A summary of the internet public 
consultation is provided. 
The revised IA was resubmitted to the IAB on 5
th July 2010. The IAB concluded that the 
report has been significantly improved along the lines of the Board's first opinion, and 
provides evidence to justify action in this area. Following the 2nd IAB opinion, the mitigating 
 
EN 8   EN measures have been further clarified and th e proportionality of opt ions with mitigating 
measures has been indicated. The text has been improved with regard to the reduction of administrative burden, the SME test and the monitoring procedures.  
3. PROBLEM DEFINITION 
Since 1994 the EU has regulated the placing on th e market of recreatio nal craft and related 
products. Harmonised requirements on the safety of products have been adopted, which since 
2003 have been completed by requirements on the environmental  impact of recreational craft 
which cover the main environmental concerns of boat usage, namely the engine exhaust and 
noise emissions. 
3.1 Exhaust emissions caused by recreational craft 
 
3.1.1 Effects on environment and health 
Approximately 6 million of recreational crafts  are in use in Europe (including Turkey, 
Croatia, Norway and Switzerland). Of this total figure the majority (4.8 million) are 
motorboats, 1.1 million are sailboats and 0. 1 million are personal watercrafts (PWC). 
Motorboats and PWCs use propulsion engines that  are either spark-igni tion engines (called SI 
or petrol engines) or compression ignition (C I or diesel engines) both for inboard and 
outboard use (see information on the speci fic engine terminology in Annex III). 
3.1.1.1 Impact of emissions to the air  
According to the air emission i nventory for Europe CORINAIR,5 the overall emissions from 
recreational craft are in gene ral minimal compared with ot her pollution sources such as 
energy producing industries, manuf acturing industries, road transport, etc. Recreational crafts 
are estimated to contribute to approximately 0.5% of total hydrocarbon  (HC) emissions and 
0.1% of total NO X emissions. Despite to this small contribution of recreational craft to the 
overall air emissions, its use however can lead to localised problems in areas that have a high concentration of recreational craf t at certain times of peak activ ity. Such affected locations are 
the areas of big lakes and the attractive sea shores. Geographical ly, among the most affected 
locations belong the lakes and sea shores in the north of Italy, the shores of the Channel and 
the lake Constance. This is why in the late ei ghties local authorities in Germany, Switzerland 
and Austria bordering on Lake Constance started to regulate th e use of boats and the exhaust 
emissions from boats to preserve a high qual ity of the air and the drinking water. As a 
consequence, in order to en sure a high protection of the environment while ensuring the 
correct functioning of the intern al market, the so-called Stage I of the exhaust emission limits 
were adopted at EU level. 
                                                
 
5 CORINAIR European Topic Centre in Air Emissions: The results of an in-depth study published in 1998, CORINAIR 
1994 Inventory were reconfirmed in 2007.  
 
EN 9   EN Figure 1 indicates annual average NOx emissi ons made by various sources of pollution. 
While it does not address the s hort term (or peak) periods, it can  be deducted that for areas 
suffering from NOx concentrations above th e Environmental Quality Standard (EQS)6, the 
short term concentrations will be more signi ficant. Information about the EU annual air 
concentrations of particulate matters  (PM) is available in Annex IV. 
Figure 1: Annual average NO X air concentrations  
 
Source: The Complementary Impact Assessment Study: ARCADIS (2008), p.58  
As indicated, the most important air polluta nts emitted from propulsion engines used in 
recreational crafts are nitrogen oxides (NOx), hydrocarbons  (HC) and particulate matters 
(PM) as well as carbon monoxide (CO). All of th em may affect human he alth either directly 
or indirectly.  Nitrogen compounds derived fr om NOx emissions are cons idered as a particular 
harmful impact from exhaust emissions.  Nitrogen dioxide (NO 2) causes direct acute and 
chronic effects to the respiratory system. Furthe rmore, NOx contribute to  the nitrogen load in 
the environment which can result in significant impacts caused by eutrophication7 of 
terrestrial and aquatic environments. Moreov er, NOx and HC emitted by engines can react 
together in the presence of sunlight to form photochemical oxidants such as ozone. These can 
cause direct damage to vegetation, and can also form aerosols in the presence of PM. 
Together, these pollutants resu lt in the formation of photoche mical smog. In 2008, the health-
related ozone target was exce eded at 35 % of all rural b ackground measurement stations 
                                                 
6 EQS is a concentration established to  ensure protection against exposure. 
7 Eutrophication is an increase in the concentration of  chemical nutrients in an  ecosystem to an extent 
that increases the primary pr oductivity of the ecosystem. 
 
EN 10   EN reporting to the EEA8. NOx emissions can also occur natura lly, e.g. in salt marshes, estuaries 
and shallow water areas. 
The contribution of recreational craft to the emi ssions of PM is rather small (see Table 1 - 3).  
The following tables show estimated concentrat ions of pollutants ( NOx, PM, CO) measured 
in marine environment and compared to the environmental quali ty standards (EQS)9. EQS are 
available for NOx, PM and CO, but not for HCs. It indicates that  EQS’ for NOx emissions 
exceed significantly in c oast marinas in short term . The concentrations of other pollutant 
are below the limits in all considered areas. 
 
Table 1: Estimated concentrations of selected pollutants for Coast Marina  
Pollutant   EQS (µg/m3) Current situation (baseline) 
(µg/m3) 
NOx long term10   40 17,54 
NOx short term 200 599,47 
PM long term   40 0,26 
PM short term 50 0,59 
CO long term   350 231,26 
CO short term 10 000 3093,82 
 
 
                                                 
8 EEA SOER 2010–Thematic Report Air Pollution at http://www.eea.europa.eu/s oer/europe/air-pollution  
9 Directive 2008/50/EC refers to a limit value for NO 2 for the protection of human health and for NOx for 
the protection of the environment. As in other impact assessments, exhaust emissions are usually 
measured as NOx. For simplicity reasons, Tables 1-3 refer to NOx (sum of NO 2 and NO) only since NO 
emissions can be transformed into NO 2 in the atmosphere.  
10 Long-term concentration represents an annual mean 
- Short-term ambient NO 2 concentrations represent a 99.79 percentile 1-hour mean 
- Short-term ambient PM concentrations represent a 90.41 percentile 24-hour mean 
- Short-term ambient CO concentrations represent a 100 percentile 8-hour mean 
- Short-term ambient HC concentrations  represent a 100 percentile 1-hour mean  
- Long term EQS shall mean a concentration established to ensure protection against long-term exposure 
- Short term EQS shall mean a concentration established to ensure protection against short-term exposure 
 
 
EN 11   EN Table 2: Estimated concentrations of selected pollutants for Lake Marina 
Pollutant   EQS (µg/m3) 
 Current situation (baseline) 
(µg/m3) 
 
NOx long term   40 13,17 
NOx short term  200 213,97 
PM long term   40 0,27 
PM short term 50 0,56 
CO long term   350 137,98 
CO short term 10 000 1121,75 
 
Table 3: Estimated concentrations of se lected pollutants for Inland Waterways 
Pollutant   EQS (µg/m3) Current situation (baseline) 
(µg/m3) 
 
NOx long term   40 0,16 
NOx short term 200 2,5 
PM long term   40 0 
PM short term 50 0,02 
CO long term   350 3,73 
CO short term 10 000 29,64 
Source of the tables: Environmental Impact Assessment Study, ECNI (2006), p.152 
The fate of exhaust emissions entering the atmo sphere is complex, and heavily influenced by 
the prevailing meteorological conditions as well as the t opography of the land and the 
vegetation present. Whilst some emissions will tr avel long distances in the atmosphere, others 
may be deposited on land or intercepted by vegetation close to the emission source.  
Carbon monoxide (CO) is hardly soluble in wate r therefore more than 80 % is emitted to the 
atmosphere. CO concentrated in enclosed and not ventilated spaces may have a direct negative impact on human health because it is hi ghly toxic. However, the concentration of CO 
in the open air is short-livi ng and rather small as CO quickly oxidizes and forms CO
2. It 
means that marine ambient is not no rmally affected by carbon monoxide.  
Carbon monoxide may reach a boat user if the boat does not meet essential safety 
requirements requesting the inboard engine to be separated from livin g quarters within an 
 
EN 12   EN enclosure and the engine compartment to be ven tilated. If the boat meets the essential safety 
requirements for design, the CO emitted by the boat should not endanger the boat user. 
3.1.1.2 Impact of emissions to water  
The exhaust gases of modern engines are emitted below the water surface with the major part 
being directly released to the atmosphere; a mi nor part will condense and suspend temporarily 
in the water. The fate of HCs in the water is complex: a large quantity evaporates quickly, particularly under the influence of propeller action, but other HCs form microfilms at the 
surface or adsorb to sediments. No evidence wa s found that HC from re creational craft build 
up to dangerous levels in sediments, or that HC levels exceed levels permitted by environmental quality standards in drinking water. 
Despite the fact that water contamination is pos itively correlated to the size and intensity of 
the fleet, it is generally accepted that there is no  need for general measures at EU level to 
restrict engine power levels or types of engines or even to prohibit the use of boats on lakes to 
preserve the quality of dr inking water legislation.  
3.1.2 The international context - em ission regulations in the US 
3.1.2.1 EU-US trade relations for RCD
 
The number of motorboats and personal waterc rafts outreach the other boat categories. The 
sales figures of engines provide d in tables 4 and 5 underline th e importance of the EU and US 
markets. For SI (petrol) engines, the latter repr esents more then half of the sales in value 
terms and more than one third of units sold at the world ma rket. Furthermore there is a 
dominance of SI engines at wo rld level and clear preference of US customers for high power 
categories. 
The EU and the US are also the largest mutual  trading partners of the recreational marine 
engines. If EU manufacturers are dominating the CI (diesel)  engines production with more 
then half of the world production, it only has a marginal share of the SI engine production. 
Exports from the EU are mainly concerning CI engines.  
This close relationship between th e EU and US market explains the continued effort to align 
exhaust emission regulations on bot h sides of the Atlantic, similarly to the discussion in other 
engine user sectors such as on-road or non-road. 
Table 4: Sales of outboard SI engines per power category in units and value in Europe, 
U.S. and the Rest of World (2007) 
Unit sales  Sales value (in million €)  Engine category 
(in kW)  
EU US Other EU US Other 
< 3 49 608  7 596 71 017 39,2 6 57,8 
3 - 20 84 652 74 168 121 186 173,5 152 255,5 
20 - 75 54 242 98 550 77 652 357,5 649,4 526,4 
 
EN 13   EN 75 - 110 10 524 36 235 15 066 113,1 389,3 166,5 
110 - 150 7 684 37 082 11 107 516,1 157,5 
> 150 4 119 48 070 5 896 80 933,6 117,8 
Total 210 829 301 701 301 818 870,2 2 646,4 1 281,5 
Source: The Complementary Impact Assessment Study: ARCADIS (2008)   
Table 5: Sales of CI engines per power categor y in units and value in Europe, U.S. and the 
rest of the world (2007)  
Unit sales Sales value (in million €) Engine category (in 
kW) 
EU US Other EU US Other 
< 18 12 800 865   60,8 4,1   
18 – 37 9 200 622   82,5 5,6   
37 – 75 7 600 514   91,4 6,2   
75 - 130 3 600 1 147   60,8 19,4   
130 - 560 6 800 5 980   166,8 146,6   
Total 40 000 9 128 15 872 462,2 181,9 107 
Source: The Complementary Impact Assessment Study: ARCADIS (2008)  
3.1.2.2 Different EU/US emission regulations  
The United States legislation fo r recreational craft contains more stringent emission limits for 
recreational marine engines than those provided in the EU legislation. The US Environmental 
Protection Agency (EPA) regulates emissions fr om SI and CI engines. Standards for CI 
engines were introduced in 1998 and been progr essively reinforced until 2008 (CFR 40 Part 
1042). Since 2001 the Californian Air Resour ces Board (CARB) sets independently 
requirements for SI marine engines which are now aligned to EPA rules (CFR 40 Part 1045). 
As the use of SI engines far outnumber the use of  CI engines (in the U.S. the relation is 30:1, 
in EU it is 5:1) a closer l ook is dedicated to the comparis on of the main exhaust emission 
limits for SI outboard engines in the EU and the US. 
    
 
EN 14   EN Table 6: Comparison of the applicable  limits for SI OB marine engines 
Power (P N) Carbon Monoxide (CO) Hydrocarbons + Nitrogen Oxides 
(HC + NO X) 
  EU US EU US 
(kW) (g/kWh) 
2,5 390 488 36 30 
3 350 485 34 30 
4,3 290 479 30 30 
10 210 450 25 21 
30 170 350 22 18 
40 165 300 22 17 
50 162 300 22 17 
100 156 300 21 16 
Table 6 compares the currently applicable emi ssion limits in the EU with the most recently 
adopted US regulation which shows lower lim it values for HC+NOx for SI OB marine 
engines in the US. While the RCD provides limit values for NOx, the US rules provides 
aggregated limit values for HCs and NOx whic h allows the engine ma nufacturer a certain 
degree of freedom when calibrating engines to meet the exhaust emission limits including CO 
and PM. HC emissions are unburne d residues of fuel, where NOx is the reaction product after 
combustion. When optimising the engine perf ormance, HCs and NOx perform in opposite 
direction, if one goes up, the other goes down. Other differenc es of EU and US emission 
limits for various types of engines are highlight ed in the detailed overview provided in the 
Annex V. 
As a consequence of the different regulatory standards the emission levels per recreational 
craft will be higher in the EU compared to th e US. It will also affect engine manufacturers 
that have to meet the additional development costs and higher production costs for complying to the stricter US emission standards. The different requirements can result in keeping two separate production lines in place, which do no t allow engine manufacturers to benefit from 
economies of scale. However we do not know the cost of having two separate production lines. Moreover most engines are regularly redesigned even in the absence of new emission limits. This requires recertification costs, wh ich for most manufactur ers who supply engines 
to the EU and to the US market s need to be paid twice. An  enquiry among the representative 
companies in this market highlighted that th e average costs per engi ne is approximately 20 
000 € which in case of a small engine manufact urer producing low power engines may be up 
to 5% of the engine costs. 
Stakeholders have asked the Commission to align the EU emission requirements with the 
more stringent US limits which they exp ect would limit productio n costs due to the 
advantages of scale and lower costs of testing procedures. 
 
EN 15   EN If the EU and the US are not able to agr ee on a common set of ma rine engine exhaust 
emission standards, it is unlikely that the re st of the world will be able to do so. The 
consultations between the European Commission and the EPA will be continued in order to 
coordinate the development of the exha ust emission limits in the future.  
3.1.3 The EU Internal Market context - ri sk of diverging national standards 
Some of the EU regions and local areas are part icularly affected (see chapter 3.1.1) by exhaust 
and noise emissions caused by recreational craft and the relevant authorities are eager to take action to remedy to this situation. As the RC D is a full harmonisation directive, Member 
States can however not introduce individual nationa l/local legislation to further restrict the 
exhaust emissions. Nevertheless, they have the legal means to introduce a limitation of a use 
and speed of boats. Some Member States appl y this measure until the extreme such as a 
complete ban of use of some boa ts (usually PWCs) in their waters. Several court cases have 
been reported and stakeholders consider this  extreme application as a breech of European 
Charter of Human Rights, Prot ocol 1 requiring the right of  a citizen to use freely its 
possession.  If the EU exhaust emission limits would become obsolete in case they are not 
revised according to the actual needs, more EU  regions might use an extreme version of the 
use and speed limitations to decrease the exha ust emissions. This may escalate the conflict 
and become a serious internal market trade obstacle.  
3.2 Noise emissions from recreational marine engines
 
Noise emitted from recreational craft has an impact on the surrounding nature and population 
as well as on the boat users. Crafts tend to operate close to the shore often in company with other users, generating a droning sound, made worse by weather conditions which may be 
very annoying to persons living close to the shor e. The noise impact on the boat user varies 
largely depending on the boat itself but equally also on its use and speed as well as on the 
weather conditions. One can assume that in ex treme cases the permanent exposure to noise 
will cause hearing impairment, hypertensi on, annoyance, sleep disturbance.   
3.3 Safety and design concerns
 
Directive 94/25/EC harmonises all relevant safety characteristics for recreational craft in order 
to allow the correct functioning of the Internal Market. The essential requirements for safety remain unchanged till the present.  
Some stakeholders have raised the need to modify certain essentia l safety requirements, 
namely the boat design categories. They pr opose to extend and re-define boat design 
categories in order to better reflect the specific  risks of each boat categ ory in relation to its 
use. 
The essential requirements for safety have also be en discussed in view to the possible need to 
introduce more detailed regulatory provisions on technical solutions to mitigate risks. This 
would be in contrary to th e philosophy of the New Approach  which is limited to fix the 
essential requirements in the legislation and leav es the definition of tech nical solutions to be 
fixed in Harmonised Standards. 
A small modification has been discussed for th e definition of the discharge prevention in 
sense of strengthening the requirement to inst all the holding tanks mandatorily and not only 
voluntarily. 
 
EN 16   EN 3.4 Who is affected?  
The analysis of the sector as well as stakeholders’ consultations  revealed that about 95% of 
the businesses active in the recreational craft s ector are SMEs. The vast majority of these 
SMEs are boat builders. In  2007, around 2600 boat builders have  been identified which are 
located in 12 EU Member States. The consulta tion has shown that boat builders are not likely 
to be affected by the restricted exhaust em issions since most boats are designed to host 
differently designed engines. The choice of th e engine is often left to the customer.  
The other group of SMEs consists of engine ma nufacturers and marinisers. Whereas the first 
manufacture genuine marine engines, the latter  buy engines that are originally designed for 
applications such as automotive, and adapt them for the marine use. About 40 engine 
manufacturers (rather medium sized companies) and marinisers (micro or small companies) 
were identified in 12 EU Member States. As ma rinisers buy already compliant engines used 
for different applications (on-road, non-road), th ey will not be likely affected by the changes, 
too.  
Therefore, the preliminary a ssessment leads to the conclusion that the small and medium 
sized engine manufacturers are the main affect ed party. Only a few engine manufacturers 
falling into this category were identified. Despit e the fact that they act independently, they 
often belong to a group of large engine manufacturer and in fact do not meet stricto senso  the 
criteria of an SME. The consultation has show n that there is at least one independent SME 
engine manufacturer.  
3.5 Legal certainty and simplifica tion - alignment with the NLF  
With regard to the question whether the type of  act chosen, namely a directive , which needs 
to be transposed by the Member States into na tional legislation, is a ppropriate, or whether a 
regulation should be envisaged in stead, the current positive experi ence with the application of 
this directive did not show  any reason for a change. 
On 9 July 2008, the Council and the European Parliament adopt ed two horizontal instruments 
relating to the marketing of products in the Union. Regulation (EC) No. 765/200811 which is 
setting out the requirements for accreditation and market surveillance relating to the 
marketing of products and Decision No 768/2008/EC12 on a common framework for the 
marketing of products. Both instruments apply to  the recreational craft sector. Therefore, for 
clarity reasons a reference to the applicability of  the Regulation in the recreational craft sector 
needs to be inserted into the proposal. In or der to ensure further consistency with other 
product legislation, it is also appr opriate to align certain provisi ons of the RCD Directive with 
the Decision, in so far as sect or specificities do not require a different solution. The model 
articles of the Decision that have been taken over to the RCD proposal concern in particular 
                                                 
11 Regulation (EC) No 765/2008 la ys down horizontal provisions on the accreditation of conformity 
assessment bodies, on the CE marking and on the Co mmunity market surveilla nce framework for, and 
controls of, products entering the European Union market, which also apply to the recreational craft 
sector. The Regulation is directly applicable and is applied from 1st January 2010. 
12 The Decision is a sui generis  instrument, which provides common principles and reference provisions 
for the purposes of legislation based on the New Appr oach principles. The Decisi on is not applicable as 
such but it is addressed to the Union legislator . In the Decision, the Council and the European 
Parliament commit themselves to ta ke the provisions of the Decision  into account whenever legislation 
is drawn up which concerns a product already subject to other Union acts. 
 
EN 17   EN (1) horizontal definitions (e.g. placing on the ma rket, manufacturer, impor ter, distributor, 
etc.), (2) obligations of economic operators (including obligations to ensure traceability13), (3) 
harmonised standards and presumption of conf ormity, (4) formal objection to harmonised 
standards, (5) requirements for conformity a ssessment bodies and for authorities notifying 
them as well as for notification proce dures, (6) conformity assessment modules14, (7) EC 
declaration of conformity and (8) provisions concerning procedures dealing with products 
presenting a risk (Safeguard clause procedures).  
3.6 Consistency with EU Policies  
The Recreational Craft Directive is embedded in a framework of European Legislation 
combining maritime and environmental aspects. A high level of environmental protection is a 
foremost objective of the Union set in the Treaty.  
One of the flagship policies de fined in the Europe 2020 strategy15 aims at establishing a 
resource efficient Europe to meet the climate/energy targets. The integrated maritime policy16 
streamlines the protection of the environmen t in every Union policy, especially those 
affecting the maritime environment. The Recrea tional Craft Directive revision takes place in 
this general context. It also contributes to  the objective of the 2010 International Year of 
Biodiversity.  
The Recreational Craft Directiv e contributes to a progressive  reduction of emissions, in 
particular with regard to localised areas su ch as marinas and har bours, which suffer from 
pollution peaks during certain periods of the year. It  is therefore in line with the objectives of 
the Clean Air for Europe (CAFE) initiative17, which provides an integrated and long term 
strategy for reducing the adverse impact of ai r pollution on human health and environment as 
specified in the Directive 2008/50/EC on ambien t air quality and cleaner air for Europe.18 The 
approach followed to regulate recreational craf t emissions is derived from Directive 97/68/EC 
on non-road mobile machinery (NRMM)19 with the introduction of emission stages and 
implementation dates as well as  the test procedures.   
Also the national ceil ings Directive 2001/81/EC20establishes legally binding limits to be 
obtained by 2010 for the total permissible emi ssions at Member State level for several 
                                                 
13 Import of recreational craft by private individuals from  the third countries is specific for this sector. The 
obligations of the private importers should be to some extent harmonised with the obligations of manufacturers.   
14 The conformity assessment modules to be used are set by reference to the modules set in the Decision, 
whereas the choice of the conformity assessment modules available to the economic operator is a sector specific 
issue.  
15 COM (2019) 2020 final 
16 See for instance Green Paper COM (2006) 275 final "Towards a future Maritime Policy for the Union: 
A European vision for the oceans and the seas", the Communication from the Commission COM (2007) 
575 final "An integrated Maritime  Policy for the European Union", and more recently, the Clean Ship 
Initiative proposed by DG Mare in 2009. All these initiatives acknowledge the need for high protection 
of the environment in the context of any maritime policy.  
17 See the link: http://europa.eu/legislation_summar ies/environment/air_pollution/l28031a_en.htm#KEY 
18 See the link: http://eur-lex.europa.eu/LexUriSe rv/LexUriServ.do?uri=CEL EX:32008L0050:EN:NOT 
19 OJ L59, 27.2.98 
20 Directive 2001/81/EC of the European Parliament and of the Council of 23 October 2001 on national 
emission ceilings for certain atmospheric po llutants,  OJ L 309, 27.11.2001, p.22  
 
EN 18   EN pollutants including nitrogen oxides. Current forecast suggest 11 Member States will not 
comply with their ceilings for NOx.  Therefor e, more stringent emi ssion limits for combustion 
engines in recreational craft will however positively contribute to the overall objective of the 
mentioned Directive.  
3.7 Does the EU have right to act?  
With a large number of pleasure boats running ac ross national waters, the significant part of 
recreational craft cruises is in ternational. In the absence of  common emission limits the EU 
national administrations used to create their na tional abatement strategies, which solved the 
problem locally but created anot her problems affecting proper functioning of the internal 
market, which is in contradiction with Article 120 of the Treaty on the Functioning of the EU 
(TFEU).  
Further, Article 191 of the TFEU providing that  European Union's policy on the environment 
shall contribute to protecting and improving the quality of the environment is yet another basis for Union's right to act. Environmental protection is a fundamental component of the 
harmonious and sustainable development of eco nomic activities and non -inflationary growth 
(Article 3 of the Treaty on the European Union).  
Finally, given that the exhaust emission limits have already been totally harmonised at EU 
level through the existing Directive, the revi sion of these limits is within the exclusive 
competence of the Union, and therefore, the appli cation of the principle of  subsidiarity within 
the meaning of Article 5 (3) of the TEU does not arise. 
3.8 How is the current situation likely to evolve?
 
The exhaust emission levels set by Directive 2003/44/EC would become outdated over time 
and no longer meet societal needs for a better ambient air quality nor reflect the technical 
and scientific development in exhaust emi ssion abatement technologies for recreational 
marine engines.  
Lower emission requirements for recreational craft engines will be a disincentive for 
European manufacturers to innovate and thus le ad to a situation where in a longer term 
perspective they would loose their competitive position. This will be particularly true for 
enterprises – mostly SMEs - s upplying solely the EU market. 
Finally the EU market could also attrac t new third country manufacturers which may 
strengthen their position in the EU market by selling lower environmentally performing and 
therefore cheaper engine s in the EU market.  
Not acting on the EU level could lead some Member States to introduce local stricter 
measures or it may lead even to the ban of use of the recreational craft in particular areas.   
 
 
  
 
EN 19   EN 4.  OBJECTIVES 
The overall objective of this initiative is to further improve the environmental performance of 
recreational craft and thus to better protect the environment and human health, while at the 
same time ensure equal regulator y conditions with the EU main trading partners and a smooth 
functioning of the inte rnal market for RCD. 
GENERAL SPECIFIC OPERATIONAL 
1) Protect environment and 
human health  1) Improve the 
environmental performance of RC 
  1) Revise exhaust emission 
limits. 
 2) Revise limits for noise 
emissions 
 3) Revise safety 
characteristics of the RC 
3) Prevent fragmentation of the internal market  caused by different national requirements on the characteristics of RC 
   
1) Revise exhaust emission 
limits. 
 2) Improve the functioning of 
the internal market  
      
4) Protect vulnerable 
enterprises (SMEs in particular) from the worsening their position on 
the market and potential job 
losses because of complying with the new legislation.  
 4) Introduce mitigating 
measures for the most vulnerable RC market operators in Europe (SMEs).  
 
 
EN 20   EN 5) Provide the EU RC 
industry as well as citizens with legal certainty.  
 5) Align the RCD with the 
NLF 
  
3) Promote the approximation 
of the emission limits worldwide 6) Reduce additional 
compliance costs from different regulatory regimes 1) Revise exhaust emission 
limits. 
  
 5.  POLICY OPTIONS  
A wide range of options that could achieve the above mentioned objectives has been taken 
into consideration.  
5.1 Policy options discarded early in the impact assessment process  
5.1.1 Option 1: Self regulation for exhaust emissions (Voluntary code of the industry) 
This option consists in the introduction of fu rther emission limits by a non-regulatory measure 
(e.g. by means of a voluntary industry code). Th e possibility of introducing more stringent 
emission limits through a non-legislative instrument  has been assessed in particular with 
regard to the following aspects: 
• The compatibility between more stringent li mits of the non-legislative instrument and 
the legally binding ones of th e Directive (and other legisl ation in force outside the 
EU). The need to ensure legal certainty for industry stakeholders has been raised in 
this context as being of major concern.  
• The need to balance the interests of globa lly operating industry stakeholders on the 
one hand and those that are operating ex clusively on the Union market and may 
suffer from a system geared to serve the interests of those engaged in international trade. If self regulation is left to the will of the manufacturers, the ones which are active worldwide are likely to soon benef it from a comparative advantage compared 
to the ones which are active locally. Indeed, it will be easier for them to achieve 
economies of scale while following the national rule they want. 
• Uncertainty whether appropriate monito ring and enforcement tools could be 
developed and implemented to ensure a pr oper functioning of the non-legislative 
instrument. 
Whereas the Member States and environmental stakeholders doubted about the fulfilment of 
environmental targets, the industry feared that  the manufacturers from third countries would 
not respect the limits. Both, the Member States authorities as well as industry rejected this 
option mainly because of legal uncertainty of voluntary limits. 
 
EN 21   EN 5.1.2 Option 2: Discontinuing existing EU action (Repeal of the exhaust and noise 
emission limits from the Directive) 
Sub-option 2.1 Full repeal of the exhaust and noise emission limits from the Directive  
The Annexes I.B and I.C. in troduced by the Amendment 2003/44/ EC would be repealed and 
Member States would impose their own tailor made emission limits.   
Repealing the current provisions on exhaust and noise emission limits would enable the 
national administrations to introduce their own limits, precisely for the areas, where it is 
needed. The national authorities could set more lenient limits or no limits for the areas where 
the use of pleasure boats is not so intensive. However, this option entails the risk that polluting engines, which are often imported from  third countries will be more frequently 
placed on the market and that the engine manufac turers would have fewer incentives to invest 
into the development of cleaner models. Furt hermore, the internal market would become 
significantly distorted due to  various limits in place. 
During the discussions on the revision of the RCD, stakeholders refused this option as it will 
result in stepping back in the development of the sector. This option could be considered only 
if there were no internal trade between the Memb er States. As the option would not lead to the 
requested improvement of environmental character istics of marine engine s and could lead to 
the fragmentation of the internal market, the option is discarded from the beginning. 
Sub-Option 2.2 Repeal of the exhaust and noise emission limits and the use of informative 
labels on the engines instead  
With this sub-option, it is proposed that, wh ile the exhaust and noise emission limits are 
repealed, a system of informative labels on the engines is put in place in order to inform the consumers about the exhaust and noise emission characteristics of the engine. Each engine 
installed in the recreational craft or intended to be  installed, would have to  bear such a label to 
be affixed by the person placing the e ngine or the boat on the EU market.  
Although it might lead to consumer awareness, this option is likely not to have any positive 
impact on the environment given that the only potential protection of the environment would 
lie in the consumer choice to buy a more environment-friendly cr aft. This entails however the 
risk that the consumers would not make the choice of these environment-friendly products 
and that the measure would have no effect on the environment. Moreover, as demonstrated 
and reported by studies made in the car sector , it is likely that a substantial number of 
consumers in the RC sector might also prefer cheaper and more polluting engines rather than clean, but more expensive ones.
21 Therefore, the impact on the environment would be very 
limited with this option. In addition, it is un likely that the cons umers will examine the 
engines' labels before deciding to buy a boat. The usefulness of such label would therefore be 
questionable and disproportionate to the bur den and costs generated for affixing it.  
                                                 
21 Some studies have shown that the first determinant in the choice to buy a car for a company is the 
relationship it has with the retailer. The second fact or entering in the purchasing choice is the brand 
name of the car. The environment criterion therefore is not an importa nt factor in the buying decision. 
This would even more true in case of indivi dual consumers rather than of companies.  
 
EN 22   EN As a significant part of the recreational cr aft placed on the EU market are second-hand22  
boats imported from third countries, the respon sibility of testing the boat, estimating the 
emission limits and affixing the label would la y in this case on the pr ivate person importing 
boats for his/her own use. The emission values testing would considerably increase the costs 
of such private importers. 
The option of introducing the informative emission la bels is not in favour of stakeholders as it 
would not lead to the intended goal to improve environmental characteristics of recreational 
marine engines as well as it would mean the ad ditional administrative bu rden for the industry.  
5.1.3 Option 3  - Modification of essential requirements on safety  
A revision of safety requirements, in particul ar with regard to new boat design categories 
should be achieved. However, the TNO Study 2004 concluded th at there is no scientific 
evidence for the need to change the design categories.   
In spite of some minor clarifi cations made in the essential sa fety and design requirements, the 
concerns described above have not been furt her assessed because there was no sufficient 
evidence to justify possible changes.  
5.2 Policy options retained for further analysis  
5.2.1 Exhaust emission limits for engines  
Option 1 - No change  
The existing exhaust emission limits  in the Directive remain as defined by the amendment 
2003/44/EC. 
Option 2 - Stricter exhaust emission limits (Stage II) 
This option foresees the possibi lity of introducing a new Stage of the exhaust emission limits. 
Five possible scenarios to restrict the limits depending on the engine’s power (P N) have been 
discussed. Four scenarios were develope d by TNO in the Stocktaking Study 2004 and 
assessed by ECNI in the IA Study 2006. The in troduction of these four  scenarios was the 
answer to a request of the Council and the Eur opean Parliament to develop more stringent 
exhaust emission limits based on the technological  development in the se ctor. These scenarios 
considered the alignment with  the NRMM Directive as regard s CI engines and introducing 
new stricter limits for SI engines. The alignment with the NRMM Directive was considered because of the similarities of the engine techni ques and markets. After the assessment of the 
impacts of these four scenarios (see details below) the Commission deemed it necessary to 
develop a more ambitious but still economically  sustainable scenario. Scenario 5 has thus 
been developed and assessed by ARCADIS in the Complementary Impact Assessment Study 
2008. 
 
                                                
 
22 It is almost impossible to have a precise number of how many second hand boats there are in the 
European Union: indeed they are no t registered in all countries and some second-hand boats are bought 
in the US on the Internet, it is therefore impossible to monitor all the second hand boats that are bought 
and brought into the EU.  
 
EN 23   EN Table 7: Overview of five scenarios  
Scenario 1   Engine category Legislation to 
comply with Comment 
SI engines  All SI engines RCD Stage I  Limits of 4-stroke SI engines 
applicable for all engines 
CI engines   P N > 37kW NRMM Stage IIIA23 Limits for propulsion engines of 
inland waterway vessels 
  P N < 37kW RCD Stage I  
  
Scenario 2         
SI engines  All SI engines RCD Stage I  75% of HC+NOx limits of 4-
stroke SI engines  
CI engines  P N < 18kW RCD Stage I  
  
   PN 18 kW - 37kW NRMM Stage II  Limits for propulsion engines of 
inland waterway vessels 
  PN > 37kW NRMM Stage IIIA Limits for propulsion engines of 
inland waterway vessels 
Scenario 3         
SI engines   P N > 30kW RCD Stage I  75% of HC+NOx limits of 4-
stroke SI engines  
  PN < 30kW and 
PWC engines  RCD Stage I    
CI engines  P N < 18kW RCD Stage I  
  
   PN 18 kW - 37kW NRMM Stage II  Limits for propulsion engines of 
inland waterway vessels 
  PN > 37kW NRMM Stage IIIA Limits for propulsion engines of 
inland waterway vessels 
                                                 
23 Table with the NRMM Stage IIIA limits available in Annex VI 
 
EN 24   EN Scenario 4         
SI engines   P N > 30kW RCD Stage I  75% of HC+NOx limits of 4-
stroke SI engines  
  PN < 30kW and 
PWC engines  RCD Stage I    
CI engines   All CI engines NRMM Stage II  Limits for propulsion engines of 
inland waterway vessels 
Scenario 5         
SI engines  All SI engines US EPA emission standards for new non-road SI 
engines, equipment and vessels  
CI engines   All CI engines US EPA emission standards for marine diesel 
recreational engines  
 
Scenario 1  harmonises Stage I limits for all SI engi nes and aligns the limits for CI engines 
with the NRMM standards.  
Scenarios 2-4  significantly restrict SI engine limits  and align CI engine limits with the EU 
NRMM legislation with different  levels of stringency.  
Scenario 5  proposes to harmonise the limits for SI  and CI engines with the US EPA 2008 
rules. 
The assessment of scenarios 1-4 demonstrated that even though the environmental effect 
would be satisfactory, the high compliance cost s and possible job losses would outweigh the 
reduction of the exhaust emissions. Annex VI provi des a detailed comparison of the scenarios.  
Following this analysis, the scenario 5 seems to be the most suitable scenario for further 
evaluation. Consequently, this scen ario is considered in the Im pact Assessment as option 2.  
Option 3 - Stricter exhaust emission limits (St age II) combined with mitigating measures 
to limit negative economic/social effects 
The stakeholders’ consultation revealed that the introduction of higher emission limits may 
have negative economic and social effects. Th erefore, option 3 was de veloped to look into 
different possibilities to tighten the rules fo r exhaust emissions while at the same time 
including a mitigating measure to limit negativ e economic and social impacts. The option 3 is 
divided into sub-options according to th e type of mitigating measures used. 
  
 
EN 25   EN Sub-option 3.1 – Use of a flexibility scheme 
An option to mitigate the effects of stricter exhaust emission rules might be the introduction 
of a flexibility scheme as enshrine d in Article 4 of Directive 97/68/EC24  on the emission of 
gaseous and particulate pollutant s from engines to be installed in non-road mobile machinery 
(NRMM). Under this directive a CI engine ma nufacturer may place on the market, on request 
by an equipment manufacturer and when perm ission being granted by an approval authority, 
during the period between two successive stages of emission limit values, a limited number of engines that only comply with the previous st age of emission limits." The idea for the RCD is 
to allow the engine manufacturer s to place on the market a li mited number of recreational 
marine engines compliant with the previous stag e of emissions, still after the entry into force 
of new emission limit values.  
This meets also the measures provided in the US legislation with the most widely used 
provision being the Average, Baking and Trading  system (ABT) which is part of most 
emission control programs. It allows manufactur ers to certify engines with emissions above 
the applicable emission standard, provided that the emissions differential is offset by engines 
certified below the standard. Credits can be tr aded with other companies or saved for later 
use. Another mitigating measure in the US is  the hardship relief that addresses unusual 
circumstances which may affect companies outside their control. Similar as for the ABT this 
measure is however not appropriate to the EU du e to the absence of a central monitoring unit, 
the creation of which would be disproportionate. The idea had already been discussed in the 
context of the last amendment of the NRMM Dir ective where it was reje cted because of its 
incompatibility with the EU legislative and administrative sy stem. Finally the US also provide 
a flexibility mechanism that allows SMEs to postpone the redesign of low volume engines or 
difficult engine categories and as such to decr ease the cost of compliance with new emission 
limit values. 
Sub-option 3.2 – Use of a transitional peri od for all engine manufacturers (3 years) 
New and revised regulations mostly provide additional lead time before new standards take 
effect for business. In a similar way it is propos ed as an alternative mitigating measure   to 
grant additional lead time to all engine manufact urers before their engines shall comply with 
the new emission standards. It gives the compan ies more time to redesign the engines and to 
adapt the production lines to the new technologi es. Additional lead time had also been 
provided under Directive 97/68/EC  to manufacturers of engines used in certain small hand-
held equipment for which technological solutions were not available yet. The proposal is to 
provide a three years transitional period  after the entry into force  of the revised RCD. 
This transitional period would be composed  of the normal transposition period of EU 
Directives by the EU Member States (2 year s) plus one additional year for technical 
adaptation. 
5.2.2 Noise emission limits for engines
.  
Option 1 - No change  
The existing noise  emission limits  from the recreational craft in the Directive remain as 
defined by the amendment 2003/44/EC. 
                                                 
24 OJ L 59, 27.2.1998, p. 1 , Consolidated version  of Directive 97/68/EC 
 
EN 26   EN Option 2 – Stricter nois e emission limits   
This option looks into the introduc tion of stricter noise limits for engines on the EU level and 
how these would contribute to the abatemen t of noise produced by recreational craft. 
5.2.3 Alignment of the RCD with th e New Legislative Framework  
Consequently to the adoption of Regulation (EC) No 765/2008 and of  Decision 768/2008/EC, 
the Recreational Craft Directive has to be br ought in line with the principles of New 
Legislative Framework. It m eans basically the inclusion of  the chapters describing the 
obligations of economic operators, the compet ences of conformity assessment bodies and 
market surveillance authorities, new conform ity assessment modules and the status of CE 
marking. 
6.  ANALYSIS OF IMPACTS  
6.1 Impact of stricter exhaust emissions limits  
6.1.1 Option 1 - No change of limits 
There are two main concerns related to this opt ion: environmental and trade concerns. Firstly, 
it has been demonstrated in Section 3.1.1.1 (see Table 1) that NOx con centrations do exceed 
the environmental quality standards in coast marinas. Secondly, if the current limits would continue to apply, the engine manufacturers and especially ma rinisers may be tempted to 
install more polluting engines complying with  Stage I instead of the cleaner but more 
expensive engines complying with the more stringent US standards.
25  
Another concern related to this option is the fragmentation of the Internal Market due to the 
likely adoption of diverse regi onal regulations as mentioned in Section 3.7. Industry would 
continue to offer two different products and will not be able to benefit from economies of 
scale.  
6.1.2 Option 2 – Stage II of the exhaust emissions limits  
Implementing Stage II of exhaust emission limits  would follow the t echnological progress of 
the recreational marine engines as well as the EU commitment to support less polluting 
technologies and the alignment of the limit le vels internationally. The option would also 
prevent a fragmentation of the Internal Market  because the restricting of the limits would 
satisfy those Member States w ho would intend to introduce various restrictive measures 
aiming at reducing emissions from recreational crafts.  
Environmental impact 
In order to assess the environm ental impacts a formulaic appro ach has been adopted allowing 
the emissions to the air to be modelled under  each regulatory option. The details of the 
methodology applied are explained in Annex VII.  
                                                 
25 The engine manufacturers declare to  include their R&D and certificatio n costs to the in creased price of 
the cleaner engine.   
 
EN 27   EN For the purpose of modelling ai r quality, it has been assumed that all emissions from 
recreational craft exhausts ente r the air. The assessment does not consider the impact of so-
called wet exhaust emissions to the water beca use only a marginal proportion of the exhaust 
pollutants remain in the water. 
Table 8: Total emissions change measured in tons per year 
  HC+NOx 
(tons/year) PM 
(tons/year)  CO 
(tons/year) 
Option 1 - No change of the limits 40 907 539 153 142 
Option 2 - Stage II 30 061 296 184 634 
Source: ARCADIS Complementary Impact Assessment Study July 2008, p.57 
According to the findings of the adopted appro ach the yearly emissions of HC+NOx, PM for 
Stage II are lower than for the baselin e scenario. CO emissions increase.  
Table 9: Average emission change / year compared to the Option 126 
  HC + NOx  PM CO 
Option 2 - Stage II   -26,51% -45,08% +20,56% 
For the monetization of environmental benefits , the Cost-Benefit Analysis of Policy option 
scenarios that have been devel oped for the CAFE Programme (2005)27 have been used. 
Environmental benefits are expressed as mone tized damage savings per tonne of the air 
pollutant. The methodology of monetiza tion is described in Annex IX. 
For calculation purposes we assume the NOx em issions to represent 40% of aggregated 
HC+NOx emissions 28 .  
Table 10: Value of damage avoided / year compared to the Option 1  
 Value of damage 
avoided (M€) / 
year (NOx)  Value of damage 
avoided (M€) / 
year (PM)  
Option 2 - Stage II   
9,5 M€ - 45,5 M€ 
  
3,2 M€ - 18,2 M€ 
 
 
 
                                                 
26 Detailed calculation of the emission reductions available in Annex VIII 
27 http://www.cafe-cba.org/assets /marginal_damage_03-05.pdf . 
28 Source: ARCADIS Complementary Impact Assessment Study July 2008, page 57 
 
EN 28   EN Economic impact 
Compliance costs are purely related to costs incu rred by engine manufacturers and marinisers 
and do not include downstream economic impacts related to competitiveness, changes in the market structure, changes in fuel economy, etc.  
Compliance costs are evaluated in  the scope of the time horizon within which these costs are 
made: Fixed costs occur in the course of first years, later they are fully amortized. They are 
linked to the development, production, validation and certification of Stage II engines. This 
includes recertification, redesign  of components, adaptations to  assembly line, environmental 
validation tests, etc.  After a particular period of time, some fixed costs will appear again (e.g. 
renewable of certificate). Variable costs remain  a cost item in the long run but will probably 
decrease as manufacturers lear n over time to produce the engi nes with the new technologies 
or after treatment at a lower cost. These figures are for guidance only and should be 
regarded as orders of magnitude rather than absolute figures. For the unit costs, see 
Annex X.  
Table 11: Estimation of total compliance cost s linked to the Option 2 - Stage II limits  
 CI Engines SI Engines 
Option 2 ( Stage II)   5,7 M€ to 19 M€ / year 5,1 M€ to 10,6 M€ / year 
Source: ARCADIS Complementary Impact Assessment Study July 2008, Table 6.13, page 85 
The wide range of cost estimates is due to the large variety of the variable costs for lower 
power engine families (P N < 75kW). The higher costs indicate d in Table 11 relate to engine 
manufacturers which serve only the EU market and have no e xports to the US including 
indirect ones via boats in wh ich their marinised engines ar e mounted. Small and medium 
sized engine manufacturers may face the tempor ary discontinuation costs including loss of 
profit and loss of market share by not being able to provide a certain engine model to the 
market. The details of the cal culation of compliance cost s are provided in Annex X. 
It has to be noticed that th e compliance costs are calculated assuming that the new standards 
are equally phased-in in the EU  and in the US. Harmonisation  of RCD emission standards 
with the recently adopted US EPA emission stan dards will have a different impact depending 
on whether companies are active on both markets or only on the EU market. For those  which 
are active on both  markets the costs to meet the emission standards can be regarded as sunk 
costs as they have to be made for the US mark et already. Their fixed costs will be limited to 
re-certification and relate d testing and calibration.29 The situation is however different for 
those companies which supply only the EU mark et which have to bear the full compliance 
costs. These are mainly SMEs. 
Option 2 (Stage II) would be e ffective to the extent that it  would meet both general and 
specific objectives pertinent to the environment as described in section 4 for most European 
companies. However, it creates difficulties fo r SMEs as they would be unable to comply 
timely with the new exhaust emission limits.  
                                                 
29 These are common for CI and SI engine manufacturer s.  They can reach up to 19 900€. The table in 
Annex X provides the details. 
 
EN 29   EN Indeed SMEs do not have the same liquidity and access to finance as bigger companies to 
finance these investments. Hence they supply a li mited market they will not be able to spread 
fixed costs over a larger production and use econom ies of scale, as bigger manufacturers can. 
The SME engine manufactures also do not be nefit from the experience gained from 
redesigning of engines for other user markets,  as this is the case of their large volume 
competitors who do not only supply marine engines.   
As a result, SME engine manufacturers may be  obliged to limit their production of engine 
ranges as they will not be able to comply with the new limits  for all ranges at the same time. 
In cases where compliance costs are too hig h, companies are likely to discontinue the 
production of certain models. Disc ontinuing product ranges is ofte n very costly, especially if 
products have not reached the end of their lifetim e or in case of newly developed engines. The 
costs linked to discontinuation include loss of profit generated by the models and additionally the loss of market share by not supplying  these models. Recrea tional craft engine 
manufacturers generally k eep a wider range of power categories of engines. 
The stakeholders’ consultations revealed th at SME SI engine ma nufacturers producing low 
power engines will have the highest difficulties to comply with the ne w Stage II limits due to 
their limited R&D capacity to redesign the engi nes. Low power SI out board engines (i.e. P
N < 
15 kW) are particularly affected as it requires  the same high investment to develop the new 
engines while at the same time due to the lower revenue of such engine categories, the 
payback time is longer than for the high power engine categories.  
Total compliance costs (mainly dedicated  to the R&D) of these manufacturers30 may reach up 
to 1,8M – 5M € or 67,35% of their annual turnover while a maximum ratio for large engine manufacturers is 2,76%.
31  
Particular case of CO limits 
Option 2 leads to a relaxation of CO limits. As explained in the chapter 3.1.1.1 CO has an 
impact on human health and the limits provi ded in the current RCD aim at avoiding any 
serious risk of expose for the boat user and other persons. Ev en with the proposed relaxation 
of the limits the CO emitted by the recreational marine engines stays well below the environmental quality standards therefore should not pose significantly greater risk to user’s 
health. However, the appropriate CO emission limits for recreational cr aft may be reflected 
upon in a future revision.  
Keeping CO emission limit values at the curre nt level while at the same time NOx, HC and 
PM limit values are significantly restricted in, the SI outboard engines and PWC would 
require the use of a catalyst t echnology which is not yet techni cally feasible in the marine 
environment. The development of catalyst outb oard program would lik ely require 2-3 year 
completing and converting all outboard engine ca tegories to catalyst tech nology is likely take 
8-9 years
32. The costs of redesigning an engine family can run up to 30 million € which 
                                                 
30 That is small and medium sized engine manufacturers producing low power engines  
31 Based on consultation results. ARCADIS Impact Assessment Study (2008), p. 90-93. Details of impact 
on competitiveness of large and small companies described in Annex XII  
32 Source: Development and Demonstration of a Low Emission Four-Stroke Outboard Marine Engine 
Utilizing Catalyst Technology , Mercury Marine,  CARB Technical Seminar, 2010  
 
EN 30   EN represents 10–25 % of EU annua l sales of a large outboard e ngine manufacturer in this 
particular engine category. The costs may be especially critical for some solely EU based 
small and medium sized SI en gine manufacturers with the annual turnover not exceeding 20 
million €33. 
6.1.3 Option 3 – Stage II of the exhaust emissions limits with mitigating measures  
Complying with the new EU emission standards will entail additional costs. The recreational 
craft sector has been serious ly hit by the economic and fi nancial crisis of 2008/2009. The 
sales of new boats decreased up to 50 % in years 2008 and 2009 comparing to 2007.34 Option 
3 would allow maintaining the introduction of higher emission standards while at the same 
time mitigating possible negativ e economic/social impacts.  
Sub-option 3.1 – Use of a flexibility scheme 
In this sub-option, the mitigating measure consid ered would be a flexibility scheme, in line 
with the one in place in the framework of the NRMM Directive 97/68/EC. Similar to the ABT 
provided in the  U.S legisla tion (see under 5.2.1.), the objectiv e is to allow companies to 
optimise their strategy for complying with the required new emission st andards and the reach 
the same absolute level of em ission reduction at lower costs.35   
Environmental impact  
Due to lower emission reductions, introducing a flexibility scheme will result in a less 
positive impact on the environment compared to Op tion 2 (Stage II), which is demonstrated in 
the tables below.  
Table 12: Total emissions change measured in tons per year 
  HC+NOx 
(tons/year) PM 
(tons/year)  CO 
(tons/year) 
Option 1 - No change 40 907 539 153 142 
Sub-option 3.1 - Stage II + Flexibility scheme 31 105 387 180 698 
Source: ARCADIS Complementary Impact Assessment Study July 2008, Table 5.5, page 57 
Table 13: Average percentage chan ge / year compared to Option 1  36 
  HC + NOx PM CO 
Sub-option 3.1 - Stage II + Flexibility scheme  -23,96% -28,20% +17,99% 
 
 
                                                 
33 Source: The Complementary Impact Assessment Study, ARCADIS (2008) 
34 Source: Information provided by ICOMIA 
35 According to the available inform ation there is just one company actually relying on the ABT system; 
other engine manufacturers  consider the administrative costs involved too high. 
36 Detailed calculation of the exhaust emission reductions is provided in Annex VIII. 
 
EN 31   EN Table 14: Value of damage avoided / year compared to the Option 1  
 Value of damage 
avoided (M€) / year 
(NOx)  Value of damage 
avoided (M€) / 
year (PM)  
Sub-option 3.1 - Stage II + Flexibility scheme   
8,6 M€ - 41,2 M€ 
  
2,0 M€ - 11,4 M€ 
 
Economic impact  
Flexibility will result in saved compliance costs for the industry. 
Table 15: Total compliance costs linked to the Sub-option 3.137 
 CI Engines SI Engines 
Sub-option 3.1 -  Stage II + Flexibility scheme  1,2 M€ to 8 M€ / year 4,6 M€ to 10 M€ / year 
Source: ARCADIS Complementary Impact Assessment Study July 2008, Table 6.15, page 86 
In the case of the flexibility scheme provided in the NRMM Directive, the limited number of 
engines to be placed on the market under this scheme is limited by the entry into force of the next stage of emission limits. Since there is  no such stage in the RCD Directive, the 
implementation of the flexibility scheme would require an end date to remain proportional 
and to limit the period for placing on th e market of more polluting engines. 
Furthermore the objective of the flexibility sc heme established under the NRMM Directive is 
to provide the Original Equipment Manufacturer (OEM) 
with additional lead-time for 
adjusting the machine design. The OEM is the la st actor in the production chain, who will 
always depend on the engine manufacturer and the availability of the newly designed engines. 
The time necessary to redesign the machines by the OEM may be very short and substantial 
R&D investments need to be achieved in a lim ited period, which may result in a substantial 
increase of costs. The possibility to use a lim ited number of previous stage engines allows 
balancing this peak in investment costs.   
This scheme can however not be directly transpos ed to the  recreational craft  In the case of 
recreational craft the major development costs occur at the engine  design and production 
while the costs for the boat manufacturer remain  marginal. Therefore the mitigating measure, 
in this case the flexibility, must be provided to  the engine manufactur er and not to the boat 
producer.  
While in case of NRMM the OEM will only use th e flexibility scheme when it is needed to 
overcome a momentary period of peak R&D inve stments, the engine manufacturers in the 
case of recreational craft would be tempted to fu lly use the Flexibility Scheme and to place on 
the market maximum of engines compliant with  the previous stage even if this is not 
                                                 
37 Methodology and assumptions used for calculation of compliance costs available in Annex X 
 
EN 32   EN economically needed. This measure would disqualify its mitigating effect for the companies 
in serious economic troubles and would resu lt in an indirect postponement of the 
implementation date of the new Stage of exhaust emission limits. 
Other problems could also rise from the impl ementation of the flexibility scheme. In the 
framework of the NRMM Directive, the flexib ility scheme is managed by the established 
national approval authorit ies. It would be nece ssary to create a similar authority in the 
framework of the RCD Directive, thus creating costs for the public administration as well as 
costs for the enterprises that occur in the ad ministrative procedure. The administrative burden 
could be substantial for SMEs, as the latter may in cur opportunity costs, as  part of their staff 
would need to be given up for administration burden related activities rather than core tasks. It 
could potentially disrupt company’s normal operations. 
From the industry’s point of view, the flexib ility scheme would be a convenient mitigating 
measure as the companies could place on the market a number of non-compliant engines and delay the investments. On the other side, doubts have been expressed by enforcement 
authorities about monitoring pos sibilities and effectiveness of  this scheme and additional 
administrative burden.  
Sub-option 3.2 –– Use of a transitional period for all engine manufacturers 
The aim of this option is to grant a transitiona l period of 3 years to all engine manufacturers 
so that they have enough time to adapt to the new rules. Th e transitional period reflects the 
time when the exhaust emission limits will become fully applicable in the US so the production of majority of engi ne manufacturers should comply with these limits already. The 
period would start from the entry into force of the Directive, meaning that approximately two 
years would overlap with the transposition period of the Directive, leaving one extra year for 
adaptations.  
Environmental impact  
Table 16: Average percentage chan ge / year compared to Option 1
38 
  HC + NOx PM CO 
Sub-option 3.2 - Stage II + Additional transition period  -19,88% -33,81% +15,42% 
Table 17: Value of damage avoided / year compared to the Option 1  
 Value of damage 
avoided (M€) / year 
(NOx)  Value of damage 
avoided (M€) / year 
(PM) 
Sub-option 3.2 - Stage II + Additional transition 
period   
7,1 M€ - 34,2 M€ 
 2,4 M€ - 13,7 M€ 
                                                 
38 Detailed calculation provided in the Annex VIII. 
 
EN 33   EN HC+NOx emissions for this option will decrease less than in the case of previous options. 
However, the transitional period seems to be better  choice in terms of d ecrease of PM than the 
flexibility scheme (presented in Sub-option 3.1) . These results are give n assuming that during 
the 3-year transitional time, the possibility to  continue placing on th e market the engines 
compliant with the previous stage of emissions w ill be used to the fullest and that no engines 
compliant with the new limits will be placed on the market, which is  a rather extreme 
assumption unlikely to happen in reality.  
Economic impact 
Certain engine manufacturers or marinisers will encounter problem s to have all their engines 
certified on time unless they are allowed specif ic additional lead time. Such a specific 
measure would therefore help to limit and spread  out the compliance cost s, i.e. guarantee a 
better scheduling of investments rather than ha ving high compliance costs concentrated over a 
very short period of time. If an additional lead time could be granted to  the companies, this 
would allow the engine manufact urers or marinisers to avoid investments on products coming 
close to their end of life and would allow keeping them alive until the new products are ready.  
Table 18: Total compliance costs linked to the Sub-option 3.2  
 CI Engines SI Engines 
Sub-option 3.2 -  Stage II + Transitional period  2 M€ to 8 M€ /year 1,8 M€ to 5 M€ / year 
Source: ARCADIS Complementary Impact Assessment Study July 2008, Tables 6.13 and 6.15, pages 85, 88 
As can be seen in the Table 18, the compliance co sts will be probably lower as the majority of 
engine manufacturers will have spent the R&D cost s already earlier in order to be able to 
comply with the US rules. These costs can therefore be considered as sunk costs.  
Use of a transitional period is generally accepted by stakeholders as a compromise mitigating 
measure which is not burdensome in terms of administration. However, industry considers it 
not fully adapted for the needs of SMEs.  
Sub-option 3.2 would thus be effective to the extend that it meets the general objectives for 
protecting the environment and human health as  well as improving the Internal market, but it 
would fail to fully meet the specific objective for protecting vulnerable enterprises.   
Sub-option 3.3 – Use of a transitional peri od for all engine manufacturers + a specific 
transitional period for small and medium si zed engine manufacturers placing on the EU 
market the SI outboard engines ≤ 15 kW (3+3 years). 
For a very limited number of small and medi um sized engine manufacturers which clearly 
meet the SME definition 39 the new emission standards will remain a serious challenge. This 
is why, after applying the SME test  as described in A nnex XIV, it is recommended to add an 
additional SME specific mitigating measure. One SM E that would be eligible for this measure 
has been identified during the st akeholder’s consulta tion although a few others may also exist.    
                                                 
39 Commission Recommendation on the definition of SMEs , OJ, L124, 20.5.2003 , p.36 
 
EN 34   EN Environmental impact 
The mitigating measure as proposed in this op tion would relate to at  least one small and 
medium sized SI engine manufacturers. The environmental impact of this mitigating measure is estimated at about 6,16 t ons/year of HC+NOx emissions more comparing to Sub-option 
3.2. It would represent 0,015 % of  the total annual HC+NOx em issions from recreational 
craft. This figure does not make a real differe nce in the overall annual exhaust emissions from 
the recreational marine engines. The PM emission s are not considered here as the SI engines 
do not emit PM.  
Economic impact 
A special transitional period of 3 years (in addition to the 3 years granted already to all engine 
manufacturers) would be grante d to those small and medium sized engine manufacturers who 
place on the EU market the lo w power SI outboard engines.  Contrary to a complete 
exemption from the Stage II for SME SI engi ne manufacturers placing  low power engines on 
the EU market, which would mean a distortion of competitive environment as some of the 
companies would not need to invest to the new technology at all, this option simply provides a 
longer period for adaptation and mitigates the negative economic and social impact. At the 
same time it does not provide a disproporti onate competitive advantage. The proposed 
additional transitional period gi ves a limited number of companie s enough time to adapt their 
production. The time to develop the appropriate  new technology for low power SI outboard 
engines is assumed to be about 6 years. 
If the additional transitional pe riod of 3 years is granted, the small and medium sized SI 
engine manufacturers will be able to upgrade their engine families to the new emission 
standards. These manufacturers will not be forced to limit their product offer. 
The worldwide market share of small and me dium sized SI engine manufacturers is 
negligible (0.5% as reported by ARCADIS). Therefore the impact of this additional 
mitigating measure on the relevant market, which is the global market, remains marginal. The affected companies usually serve only Eur opean market and do not have a chance to 
increase their production capacity  and consequently their mark et share due to the limited 
capacity to invest. The proposed mitigating m easure will not have a negative impact on 
competitiveness of large manufacturers. This was discussed with representatives of large manufacturing companies and no objections were raised.  
A transitional period for all industry and speci fic time granted to SMEs did not receive any 
objection from stakeholders. 
Final comparison of the options 
 
Table 19: Comparison of the environmental im pact measured as emission reduction/ year 
  Average annual 
emission 
reduction of 
HC+NOx (%)  Average annual 
emission 
reduction of PM 
(%)  Average annual 
emission change 
of CO (%)  
Option 1 - Stage I. – Baseline 
scenario 0% 0% 0% 
 
EN 35   EN Option 2 – Stage II of the limits -26,51% -45,08% 20,56% 
Sub-option 3.1 – Stage II + 
Flexibility scheme -23,96% -28,20% 17,99% 
Sub-option 3.2 – Stage II + 
Transitional period -19,88% -33,81% 15,42% 
Sub-option 3.3 – Stage II + 
Transitional period + Specific time 
for SI engine SMEs -19,78% -33,81% 15,36% 
 
Table 19 ranks the Option 2  as the preferred one in terms of reduction of exhaust emissions. 
However, the achieved emission reduction has to be seen in the context of related economic 
and social costs. Therefore, Table 20 compares  the monetized environmental effect with the 
compliance costs resulting from the restriction of the limits. Although the availability of data 
enables to monetize the environmental benefits only for NOx and PM, the positive financial effect may be concluded for all the options. Expected damage savings vastly outweigh the 
expected compliance costs. It is probable th at the overall damage savings would be even 
higher if the savings of HC emissions are included.  
Table 20: Comparison of environmental benefi t / year with the compliance costs / year for 
all options 
  Value of damage 
avoided (M€) / 
year (NOx) Value of damage 
avoided (M€) / 
year (PM) Average 
compliance 
costs (M€) for CI 
engines / year Average 
compliance 
costs (M€) for SI 
engines / year 
Option 1 - Stage I. – Baseline 
scenario 0 0 0 0 
Option 2 – Stage II of the limits 9,5 M€ - 45,5 M€ 3,2 M€ - 18,2 M€ 5,7 M€ - 19 M€ 5,1 M€ - 10,6 M€ 
Sub-option 3.1 – Stage II + 
Flexibility sceme 8,6 M€ - 41,2 M€ 2,0 M€ - 11,4 M€ 1,2 M€ - 8 M€ 4,6 M€ - 10 M€ 
Sub-option 3.2 – Stage II + 
Transitional period 7,1 M€ - 34,2 M€ 2,4 M€ - 13,7 M€ 2 M€ - 8 M€  1,8 M€ - 5 M€ 
Sub-option 3.3 – Stage II + 
Transitional period + Specific 
derogation for SI engine SMEs 7,1 M€ - 34,1 M€ 2,4 M€ - 13,7 M€ 2 M€ - 8 M€  1,8 M€ - 5 M€ 
 
 
 
EN 36   EN Despite the positive environmental effect, Option 2  entails the highest economic and social 
costs. Sub-option 3.1 shows up the solid exhaust emission decrease as well as reasonable level 
of compliance costs and job losses . However, one has to consider that the flexibility scheme is 
not suited for the recreationa l craft sector. The administra tive costs for national market 
surveillance authorities which w ould have to grant and monitor the flexibility scheme may be 
a considerable burden too. Sub-options 3.2 - 3.3 limit the danger of high discontinuation costs 
and enable spreading out other compliance costs in time, which makes the difference between 
these Sub-options and Option 2. For better transparency a table of net economic benefit has 
been added. It aggregates the damage saving s of referred pollutants as well as compliance 
costs for all engines. It keeps the range of lower and higher bound of costs/savings. 
Table 21: Net economic benefit (savings/costs analysis)  
  Net benefit (M€) 
Option 2 – Stage II of the limits 1,9 M€ - 34,1 M€ 
Sub-option 3.1 – Stage II + Flexibility scheme 4,8 M€ - 34,6 M€ 
Sub-option 3.2 – Stage II + Transitional period 5,7 M€ - 34,9 M€ 
Sub-option 3.3 – Stage II + Transitional period + Specific 
derogation for SI engine SMEs 5,7 M€ - 34,8 M€ 
Following the information provided in the Table 22 all options would en tail a price effect 
(price increase) and could also generate a di sruption of the lines of  products, leading to a 
decrease in consumer choice, which would have  a negative impact on consumer welfare. The 
Complementary Impact Assessment Study (2008) quantified the number of jobs directly 
linked to the recreational craf t industry to amount to ap proximately 2300. The job losses40 
derive directly from the price increase and the price effect: increase in price will result in 
important decrease in demand because of the elas ticity of recreational craft, the decrease in 
demand will lead to job losses. The job losses  in engineering positions may be linked to 
discontinuation of those engine families that ge nerate too low profit to invest money to make 
them compliant with the new limits. Such a di scontinuation is probable for Option 2 and Sub-
option 3.1. Job losses in marketing and sales positio ns may be caused by the loss of market 
share.  
Table 22: Comparison of the social impact  
  Total job losses for CI 
engines  Total job losses for SI 
engines  
Option 1 - Stage I. – Baseline scenario - - 
Option 2 – Stage II of the limits less than 100  less than 100  
                                                 
40 Quantification of job losses for Option 2 and Sub-option 3.1 described in Annex XIII 
 
EN 37   EN Sub-option 3.1 – Stage II + Flexibility 
scheme less than 10  less than 100  
Sub-option 3.2 – Stage II + Transitional 
period job losses unlikely  less than 100  
Sub-option 3.3 – Stage II + Transitional 
period + Specific derogation for SI engine 
SMEs job losses unlikely  job losses unlikely  
 
Such job losses are unlikely to occur in the Sub-option 3.3  since no price increase or loss of 
market share should occur. Although the same cost s will arise in this sub-option, they will be 
spread over a longer period of time. Theref ore, unlike the other options, the enterprises 
(especially SMEs) will not have to support these high costs on a very short time span and will 
support these cost over a longer pe riod of time. This will allow the manufacturers to reduce 
the price increase to a minimum, and to keep th eir market shares. As the price effect will be 
limited for Sub-option 3.3 , the demand remains steady and job losses will be unlikely or 
minimised. Spreading the costs over a longer peri od of time should allow the industry to keep 
the current jobs and not to resort to job cuts. Similarly, spreading the costs will also allow the 
industry to continue producing all the lines of  products. No decrease in consumer choice 
should therefore occur. As a consequence, in  this last sub-option, the negative impact on 
consumer welfare and the overall so cial impacts are the lowest.  
Basically all the presented options meet the general objectives as they firstly lead to the 
decrease of air pollutants in  the environment and secondl y they provide the common 
legislative framework for the engine manufac turers operating within the EU market and 
thirdly ensure the alignment of engine  emission requirements with the US.  
However, Option 2 does not sufficiently meet the specific objective to protect vulnerable 
enterprises from worsening their position on the market. Considering the SMEs as the most 
vulnerable companies in the se ctor, the Sub-option 3.3 meets th e best designed objectives.  
Sub-option 3.3 is the most effici ent compromise for SMEs in te rms of environmental effects 
combined with economical and social losses . Therefore it becomes the preferred option. 
Tables 23-25 compare the environmental impact  of the preferred opti on with the baseline 
scenario and with the EQS. The preferred opti on will enable to decrease the most exposed 
pollutant – NOx in Lake Marinas under the EQS level and will contribute to the decrease of 
NOx in Coast Marinas . 
 
Table 23: Estimated concentrations of selected pollutants for Coast Marina 
Pollutant   EQS (µg/m3) Current situation 
baseline 
 (µg/m3) Preferred option 
(µg/m3) 
NOx long term   40 17,54 14,07 
NOx short term 200 599,47 480,89 
PM long term   40 0,26 0,17 
 
EN 38   EN PM short term 50 0,59 0,39 
CO long term   350 231,26 266,78 
CO short term 10 000 3 093,82 3 569,03 
 
Table 24: Estimated concentrations of selected pollutants for Lake Marina 
Pollutant   EQS (µg/m3) Current situation 
baseline 
 (µg/m3) Preferred option 
(µg/m3) 
NOx long term   40 13,17 10,56 
NOx short term  200 213,97 171,65 
PM long term   40 0,27 0,18 
PM short term 50 0,56 0,37 
CO long term   350 137,98 159,17 
CO short term 10 000 1 121,75 1 294,05 
 
Table 25: Estimated concentrations of se lected pollutants for Inland Waterways 
Pollutant   EQS (µg/m3) Current situation 
baseline 
 (µg/m3) Preferred option 
(µg/m3) 
NOx long term   40 0,16 0,13 
NOx short term 200 2,5 2,01 
PM long term   40 0 0 
PM short term 50 0,02 0,01 
CO long term   350 3,73 4,30 
CO short term 10 000 29,64 34,19 
 
 
6.2 Impact of the noise emis sions limits for engines  
Option 1: Impact of no policy change 
The current noise limits for recreational craf t would remain as provided by the amendment 
Directive 2003/44/EC. They were harmonised to ease the functioning of the internal market.  
 
 
EN 39   EN Table 26: Current noise emission limits in the RCD  
Rated engine power 
(kW) Maximum sound pressure 
 Level = L pASmax  (dB) 
PN ≤ 10 67 
10 < PN ≤ 40 72 
PN > 40 75 
Furthermore, in line with the provisions of the Treaty, Member States may take tailor-made 
national measures to further protect some sensitive areas from noise emitted by recreational craft, such as limiting the speed and use of boats. It enables to effectively restrict noise and to 
achieve environmental benefits through specifica lly designed measures for the areas in which 
craft operates.  
Sound impact greatly depends on the number of recreational craft used  and the duration of 
activities. Therefore, measures such as speed re striction restricted use of the craft at certain 
hours seem to be more effective measure fo r further reducing noise. Table 27 shows that 
speed limits or restricted use at certain hour s could be a more effective solution than a 
requirement for all  boats or engines to m eet severe standards. 
Table 27: Estimated environmental sound impact for some typical cases, expressed in dB
41  
Low Intensity High intensity  
Situation Intensity (number 
of hours) Sound Impact 
(dB) Intensity (number 
of hours) Sound Impact 
(dB) 
Canal (50 m) 15 43 45 47 
Lake (200m) 
Boats 
PWC  
10 
0.2  
50 
42  
40 
0.8  
56 
48 
Marina (200m) 
Boats  
1  
40  
7  
49 
Passing (25 m) 
Boats 
PWC  
2 
2  
38 
45  
20 
20  
48 
55 
Source: Stocktaking Study, TNO (2004) 
These levels should be compared ag ainst following target values:  
 
                                                 
41 Assumptions for measurement of environmental noise impact settled in Annex XII 
 
EN 40   EN Table 28:  The permissible levels differentiated for different types of areas and their use  
Area concerned Target value (in dB) 
Residential Area 55 
Recreational Area 40-60 
Park / Nature Conservation Area 30-40 
Source: Stocktaking Study, TNO (2004) 
Both tables show that the environmental sound impact on humans varies for normal use 
depending on the area in which the craft is used. The enviro nmental sound impact on humans 
varies for normal use between 38 dB (A) and 56 dB  (A), which is not critical for residential 
areas, some types of recreational areas and for boat user’s health. For other types of 
recreational areas this could be  too high for parklands and cons ervation areas it is clearly too 
high. In those cases additional measures such as speed limits and restric tions of use will be 
necessary. Speed limits alone might not be enough, especially for low power engines where the sound from the engine dominates over the sound from the moving hull.  
Another consequence of retaining the current limi ts and relying on reduction of the use is that 
the companies would not have to invest in new technologies to further reduce noise.  
Despite its benefits, this option presents also a risk: as Member States are free to implement 
different national, tailor-m ade, measures, this could lead to tr ade distortion or barriers to trade 
within the EU, or measures having an equivalent  effect to a quantitativ e restriction (contrary 
to Article 34 of the TFEU. Such measures can  only be implemented by Member States since 
they have to be specifically designed for specific areas. Considering the principle of 
subsidiarity and the repartition of competences  between the Union and the Member States, 
such specific measures shall be taken at the national level and not at the Union level.  
Option 2: Impact of stricter noise emissions limits  
The option to introduce more restrictive nois e emission limits for engines only has a limited 
real impact on the environment and on overall  sound levels. The TNO study provides several 
arguments showing that the reduction of engines'  noise is not the key to reducing the overall 
craft noise.  
First of all, noise from the boa t does not entirely resu lt from the engine's noise emissions but 
rather, they are a result of a combination of fa ctors (use/speed of th e boat, boat structure, 
subjective criteria linked to the area, the person listening etc.).  Therefore, since the directive 
can only act on the noise emission from the engine s, its impact on the total noise felt by the 
user/bystanders will remain marginal. 
Moreover, although the sound level itself is mainly responsible for some negative effects, the 
annoyance  experienced by human beings depends on other aspects, including the type of 
sound (level, frequency, content,  temporal variation, etc.), the type of surrounding (harbour, 
recreational area, parkland or conservation areas, etc.), time of  occurrence (type of day, day or 
night, etc.) and several subjectiv e and personal aspects such as the feeling about the type of 
source and the usefulness of the source and it s use. The use of a recreational craft can 
therefore be just as impor tant as the sound emission  of that craft; and even  the sound emission 
 
EN 41   EN of the craft is determined larg ely by its user. In addition, seve ral studies have shown that the 
perceived annoyance is not based on the sound le vels alone and perceived annoyance is much 
higher in case of personal watercrafts (PWC).42 
Furthermore, engines' noise emissions are only a small part of the overall noise emitted by the 
craft. Table 29 shows the expected sound reducti on for the overall craft when decreasing the 
noise emissions from the engines.  
Table 29:  Overall sound reductions that can be obt ained from reducing noise from engines   
Type of engine  Sound reduction of the engine 
(in dB) Total craft’s sound reduction 
obtained (in dB) 
Outboard P N > 40 kW -6 / -8 -3 
Outboard 10 < P N < 40 kW -4 / -5 -3 
Outboard P N < 10 kW -4 / -5 -3 
PWC P N > 40kW -4 
-3 -3 
-2 / -1 
Source: Stocktaking Study, TNO (2004) 
If only measures are taken in order to modify  the engines, the maximum achievable total 
sound reduction for craft with outboard engines in the higher power range is about 3 dB. 
However, to achieve such a reduction, outboard engine's emissions would have to be reduced 
by at least 6 dB, which is quite significant. For the lower power range the potential is 
somewhat higher: a total sound reduction by 3 dB  requires ‘only’ 4 dB  reduction for the 
outboard engine, still a significant reduction. Also  for PWCs the required sound reduction of 
the engine is about 4 dB in order to obtain a total sound reduction of 3 dB. Moreover, if the sound contribution of the engines is only reduced by 3 dB, that would result in an overall 
reduction of the sound impact of 1 to 2 dB which is not significant. 
The cost involved in the modification of e ngines entailed by the introduction of stricter 
standards should also be taken into account. Manufacturers will have to bear R&D and investment costs to introduce new technology to  achieve higher noise emission standards.  
Contrary to the exhaust emission limits, there is no common policy at fe deral level related to 
noise of recreational crafts in the US. California as the state with the highest concentration of recreational crafts specif ies a single limit of 75 dB for all engine power categories whereas the 
EU requires tougher limits for smaller power range s. Thus, a more severe  limit value of EU 
noise limits would disalign the rules with the US.  
Despite positive reactions from some Member St ates on legislative restriction of noise limits, 
the option is strongly opposed by the industry. The letter points out th e findings of TNO 
Study 2004 and underlines in par ticular the limited environmen tal benefit entailed by the 
                                                
 
42 Stocktaking Study, TNO (2004), p. 67 
 
EN 42   EN introduction of stricter noise emission limits , the importance of the changes necessary to 
achieve a small emission reduction and th e costs entailed by such changes. 
This leads to the conclusion that current no ise limits are necessary to guarantee the 
functioning of the intern al market. Further decreasing noise of recreational craft can be most 
effectively achieved by national measures on the boat use. 
6.3 Impact of the measures aligning the Recreational Craft Directive with the New 
Legislative Framework (NLF)  
Most of the provisions from the NLF codi fy the current practice and do not introduce 
important new changes in the sector. The impacts of the integration of the model Articles into the RCD sector are therefore minor. 
The significant impacts should be mostly posi tive, since the horizontal provisions clarify 
certain issues
43 which are uncertain for the moment. Lega l certainty will be beneficial for all 
parties: economic operators, national and European Union administration as well as 
consumers. Certain new obligations set for eco nomic operators, can have an economic impact 
in terms of new costs for the economic operators.44 In particular, importers have new 
obligations to ensure the complia nce of the product. However, th ese impacts should be largely 
overweighed by the benefits stemming from th ese provisions for consumers in terms of 
increased safety of recreational craft and for na tional administrations in terms of reduced costs 
following clearer new rules on respon sibilities of economic operators. 
Administrative Burden 
According to the current Directive, the Member  States are obliged to  inform Commission 
when the Safeguard Clause is applied and when  the Notified Body is ap pointed or withdrawn 
from the list of the bodies notif ied to make a conformity asse ssment for recreational craft. 
These administrative measures are considered to be necessary and effective and are proposed 
to be kept in the Directive.   
As explained in Problem Definition on the page  13, the administrative burdens arise to the 
engine manufacturers from different certificat ion requirements in the EU and the US. The 
preferred option is based on aligning the rule s on both sides of Atlantic, therefore the 
requirement to certify twice for two different markets might be reduced.  
7.  MONITORING AND EVALUATION 
The Commission has several tools at  its disposal to make sure that the objectives set in this 
new piece of legislation will effectively be achieved. 
The main tool is market surveillance by the competent authorities of Member States. Non-
compliance will also be spotted as a result of complaints addressed to the Commission.  
                                                 
43 For instance horizontal definitions, requirements for Notified bodies and notified authorities and for  
     notification, content of conformity assessment modules, content of the EC declaration of conformity. 
44 The impact of the alignment with the NLF is cl osely evaluated in the Omnibus Impact Assessment 
(COM 
     proposal aligning several directives  to the NLF at the same time).      
 
EN 43   EN The Commission will be able to detect any prob lems regarding to the correct application  of 
the RCD through the following initiatives: 
- Regular reports that Member States have to send every five years to the Commission.  These 
reports will contai n at least the following elements  
• an evaluation of the situation co ncerning the safety of products  
• an evaluation of the effectiveness of the RCD  
• effectiveness of tracking non-compliant products 
• effectiveness of stricter exhaus t emission limits through air pollution 
measurement in marine/lake/inland waterway areas. 
The Commission will provide a guidance documen t to the Member States on key monitoring 
indicators. The Commission services will ev aluate national report s and publish a summary 
report 
There is also a reporting obligation on market su rveillance activities, which includes the area 
of recreational craft, provided  by the NLF Regulation 765/2008 
– ADCO group meetings are organized twice a year. Questions and remarks raised at 
these meetings should give a good insight  on the actual functi oning of the RCD.  
– The new information exchange systems provided by Art. 23 of Regulation 
765/08/EC framework will allow the Commissi on to monitor the effectiveness of the 
RCD.  
– The group of notified bodies (RSG), orga nizes one plenary session and two sub-
groups per year. It coordina tes the common application of  the conformity assessment 
rules and issues Recommendations for us e (RFU), the number of which provides a 
good indicator on the possible need for clar ification and application of the RCD. 
– Requests & remarks received by the Comm ission from the public will help to 
monitor the eventual infringement s of the internal market.  
– All important information about the functioning of the RCD is published on a 
dedicated CIRCA website which can be c onsulted by Member States, professional 
associations and NGOs.  
 
EN 44   EN Glossary 
 
  
2s     2-stroke 
4s    4-stroke ABT    Averaging, Banking and Trading Sy stem (flexibility system in the US) 
CARB    California Air Resources Board CI    Compression ignition (diesel) engine CO    Carbon Monoxide (emission component) DI    Direct Injection DIY    Do it yourself EEA   European Environment Agency EFI    Electronic fuel injection EPA    United States Environmental Protection Agency EUROMOT   European Association of In ternal Combustion E ngine Manufacturers 
EQS    Environmental Quality Standard GHG    Green House Gas Emissions 
HC    Hydrocarbons (emission component) 
IB    Inboard Engine IMEC   International Council of Marine Industry Associations' Marine Engine 
Committee 
Mariniser  a company which purchases engines from the engine manufacturer 
producing engines for different applica tions (automotive, non-road use) 
and convert or adapt them for marine use 
NLF    New Legislative Framework NOx    Oxides of Nitrogen (emission component) NO   Nitric Oxide NO
2   Nitrogen Dioxide 
NRMM   Non-Road Mobile Machinery OB    Outboard Engine OEM    Original equipment manufacturer PM    Particulate Matter  (solid emission pollutant) 
PWC    Personal Watercraft RCD    Recreational Craft Directive, 94/25/EC R&D    Research and Development SI    Spark ignition (petrol) engine SME    Small and medium enterprise SOER 2010  The European envi ronment – state and outlook 2010 
SOx    Oxides of Sulphur (emission component) TA    Type Approval TFEU    Treaty of Functioning of the European Union UN-ECE   Economic Commission for Europe of the United Nations 
 
 
 
EN 45   EN ANNEX I:  Overview of recreational craft and engi nes for recreational craft sector  
 
Economic importance of the recreationa l craft sector per country (2004) 
Country  GDP €  Employment 
  TOTAL  Recreational craft 
sector contribution Total labour 
force Recreational craft 
sector employees
Austria 214.000.000 55.000 0,03% 4.300.000 960 0,02%
Belgium 279.000.000 55.000 0,02% 4.440.000 940 0,02%
Bulgaria 12.100.000 14.000 0,12% 3.830.000 440 0,01%
Croatia 16.900.000 153.000 0,91% 1.700.000 3.470 0,20%
Cyprus  6.740.000 19.000 0,28% 377.000 515 0,14%
Czech Republic 75.200.000 5.000 0,01% 5.200.000 150 0,00%
Denmark  182.000.000 324.00 0 0,18% 2.860.000 5.290 0,18%
Estonia  5.220.000 13.000 0,25% 609.000 470 0,08%
Finland 139.000.000 386.000 0,28% 2.600.000 6.750 0,26%
France 1.410.000.000 2.220. 000 0,16% 26.600.000 41.200 0,15%
Germany 2.150.000.000 1.980. 000 0,09% 41.900.000 26.900 0,06%
Greece  150.000.000 225.00 0 0,15% 4.370.000 4.270 0,10%
Hungary 68.300.000 8.000 0,01% 4.200.000 280 0,01%
Ireland  121.000.000 123.000 0,10% 1.800.000 2.850 0,16%
Italy  1.230.000.000 2.920. 000 0,24% 23.600.000 92.000 0,39%
Latvia 7.400.000 2.000 0,03% 1.100.000 95 0,01%
Lithuania  10.300.000 4. 000 0,04% 1.500.000 130 0,01%
Malta 4.150.000 7.000 0,17% 160.000 210 0,13%
Netherlands 414.000.000 1.070. 000 0,26% 7.200.000 20.700 0,29%
Norway 169.000.000 525.000 0,31% 2.400.000 6.600 0,28%
Poland  162.000.000 106.000 0,07% 17.600.000 2.910 0,02%
Portugal  124.000.000 128.00 0 0,10% 5.100.000 2.480 0,05%
Romania  44.900.000 10.000 0,02% 9.900.000 330 0,00%
 
EN 46   EN Slovakia  28.500.000 1. 000 0,00% 3.000.000 65 0,00%
Slovenia  18.300.000 32.000 0,17% 857.000 716 0,08%
Spain  665.000.000 487.000 0,07% 17.100.000 9.020 0,05%
Sweden  246.000.000 742.000 0,30% 4.400.000 6.930 0,16%
Switzerland  284.000.000 233. 000 0,08% 4.000.000 2.780 0,07%
Turkey 219.000.000 152.000 0,07% 23.800.000 5.370 0,02%
UK 1.440.000.000 1.490.00 0 0,10% 29.700.000 26.400 0,09%
       
  9.896.010.000 13.489.000 0 ,14% 256.203.000 271.221 0,11%
 
SOURCE: Economic and Social Impact  Analysis, Appendix A, ECNI (2006) 
 
Number of companies in the European  recreational craft industry chain (2007) 
Country Boat builders Engine manufacturers / 
marinisers 
Denmark 30 1 
Finland 58 0 
France 156 7 
Germany 412 11 
Greece 87 0 
Ireland 4 0 
Italy 800 10 
Netherlands 450 1 
Portugal 55 0 
Spain 25 3 
Sweden 50 3 
UK 500 5 
 2 627 41 
 
EN 47   EN Croatia 65 1 
Norway 95 2 
Switzerland 18 7 
Turkey 300 0 
 478 10 
SOURCE: The Complementary Impact Assessment Study: ARCADIS (2008) 
 
Due to the financial and economic crisis which hit the sector from 2008 onwards this number 
has been reduced mainly as a result of merger  & acquisition. The manu facture of recreational 
craft engines is a small industry compared e .g. to car or truck sector, although it plays a 
significant role in specific regions. The largest marine engine manufact urers are located in 
Sweden, followed by Germany, Italy and the UK. The European engine manufacturers 
provide some 2300 jobs. 
The total number the outboard engines sold in the EU by far outnumbers the sales of inboard 
engines. The vast majority of outboard  engines are SI (petrol) engines. 
The use of recreational marine engines in the EU 
 
        
Source: Stocktaking Study: TNO (2004)  
  2%86%
inboard
2,5%9%Recreational marine engines  in the EU
outboardsterndrive 
petrolshaftdrive diesel
sterndrive diesel
 
EN 48   EN There are nine manufacturers of outboard engines  world-wide in 2008, with annual 
production volumes of 800 000 pc. (cca 210 000 in the EU / cca 302 000 in the US).45 The 
inboard engines  are essentially marinised diesel en gines obtained from the industry. For 
these engines, the European sales very much  depend on whether they are inboard petrol 
engines or inboard diesel engines. The inboard di esel engines' market is primarily a European 
one (40 000 units sold per year in the EU out  of 65 000 units / year worldwide); whereas 
inboard petrol engines sales in Europe onl y represent only 7, 5% of worldwide sales 
(approximately 10 000 units per year in Eur ope and 130 000 units / year worldwide).  
Personal watercrafts (including its inbuilt PWC engines ) sold on the European market are 
produced by 4 manufacturers, two Japanese an d two North-American companies. The total 
estimated annual sales of personal watercraft  in Europe is about 10 000 units, which 
represents less then 10% of the global market.  
                                                 
45 Source: The Complementary Impact Assessment Study: ARCADIS (2008) 
 
EN 49   EN ANNEX II:  Public consultation on a possible approach to revision of the RCD, 
summary of responses  
 
1. Introduction 
The European Commission launched an open pub lic consultation to gather views on its 
outline proposals for revising the legislation on recreational craft. Various policy options for 
drafting a proposal amending the Recreational Craf t Directive have been identified in close 
consultation with stakeholders. They address the needs for: 
1. further improving the environmental performa nce of recreational marine engines by 
proposing the next stage of exhaust emission limits; 
2. aligning the provisions of the Directive with the principles of the new legal 
framework; 
3. improving the existing provisions of the Dir ective which are not covered by previous 
two points. 
The main objective of this publ ic consultation was to ask citi zens and stakeholders for their 
views and opinions on the various issues that mi ght need to be addressed in any proposal for 
further amending the Directive. The replies to this consultation have provided the 
Commission with a broader range of views on the policy needs iden tified and should enable it 
to improve or confirm the approaches envisaged. 
2. Overview of respondents 
The consultation was launched on 11 May 2009, with 19 July as the deadline for replies. The 
Commission received 32 responses: 16 of them we re sent on behalf of an organisation or 
institution, 9 by enterprises and 7 by individual citizens. 
Most of the contributi ons sent by organisations were fr om public authorities. However, 
industrial organisations, notified bodies and non- governmental organisations also made their 
voices heard. Boat manufacturers and SMEs in pa rticular were the main contributors on the 
side of enterprises. Invaluable contributions were also received from individual citizens.  
Contributions were received from 12 different  States (11 EU States and 1 EEA State). The 
bulk of the responses were from Poland and Germany. 
3. Further improving the environmental perfor mance of recreational marine engines: 
need for further reducing emissions of air pollutants 
About 65 % of respondents agreed with the appro ach of further reducing the exhaust emission 
limits for recreational marine engines, provided sufficient attention is paid to mitigating 
measures for small and medium-sized enterpri ses, on which any further restrictions would 
have the greatest impact. A slight majority of  respondents were in favour of a derogation as 
the most acceptable option to cushion the impact  on SMEs. However, th ere is also strong 
support for exempting SMEs from complying with any new limits, especially amongst 
enterprises and citizens. By c ontrast, 19 % of the respondents,  in particular institutions, 
disagreed with mitigating measures for SMEs. 
 
EN 50   EN The idea of mitigating measures for SMEs has overwhelming support. The softer solution – a 
derogation – seems to be a compromise between the concerns of the industry (which is in 
favour of exemptions) and the public authorities (which doubt the need for any alleviation).  
4. Further improving the environmental perfor mance of recreational marine engines: 
need for further reducing noise 
The idea of regulating noise from recreationa l craft by means of operational measures 
regulating use of noise-emitting craft rather than further lowering the noise emission limits in 
the Directive has strong support am ong all parties: institutions, enterprises and boat users. The 
respondents expressed the opinion  that the local authorities might be more effective at 
reducing noise by means of sp ecially tailored limits.  
5. Subject-matter and scope  
Public authorities in particular indicated that the classification of the products covered by the 
Directive should be clearer. The status of par tly completed boats appears especially unclear. 
The reason probably lies in the vague wording of  the declaration by the builder that the boat 
will be completed by others. For citizens and enterprises, clarification of the classification is 
not such an issue. 
More than half of the respondents have no problem understanding the scope of exemptions 
from the Directive. However, some institutions stated that craft built for own use and racing 
(rowing) craft in particular should not be exem pted from the Directive as this would create 
confusion and leave room for possibly side-s tepping the system. Objections were raised 
against exempting craft intended to carry pass engers for commercial purposes, but such craft 
are regulated by other EC legislation.  
The discussion about the status of amphibiou s vehicles and pontoons indicated that they 
should also be exempted from the Directive.  
6. Alignment with the new legal framework 
The questionnaire proved that stakeholders especially stro ngly support clearly defining the 
obligations of economic operators. There we re also calls for defining and imposing 
obligations for persons importing craft from countries outside Europe for non-commercial 
purposes. Institutions are more in favour of de fining the obligations of each link in the 
economic chain, whereas manufacturers and citizen s would prefer to clarify the rules for the 
conformity assessment procedures and for affixing the CE marking. 
7. CE marking of propulsion engines 
The stakeholders indicated that  all engines covered by the Directive (including inboard 
engines and stern-drive engines without integral exhaust) should be explicitly required to have 
the CE marking affixed to confirm that they comply with the noise and exhaust emission 
limits. 
8. Choice of conformity assessment modules 
The recreational craft sector has already b een using the various conformity assessment 
modules before they are introduced in the ne w legal framework. The ch oice of those modules 
seems to be adequate and sufficient in the vi ew of the vast majority of the respondents. 
 
EN 51   EN 9. Post-construction assessment procedure 
Post-construction assessment (PCA) is a spec ial conformity assessment procedure used 
preferably by importers when neither the ma nufacturer nor the manuf acturer’s au thorised 
representative takes responsibil ity for the conformity of the product with the Directive. The 
current Directive explicitly allows use of this procedure for recreational craft only, but not for personal watercraft or engines. Opinions on wi dening the scope of the PCA to other products 
differ between stakeholders. There are eq ual numbers of supporters and opponents. 
Institutions support the idea that post-constr uction assessment should apply to all products 
covered by the Directive. By contrast, some ma nufacturers are convinced that the PCA is not 
desirable for other products and,  in particular, would not even  be technically feasible for 
personal watercraft. However, there is broad agreement that the PCA procedure should be 
defined in a separate annex.  
10. Enforcement and market surveillance 
Both governments and businesses consider that ma rket surveillance activities in the field of 
recreational craft are not sufficient and that the new legal framework should help in this area. 
However, there are also manufacturers who think that the market surveillance authorities have 
strong powers. Nevertheless, those who wish to reinforce the powers and activities of 
enforcement authorities consider that preven tive measures and enhanced cooperation between 
market surveillance authorities and customs authorities are the most powerful tools. 
Institutions are in favour of ti ghter controls at borders and even obligatory registration of 
boats, whereas manufacturers and citizens pref er improvement by means of cooperation and 
exchanges of information between enforcement authorities.  
11. Feedback from stakeholders 
Other interesting opinions expressed as feedback from stakeholders included: 
o Revision of the wave height of design categor ies is needed, as it appears inadequate for 
some categories. 
o Partly completed boats should be accomp anied by the technical documentation when 
placed on the market. 
o Alignment of the exhaust emission limits with the US limits is more desirable for SI 
engines. For CI engines, alignment with the limits for non-road mobile machinery is 
preferable. 
 
EN 52   EN  
ANNEX III:  Schematic representation of different drive principles for boat engines  
Types of engines involved in the moto rboats and personal watercraft are: 
 Spark-ignition [SI] engines (ca lled also petrol engines)  
 
Outboard engines 
¾ Inboard (stern-drive) engines 
¾ Inboard (shaft-drive) engines 
¾ PWC engines - used in the personal watercrafts 
 
 Compression-ignition [CI] engines (called also diesel engines) 
 
Inboard (stern-drive) engines 
¾ Inboard (shaft-drive) engines 
 
 
 
 
EN 53   EN ANNEX IV:  Annual average air concentrations in Europe - affected locations   
 
Annual average PM air concentrations  
 
 
 
EN 54   EN ANNEX V:  Overview of the exhaust emissions limits in the EU and the US 
Recreational Craft Directive 94/25/EC:  
Exhaust emission limits                                                                   (g/kWh)  
Carbon monoxide 
CO = A + B/P Nn  Hydrocarbons 
HC = A + B/ P Nn Type 
A B n A B n Nitrogen 
oxides 
NO x  Particulates 
PT  
Two-stroke 
spark ignition 150,0 600,0 1,0 30,0 100,0 0,75 10,0 Not 
applicable 
Four-stroke spark ignition 150,0 600,0 1,0 6,0 50,0 0,75 15,0 Not 
applicable 
Compression ignition 5,0 0 0 1,5 2,0 0,5 9,8 1,0 
Where A, B and n are constants in accordance with the table, P N is the rated engine power in kW.  
 
 
US EPA standards for marine CI engines (CFR 40 Part 1042)  
Maximum 
Engine Power L/cylinder PM 
g/bhp-hr 
(g/kW-hr) NOx + HC 
g/bhp-hr 
(g/kW-hr) Applicable for 
model year 
<19 kW <0,9 0,30   (0,40) 5,6 (7,5) 2009 
0,22   (0,30) 5,6 (7,5) 2009 19 to <75 kW <0,9a 
0,22   (0,30) b 3,5 (4,7) b 2014 
<0,9 0,11   (0,15) 4,3 (5,8) 2012 
0,9-<1,2 0,10   (0,14) 4,3 (5,8) 2013 
1,2-<2,5 0,09   (0,12) 4,3 (5,8) 2014 
2,5-<3,5 0,09   (0,12) 4,3 (5,8) 2013 75 to <3700 kW 
3,5-<7,0 0,08   (0,11) 4,3 (5,8) 2012 
(a) <75kW engines at or above 0,9 L/cylinder are subject to the corresponding 75-3700 kW standards. 
(b) Option: 0,15 g/bhp-hr (0,20 g/kW-hr) PM / 4,3g/bhp-hr (5,8g/kW-hr) NOX-HC in 2014 
 
EN 55   EN US EPA standards for marine SI engines (CFR 40 Part 1045)  
 
Type of engine Rated Engine 
Power 
PN 
 (kW) Carbon 
monoxide 
CO 
 
 (g/kWh) Hydrocarbons + 
Nitrogen Oxides 
HC + NOX 
 (g/kWh) Applicable 
for model 
year 
PN ≤ 373 75 5 
373 < P N ≤ 485 350 16 Stern-drive and 
inboard engines 
PN > 485 350 22 
PN ≤ 4,3 500 – 5,0 x P N 30 
40 > P N > 4,3 500 – 5,0 x P N 
⎟⎟
⎠⎞
⎜⎜
⎝⎛
+9.0507,15
PN Outboard 
engines and 
PWC engines 
PN >.40  300 
⎟⎟
⎠⎞
⎜⎜
⎝⎛
+9.0507,15
PN  
   
2010 
The US EPA rules include a couple of mitigati ng measures which may be used by the engine 
manufacturers marketing their products in the US (such as additional lead time, flexibility 
scheme, averaging, banking and trading provi sions and hardship relief provisions). 
 
Comparison of the exhaust emissions limit s in the EU and the US for CI engines  
Power (PN) Particulates (PM)  Hydrocarbons + Nitrogen 
Oxides (HC + NOX) 
  EU US EU US 
(kW) (g/kWh) 
PN < 37 1 1 11,4 11,4 
37 ≤ PN <75 1 0,3 11,3 4,7 
75 ≤ PN < 3700 1 0,15 11,3 5,8 
 
EN 56   EN 0,14 5,8 
0,12 5,8 
0,12 5,8 PN < 3700 
1 
0,11 11,3 
5,8 
 
Limits for non road mobile ma chinery CI engines - Stage IIIA  
Swept Volume SV PN PM HC+NOx 
 (L/cyl) (kW) (g/kWh) (g/kWh) 
SV < 0,9  0,4 7,5 
0,9 ≤ SV < 1,2  P ≥ 37 
0,3 7,2 
1,2 ≤ SV < 2,5  0,2 7,2 
2,5 ≤ SV < 5  0,2 7,2 
 5 ≤ SV < 15  0,27 7,8 
15 ≤ SV < 20  0,5 9,8 
20 ≤ SV < 25  0,5 9,8 
25 ≤ SV < 30   37 ≤ P < 75  
0,5 11 
 
         
 
EN 57   EN Development of the exhaust emission limits a pplying to engines of power ratings (5kW 
and 40kW) in the EU and the US  
020406080100120140160180200
EPA 2001 EPA 2006
/ CARB
Tier1RCD SI 2s CARB
Tier2RCD SI 4s EPA 2008
/ CARB
Tier3 EPA 2008
/ CARB
Tier4 
RegulationHC + NOx (g/kWh)5 kW
40 kW
 
 
The following conclusions were drawn from this figure in the report: 
(1) Current EU Stage I. (amendment of the RCD 2003/44/EC) requirements for 2-stroke 
engines are similar to the obsol ete US EPA 2006 requirements  
(2) Current EU Stage I 4-stroke requirements are between the CARB Tier 2 and Tier 3 
requirements  
(3) The US EPA 2008 requirements ( 40 CFR, part 1045)  for SI outboard and PWC 
engines are consistent with the requirements adopted by CARB Tier 3 
(4) The US EPA 2008 requirements ( 40 CFR, part 1045)  for SI inboard engines are 
consistent with the requirements adopted by CARB Tier 4 
(5) Proposed EU Stage II would align with the harmonised US EPA 2008 limits and 
Californian CARB limits.  
 
EN 58   EN ANNEX VI:  Analysis of 5 different scenarios 
Scenarios assessed in ARCADIS Complementar y IA Study (2008) as well as the TNO (2004) 
scenarios assessed in the ECNI IA Study (2006) are presented in terms of their effectiveness, 
efficiency and consistency. All scenarios are compared by means of a multi-criteria analysis. By altering the weights attributed to the di fferent scenarios, insight is provided in the 
sensitivity of the ranking of the scenarios. Fina lly, the environmental benefits are compared to 
the corresponding compliance costs. In this wa y, the scenarios can be ranked on the basis of 
their likely contribution to overall welfare. 
Assumptions made in the ECNI IA Study ( 2006) are sought to those of the ARCADIS 
Complementary IA Study (2008) and vice ve rsa, depending on which ones are the most 
realistic. As in the ECNI IA Study (2006), the risk associated with this impact assessment 
relates to the assumptions made when calcula ting the impacts. The crucial factors are the 
expected compliance costs, emission reductions and socio-economic impacts associated with 
each regulatory scenario. These risks have been addressed by a thorough and transparent 
stakeholder consultation. 
The impacts have been grouped in terms of their: 
(6) Effectiveness – how well does each of the scenarios achieve the objectives (reducing 
exhaust emissions)? 
(7) Efficiency – the level of resources needed to achieve the stated objectives (impacting 
technical, economic and social 
(8) Consistency – the balance, trade-offs and synergies of positive and negative 
(un)intended (in)direct e ffects on economic, social and environmental systems   
In the following table the environmental and so cio-economic impact of the various scenarios 
are presented through a number of  synthetic indicators. The s econd and third columns present 
the absolute annual reduction of HC+NOx and PM emissions. Scenarios 3 and 1 are the most 
and the least effective from an environmental poi nt of view. However, (social) cost-efficiency 
should also be considered, as the means by whic h the environmental obje ctives are realised 
should be proportionate to th e benefits. Therefore, the reduction in HC+NOx and PM 
emissions is compared to the expected compliance costs and job losses faced by industry. The reduction in HC+NOx and PM em issions was added up, accounting for the higher social costs 
of PM emissions compared to HC+NOx emissions. Factor 9 was used to convert PM emissions into NOx equivalents. This factor has been derived from the stu dy "Estimates of the 
marginal external costs of air pollution in Eur ope" by Netcen which has been referred to in the 
NRMM Directive. Moreover, the following factors are used as proxies of the marginal external costs of NOx and PM: 
• NOx – 4 200 €/tonne 
• PM – 36 420 €/tonne 
As it is not known how the reduction in HC+N Ox emissions is split up between NOx and HC, 
we only rely on the NOx marginal external cost s as a proxy for the social benefits of the 
reduction in HC + NOx emissions.  
 
EN 59   EN The following Table demonstrates that scenarios 3, 2 and 5 are the most effective. Scenario 5 
outperforms the other scenarios in terms of  PM reduction whereas 2 and 3 are performing 
better for HC + NOx. Scen ario 5 realise emission reductions in a more cost-efficient way. The 
potential compliance costs and job losses per ki loton reduction in emissions are much lower 
than for other four scenarios developed by TNO Study (2004). Scenario 5 performs best on 
both effectiveness and cost-effect iveness criteria. Industry pointed  out that the higher socio-
economic impacts per kiloton reduction for th e TNO Study (2004) scenarios relates to the 
technical difficulties of adopting the required technology in the short term. 
Absolute annual reduction (in 
kilotons) Compliance costs 
per kiloton 
reduction (in € 
million) Job losses per 
kiloton reduction 
(in number of 
jobs) 
Scenario 
NOx+HC PM NOx+HC & 
PM 
(expressed 
in NOx 
equivalents) min max min max 
1 8,14 0,09 8,99 6,75 6,75 23,75 23,75 
2 12,65 0,11 13,63 14,68 14,68 32,38 32,38 
3 13,39 0,11 14,37 12,44 12,44 29,59 29,59 
4 9,39 0,11 10,37 12,97 12,97 24,46 24,46 
5 10,85 0,24 13,03 0,83 2,27 1,93 5,87 
Source: ARCADIS Complementary Impact Assessment Study (2008) 
 
 
 
EN 60   EN ANNEX VII:  Methodology used for environmental impact analysis 
Initially, fleet composition across Europe wa s investigated, includ ing types of vessels, 
numbers and the engine mix within of groups of vessels in various environments. This 
included linear waterways, coastal areas and lakes. Data on the numbers of vessels were 
limited and therefore estimates have been made  based on limited registration data, aerial 
photography and European stocktaking data from industry sources. Based on this data, a 
hypothetical fleet was defined for each of the three environments. This included a predicted 
number of vessels, operated in a hypothetical environment aligned as closely to real situations 
as possible. Sensitivity swings were calculated to  understand the variation in the data and to 
account for the variability in real life situati ons. To quantify impacts, sensitive receptors such 
as areas of conservation and re sidential areas were modelled in the scenario building. The 
engine sizes, types, usage and di stribution within the fleet were used to calculate the total 
emissions per annum arising from the use of th e craft. These emission s were adjusted by a 
load factor to account for the fact that the engine s are not operated at  full power throughout 
their life. The overall emissions were then modelled using Atmospheric Dispersion Model 
AERMOD to give long term and short term results  for a range of air quality parameters. This 
allowed for the changes in the Directive to be directly related to environmental impacts and compared to each other and the environmental quality standards (EQS). 
Calculation and modelling of Fleets, Engine  populations and Emissions are provided in 
Appendix B and C of Envir onmental Part ECNI Study 2006 
The impacts relating to water quality were also considered in relation to quality standards and 
emissions. Although changes to th e Recreational Craft Directive primarily limit emissions to 
air, there may be some benefit in reductions through pathways such as  deposition and aqueous 
sources.  
 
 
EN 61   EN ANNEX VIII:  The calculation of the exhaust emission reductions 
The environmental impact is demonstrated by the aggregated exhaust emissions in four-year 
period. The overall exhaust emissions measured  per one year are delivered by ARCADIS 
Impact Assessment Study (2008) for Options  1 and 2 and Sub-option 3.1. The exhaust 
emissions for Sub-options 3.2 and 3.3 had to be extrapolated from th e available numbers. 
Calculation in four-year period demonstrates the best how the exha ust emissions for Sub-
options 3.2 and 3.3 were calculated.  
When the summarized emissions are divided by 4, we get the average annual emissions also 
for Sub-options 3.2 and 3.3. Then the percenta ge reduction calculated for 4 years is 
conforming to the percentage re duction calculated per one year. 
 
HC+NOx (Hydrocarbons+Nitrogen Oxides) Year 1 Year 2 Year 3 Year 4 Tons / 4 
years 
Option 1 - Stage I 40 907 40 907 40 907 40 907 163 628
Option 2 - Stage II 30 061 30 061 30 061 30 061 120 244
Sub-option 3.1 - Stage II + Flexibility scheme 31 105 31 105 31 105 31 105 124 420
Sub-option 3.2 - Stage II + Transitional period 40 907 30 061 30 061 30 061 131 090
Sub-option 3.3 - Stage II+Tran period+Spec time 
SI SMEs 40 907 30 067 30 067 30 067 131 108
            
          Reduction 
compare 
to Opt. 1 
Option 2 - Stage II         -26,51%
Sub-option 3.1 - Stage II + Flexibility scheme         -23,96%
Sub-option 3.2 - Stage II + Transitional period         -19,88%
Sub-option 3.3 - Stage II+Tran period+Spec time SI SMEs       -19,87%
            
            
PT (Particulates) Year 1 Year 2 Year 3 Year 4 Tons / 4 
years 
Option 1 - Stage I 539 539 539 539 2 156
 
EN 62   EN Option 2 - Stage II 296 296 296 296 1 184
Sub-option 3.1 - Stage II + Flexibility scheme 387 387 387 387 1 548
Sub-option 3.2 - Stage II + Transitional period 539 296 296 296 1 427
Sub-option 3.3 - Stage II+Tran period+Spec time 
SI SMEs 539 296 296 296 1 427
            
          Reduction 
compare 
to Opt. 1 
Option 2 - Stage II         -45,08%
Sub-option 3.1 - Stage II + Flexibility scheme         -28,20%
Sub-option 3.2 - Stage II + Transitional period         -33,81%
Sub-option 3.3 - Stage II+Tran period+Spec time SI SMEs       -33,81%
            
            
CO (Carbon monoxide) Year 1 Year 2 Year 3 Year 4 Tons / 4 
years 
Option 1 - Stage I 153142 153142 153142 153142 612 568
Option 2 - Stage II 184634 184634 184634 184634 738 536
Sub-option 3.1 - Stage II + Flexibility scheme 180698 180698 180698 180698 722 792
Sub-option 3.2 - Stage II + Transitional period 153142 184634 184634 184634 707 044
Sub-option 3.3 - Stage II+Tran period+Spec time 
SI SMEs 153142 184502 184502 184502 706 648
            
          Relaxation 
compare 
to Opt. 1 
Option 2 - Stage II         20,56%
Sub-option 3.1 - Stage II + Flexibility scheme         17,99%
Sub-option 3.2 - Stage II + Transitional period         15,42%
Sub-option 3.3 - Stage II+Tran period+Spec time SI SMEs       15,36%
 
EN 63   EN ANNEX IX :  Monetization of environmental benefits  
Environmental benefits are measured as the average damages per tonne of emission of NOx 
and PM2.5 for the EU25 (excluding Cyprus) and su rrounding sea areas under different sets of 
assumptions.  
Analysis follows the impact pathway methodol ogy developed in the ExternE Project funded 
by EC DG Research. The pathway describe d by the analysis is as follows: 
Emission of pollutants → Dispersion of pollutants → Exposure of people, ecosystems, 
materials, etc. → Quantification of impacts → Valuation of impacts 
Methodology is closer described in Cost-Benefit Analysis of Air Quality Related Issues, in 
particular in the CAFE Programme at  http://www.cafe-cba.org/assets/marginal_damage_03-05.pdf . 
The Study refers to four methods differing in  measurement of value of mortality. These 
methods are VOLY median, VSL median, VOLY mean and VSL mean. The environmental 
benefits are calculated for all these methods in two various environments: inland and seas. 
The tables 10, 14, 17 and 20 of the Impact A ssessment indicate the range of environmental 
benefits taking together results for all four methods. Environmenta l benefits are calculated for 
NOx and PM.  
Environmental benefit of each o ption = Amount of tonnes/year of 
particular pollutant * Damage/t onne of particular pollutant 
Total emissions measured in tonnes pe r year produced by recreational crafts  
  NOx (tons/year) PM (tons/year)  
Option 1 - No change 14 317 539 
Option 2  10 521 296 
Sub-option 3.1  10 887 387 
Sub-option 3.2  11 470 357 
Sub-option 3.3 11 472 357 
Source: ARCADIS Study, p. 54, the emissions of NOx measured as 35% of HC+NOx emissions 
 
 
 
  
 
EN 64   EN Average damage savings / tonne of emissions per various air pollutants 
 
Measures Method Damage / tonne (€) 
NOx Damage / tonne (€) 
PM 
    Inland   
PM mortality, O 3 
mortality, Health core, 
Health sensitivity, Crops, O
3/health metric VOLY median, VOLY 
median, Included, Not 
included, Included, SOMO 35 4 400 26 000 
PM mortality, O 3 
mortality, Health core, 
Health sensitivity, 
Crops, O 3/health metric VSL median, VOLY 
median, Included, Not 
included, Included, SOMO 
35 6 600 40 000 
PM mortality, O 3 
mortality, Health core, 
Health sensitivity, 
Crops, O 3/health metric VOLY mean, VOLY mean, 
Included, Included, 
Included, SOMO 0 8 200 51 000 
PM mortality, O 3 
mortality, Health core, 
Health sensitivity, 
Crops, O 3/health metric VSL mean, VOLY mean, 
Included, Included, 
Included, SOMO 0 12 000 75 000 
    Seas    
PM mortality, O 3 
mortality, Health core, 
Health sensitivity, 
Crops, O 3/health metric VOLY median, VOLY 
median, Included, Not 
included, Included, SOMO 
35 2 500 13 000 
PM mortality, O 3 
mortality, Health core, Health sensitivity, 
Crops, O
3/health metric VSL median, VOLY 
median, Included, Not included, Included, SOMO 
35 3 800 19 000 
PM mortality, O 3 
mortality, Health core, Health sensitivity, 
Crops, O
3/health metric VOLY mean, VOLY mean, 
Included, Included, Included, SOMO 0 4 700 25 000 
PM mortality, O 3 
mortality, Health core, Health sensitivity, 
Crops, O
3/health metric VSL mean, VOLY mean, 
Included, Included, Included, SOMO 0 6 900 36 000 
Source: Cost-Benefit Analysis of Air Quality Relate d Issues, in particular in the CAFE Programme 
VOLY - Valuation of mortality using value of a life approach 
VSL - Valuation of mortality using the value of statistical life  
SOMO 35 - Sum of Means Over 0 ppb.days 
SOMO 0 - Sum of Means Over 35 ppb.days 
 
 
EN 65   EN ANNEX X:  Methodology and assumptions used for economic impact analysis, 
calculation of compliance costs  
Based on the technologies that would be require d to achieve the emission limit values, the 
costs of bringing engines in compliance with th e proposed environmental standards have been 
calculated for the selected basic scenario withou t flexibilities. Technical impacts linked to the 
application of the scenario are reflected in asso ciated compliance costs. The level of costs to 
become compliant with the emission limit values set in the scenario depends on a set of factors: 
• The level of technology curre ntly used by the manufacturer  and level of technology 
used by the manufacturer to be compliant with other regulations in markets outside 
the EU 
• The sources of the engine and if a pplicable its original application; 
• Engine families and needs for simultaneous up-grading for the full engine range to 
continue component sharing; 
• The emission reduction technologies alread y available for the engine in other 
applications; 
• The production volumes between ma nufacturers and their suppliers; 
• The development and certification costs; 
• Tooling costs;  
• Component cost per engine 
Compliance costs are purely related to costs to be made by engine manufacturers and 
marinisers and do not include downstream eco nomic impacts related to competitiveness, 
changes in the market structur e, changes in fuel economy, etc.  Compliance costs are evaluated 
in the scope of the time horizon w ithin which these costs are made. Fixed costs  occur the first 
years after which they are fully amortized. After a particular pe riod of time, some fixed costs 
will appear again (e.g. re newable of certificate). Variable costs  remain a cost item in the long 
run but will probably decrease as manufacturers learn over tim e to produce the engines with 
the new technologies or after treatment at a lower cost.  
CI engines:
 
Fixed costs 
These are the costs linked to the developmen t, production, validation and certification of 
Stage II engines. This includes re-certification; re-design of components, adaptations to assembly line, environmental validation tests, etc.  
The unit fixed costs per engine are ranged be tween 30€ - 50€ for large manufacturers whereas 
those costs vary from 31€ - 664€ for small manufacturers.  The lower bound reflects a 
situation in which these companies only have to cope with (re)certification costs and related 
 
EN 66   EN testing, the upper bound a situation in which othe r fixed costs related to R&D, additional 
testing and retooling of assembly lines should be taken into account. 
The higher costs are for the companies which onl y serve the EU market and have no indirect 
exports to the US via boats in which thei r marinised engines are mounted.  For large 
manufacturers, the fixed costs can be assumed as rather limited, basically reflecting costs for 
recertification. R&D costs are negligible for th e majority of engine manufacturers, as these 
costs have already been born e by road engine manufacturers .  
Variable costs  
Variable costs  cover improved or added te chnology on every engine (after treatment systems, 
etc.). It usually includes co sts on the material, the labour and the energy requirements. 
The unit variable costs per engine are range d between 14€ - 384€ for small power engines and 
between 34€ - 108€ for large power engines. In general, variable costs for the CI engine 
manufacturers are offset by the added value deriving from the newly developed engines which 
allows the manufacturers to increase prices.  
 
EN 67   EN Unit costs per engine for CI engines 
Maximum 
Engine PowerL/cylinder
totallarge 
manufacturerssma
ll 
manufacturers & marinisers min max min max min max
<19 kW <0.9 12.800 9.600 3.200      30 €   54 €        31 €          664 €       -   €       -   € 
19 to <75 kW <0.9a 16.800 12.600 4.200      30 €   54 €        31 €          664 €      14 €    384 € 
19-37 9.200 6.900 2.300      30 €  54 €       31 €         664 €     14 €   384 € 
37-75 7.600 5.700 1.900      30 €  54 €       31 €         664 €     14 €   384 € 
75 to <3700 kW <0.9 2.080 1.560 520      30 €   54 €        31 €          664 €      34 €      34 € 
0.9-<1.2 2.080 1.560 520      30 €   54 €        31 €          664 €      34 €      34 € 
1.2-<2.5 2.080 1.560 520      30 €   54 €        31 €          664 €      49 €      49 € 
2.5-<3.5 2.080 1.560 520      30 €   54 €        31 €          664 €      51 €      51 € 
3.5-<7.0 2.080 1.560 520      30 €   54 €        31 €          664 €    108 €    108 € 
40.000 30.000 10.000 3.689.250 €        Units put on the market (1)Fixed costs small 
manufacturers & 
marinisers/engine 
(3)Fixed costs 
large 
manufacturers
/engine (2)Variable 
costs/engine (4)Costs linked to 
temporal 
discontinuation 
of engine 
models (5)
 
EN 68   EN SI outboard engines  
Fixed costs 
The unit fixed costs per engine are between 6€ - 7€. However, some SI engine manufacturers 
face the significant additional fixed costs. The solely EU SI outboard engine manufacturer 
faces a significant R&D and testing costs. R& D costs can amount up to approximately 3 100€ 
per engine and up to 2 M € per engine family. 
Variable costs 
The unit variable costs per engine may reach 1€ - 17€. The variable costs for these engines 
can be regarded as limited.  
Costs of recertification  
These are common for CI and SI  engine manufacturers.  They can reach up to 19 900€. The 
table below provides with the details.  
Typical costs [EUR, 2007] for 
engine >18kW, per engine family
Transport engine to test location 500 €
Certification by notified body 1.500 €
Administration by manufacturer [40hours x 200€] 8.000 €
Engine testing [40 hours x 235€/h] 9.400 €
Periodical update of certificate 500 €
19.900 € 
Discontinuation costs  
These costs include loss of prof it and additionally the loss of market share by not providing a 
certain model to the market. For EU based, SI outboard engine manufacturer, not active on 
the US market, high fixed costs could be ge nerated by R&D and redesigning engines from 
scratch; this could result in the decision to discontinue the pa rticular models and could have 
indirect social and economic impacts on suppliers  and customers. If one manufacturer was to 
discontinue one of its models, it would obvious ly affect the supplier who would not be 
receiving any new orders for this model. Mo reover, the discontinuatio n of one model will 
entail a loss of profit and a loss of market share for the manufacturer who might have to 
increase the prices of the other models to compen sate for these losses. If the price of the other 
models of the manufacturer increa ses, that will indirectly aff ect the consumer and its buying 
power. Similarly, for the small engine manufactur ers and marinisers mainly focusing on small 
engine power ranges that are only sold in the EU, the high compliance costs could lead to a 
decision to discontinue engine models. The discontinuation costs of CI manufacturer engine 
models may reach up to 3,6M €. If the non-Eur opean SI manufacturers, relying on the US 
ABT do not have the possibility to rely on a m itigating measure in the EU, they might have to 
discontinue particular mode ls or to stop putting these engines on the EU market. 
 
 
EN 69   EN Unit costs per engine for SI engines 
Maximum 
Engine PowerL/cylinder
min max
SI Outboard
< 3 < 4          1 €            1 € 
< 20 < 27          3 €            3 € 
< 75 < 110          8 €            8 € 
< 110 < 150        14 €          14 € 
< 150 < 230        17 €          17 € 
> 150 > 230        17 €          17 € 
SI Inboard
< 110 < 150          4 €        302 € 
< 147 < 200          6 €        426 € 
< 184 < 250          6 €        479 € 
< 220 < 300          8 €        586 € 
< 274 < 373          9 €        687 € 
> 274 > 373        13 €     1.022 € 
PWC        11 €          11 € 
        230.045   Small companies without export to US market Large companies using US ABT system                    1.688 € 
                   3.092 € Units put on the market (1)Other fixed costs/ 
engine (3)
7.684                                           
4.119                                           
210.829                                       49.608                                         
84.652                                         
54.242                                         
1.918                                           
2.214                                           
3.015                                           
1.018                                           
1.722                                           
296                                              
10.182                                         
                                          9.034  Fixed costs/engine  
linked to recertiication 
(2)
            6 € 
            6 € min ma x
            6 € 
            6 €             6 € 10.524                                         
            6 €               7 € 
              7 €               7 €               7 €               7 €               7 € 
          22 €             61 € 
            61 €             61 €             61 €             61 €             61 €           22 € 
          22 €           22 €           22 €           22 € 
            7 €               9 € Variable 
costs/engine (4)
 
 
EN 70   EN These figures are for guidance only and shou ld be regarded as orders of magnitude 
rather than absolute figures.  
Option 2 – Stricter limits - compliance costs  
Compliance costs have been estimated for the CI engine  sector to comply with the proposed 
Stage II exhaust emission limits without flexibil ities.  Costs for CI engines vary widely, i.e. 
between 5,7 M € and 19 M € per year .  
Total compliance costs (€ per year) – Option 2: CI engines 
L/cylinder
totallarge 
manufacturerssmall 
manufacturers & 
marinisers min max
<19 kW <0.9 12.800 9.600 3.200            389.997 € 7%       2.640.328 € 14%
19 to <75 kW <0.9a 16.800 12.600 4.200            752.212 € 13%       9.909.910 € 52%
19-37 9.200 6.900 2.300           411.926 € 7%      5.426.856 € 29%
37-75 7.600 5.700 1.900           340.286 € 6%      4.483.055 € 24%
75 to <3700 kW <0.9 2.080 1.560 520            133.383 € 2%          499.062 € 3%
0.9-<1.2 2.080 1.560 520            133.383 € 2%          499.062 € 3%
1.2-<2.5 2.080 1.560 520            165.806 € 3%          531.485 € 3%
2.5-<3.5 2.080 1.560 520            169.594 € 3%          535.273 € 3%
3.5-<7.0 2.080 1.560 520            288.609 € 5%          654.288 € 3%
40.000 30.000 10.000         2.032.984 €     15.269.408 € 
        3.689.250 € 64%       3.689.250 € 19%
       5.722.234 € 100%     18.958.658 € 100%Maximum 
Engine PowerTotal costs per year
Costs linked to temporal discontinuation of engine modelsUnits put on the market (1)
 
Total compliance costs of Option 2: SI engine  vary between 5,1 M € and 10,6 M € per year :  
• Compliance costs of SI OB are around 4,7 M € per year. The highest burden is 
covered by small engines (<75kW) as these represent the highest share of the market.  
• Compliance costs of SI IB vary between 0,3 and 5,7 M € per year  
• Compliance costs of PWC amount to around 0,2 M € per year.   
The compliance costs for outboard engines includ e costs to be made by a limited number of 
companies facing very high compliance costs: 
• EU based companies not serving the US market, with costs up to 1,8 M €/year 
reflecting the situation of one EU based SME and based on rough estimates provided 
by the industry. These high costs would result in the decision to discontinue 
particular models and w ould have significant social and economic impact on 
suppliers and costumers 
 
EN 71   EN Total compliance costs (€ per year) - Option 2:   SI engines 
Maximum 
Engine PowerL/cylinder
min max
SI Outboard
< 3 < 4         352.902 € 15%        367.189 € 15%
< 20 < 27         765.919 € 32%        790.299 € 32%
< 75 < 110         778.853 € 33%        794.475 € 33%
< 110 < 150         212.807 € 9%        215.838 € 9%
< 150 < 230         176.455 € 7%        178.668 € 7%
> 150 > 230           94.581 € 4%          95.768 € 4%
     2.381.517 € 100%     2.442.237 € 100%
        520.011 €        520.011 € 
         1.766.667 €         1.766.667 € 
         4.668.194 €         4.728.914 € 
SI Inboard
< 110 < 150           49.608 € 17%        696.673 € 12%
< 147 < 200           60.879 € 21%     1.078.359 € 19%
< 184 < 250           85.002 € 29%     1.627.794 € 29%
< 220 < 300           30.136 € 10%        658.649 € 12%
< 274 < 373           53.266 € 18%     1.288.563 € 23%
> 274 > 373           10.467 € 4%        320.677 € 6%
        289.358 € 100%     5.670.716 € 100%
PWC         163.817 €        183.792 € 
          230.045        5.121.368 €   10.583.422 € Small companies without export to US market Large companies using US ABT systemUnits put on the market
7.684                                           
4.119                                           
210.829                                       49.608                                         
84.652                                         
54.242                                         
1.918                                           
2.214                                           
3.015                                           
1.018                                           
1.722                                           
296                                              
10.182                                         
                                            9.034  10.524                                         Total costs per year
 
Sub-option 3.1 – Stricter limits with granting fl exibility scheme as a mitigating measure - 
compliance costs  
Costs for CI engines  vary between 1,2 M € and 8 M € per year . Compared to the basic 
Option 2, this means a cost decrease of 4,5 to 11 M €/year. It is due to the fact that some 
companies will not have to discontinue certain  engine models and instead can rely on a 
flexibility scheme. However, th is needs to be regarded as an underestimation of the total 
impact of the flexibility scheme for the CI se ctor as the figure does not reflect the impact of 
lost market share, nor additional benefits li nked to the ability for companies to spread 
investment costs over time to meet  the revised emission standards.  
Taking into account the lo wer bound of the variable costs, the highest contribution of this 
decrease comes from the implementation of th e flexibility scheme rather than from the 
installation of an exempti on of power ranges below 37 kW . When focusing on the upper 
bound of the variable costs, a dominant effect of  the high variable costs for the smaller power 
ranges prevails. This means that these costs would disappear in case of an exemption of 
power ranges below 37 kW. 
 
  
 
EN 72   EN Total compliance costs (€ per year) - Sub-option 3.1:   CI engines   
Maximum 
Engine Power L/cylinder
totallarge 
manufacturerssmall 
manufacturers & marinisers min max
<19 kW <0.9    12.800                 9.600                  3.200   19 to <75 kW <0.9a    16.800               12.600                  4.200   
19-37      9.200                 6.900                  2.300   
37-75      7.600                 5.700                  1.900              339.653 € 28%          5.249.449 € 66%
75 to <3700 kW <0.9      2.080                 1.560                      520               133.383 € 11%             499.062 € 6%
0.9-<1.2      2.080                 1.560                     520              133.383 € 11%             499.062 € 6%
1.2-<2.5      2.080                 1.560                     520              165.806 € 13%             531.485 € 7%
2.5-<3.5      2.080                 1.560                     520              169.594 € 14%             535.273 € 7%
3.5-<7.0      2.080                 1.560                     520              288.609 € 23%             654.288 € 8%
   40.000               30.000                10.000           1.230.428 € 100%          7.968.619 € 100%Units put on the market (1) Total costs per year
 
Total compliance costs of SI engines  vary between 4,6 M € and 10 M € per year , which is 
only slightly lower compared to Option 2. This can entirely be attributed to the fact that the 
company relying on ABT in the US market woul d be able to rely on a similar flexibility 
scheme in the EU, in which case the additional costs of 1,8 M € per year to meet the RCD emission standards can be regarded as sunk. Other conclusions made for Option 2 remain 
valid.  
The decrease in compliance costs indicates a small impact from the flexibility scheme. 
However, this figure does not take into accoun t additional benefits which are linked to the 
ability of companies to spread investment costs over time to meet the revised emission 
standards.   
Total compliance costs (€ per year) - Sub-option 3.1:   SI engines   
Maximum 
Engine Power L/cylinder
min max 
SI Outboard
< 3 < 4            352.902 € 15%            367.189 € 15%
< 20 < 27            765.919 € 32%            790.299 € 32%< 75 < 110            778.853 € 33%            794.475 € 33%< 110 < 150            212.807 € 9%            215.838 € 9%
< 150 < 230            176.455 € 7%            178.668 € 7%
> 150 > 230              94.581 € 4%              95.768 € 4%
        2.381.517 € 100%         2.442.237 € 0%
        1.766.667 €         1.766.667 € 
         4.148.184 €          4.208.904 € 
SI Inboard
< 110 < 150              49.608 € 17%            696.673 € 12%
< 147 < 200              60.879 € 21%         1.078.359 € 19%
< 184 < 250              85.002 € 29%         1.627.794 € 29%< 220 < 300              30.136 € 10%            658.649 € 12%< 274 < 373              53.266 € 18%         1.288.563 € 23%> 274 > 373              10.467 € 4%            320.677 € 6%
           
289.358 €     1 €         5.670.716 € 100%
PWC             163.817 €             183.792 € 
         230.045       4.601.358 €    10.063.411 € Small companies without export to US market  Total costs per year 
Units put on the market
                                          49.608  
                                          84.652                                            54.242                                            10.524  
                                            7.684  
                                            4.119  
                                        210.829  
                                            1.918  
                                            2.214  
                                          10.182  
                                            9.034                                              3.015  
                                            1.018                                              1.722                                                 296  
 
 
 
EN 73   EN Sub-option 3.2 - Stricter limits with granting transitional period as a mitigating measure - 
compliance costs46  
Costs for CI engines may vary between 2 M € and 8 M € per year . Cost decrease compared 
to the Option 2 is due to the fact that some companies will not have to discontinue certain 
engine models as they can rely on a mitigati ng measure. The transitional time of 3 years from 
entry into force means in fact a delay of 1 y ear of Directive’s applic ation when 2 years are 
presumably dedicated to transp osition of rules into national legislations. Such additional 1-
year lead time would have a similar effect on compliance costs as a flexibility scheme for 
majority of CI engine manufact urers (they will a void discontinuation of  production). However 
the lower bound of costs is expected a bit higher comparing to Sub-option 3.1 due to the shorter lead time for particularly small engine  categories. (1-year gr anted for Sub-option 3.2 
and 4-years for Sub-option 3.1 – dur ation of flexibility scheme). 
According to the information of industry, the additional lead time granted to SI engine 
manufacturers will be sufficient to consider the compliance cost s as sunk costs because they 
will fulfil already the US limits applied ear lier. Except one EU-based SME SI engine 
manufacturer which assumes their compliance costs between 1,8 M € and 5 M € per year.  
Sub-option 3.3 - Stricter limits with granting transitional period + specific transitional 
period for small and medium sized SI engine  manufacturers placing on the market the 
engines P
N ≤ 15 kW as a mitigating measure - compliance costs 
Compliance costs for CI engines will be the same  as for Sub-option 3.2 because the specific 
derogation would apply onl y to SI engines.  
Even though the costs (mainly development and recertification costs) of the SME SI engine 
manufacturers would remain in the same amount  as for Sub-option 3.2 they may be spread 
over longer time. This is crucial for the deci sion to continue with the production of some 
engine categories as the company doesn’t genera te sufficient profit to finance R&D of all 
engine categories in one and th ey are dependant on the external  financial sources. With the 
granted additional lead time they  will have the access to nece ssary financial resources to 
continue the production. 
 
 
 
                                                 
46 Compliance costs of the sub-options 3.2 and 3.3 are not precisely quantified by the ARCADIS Impact 
Assessment Study, but they are derived from the assumptions and qualitative description in the 
mentioned study 
 
EN 74   EN ANNEX XI:  Assumptions made to estimate the environmental noise impact – typical 
cases  
The sound impact depends on the number and dur ation of activities (passing craft, circling 
craft), the sound emission per craft during that ac tivity and the propagation to the observer. To 
give some estimate, based on the data presented so far, we will consider the situation along a 
typical canal or river, around a marina, around op en water (lake) and on such open water. For 
the number and use of the boats we will use estimates for an average day in the summer season and a peak day in that season. Other situations could be estimated from these results. Possible speed restrictions have not been taken into account, as these would represent 
additional measures to limit the impact of sound emissions.  
Canal, river 
Assume the canal or river has a width of 50 to 100 m and the observers are living along the 
shores; the average distance betw een the passing craft and the observers is assumed to be 50 
m. Since the use of PWCs is more restricted to a certain area and not so much passing, these 
craft will be neglected here. Fu rthermore it is assumed that th e craft are used for 80% during 
the daytime (7:00h to 19:00 h) and for 20 % dur ing the evening (19:00 to 23:00h) and are not 
used during the night period; this divisi on does not prove to be  critical though.  
Open water 
In case of open water the craft will not so much  pass the observer but will be distributed over 
(a large part of) the water, so partly at larger  distance from the observer at the shore. As a 
representative average a dist ance of 200 m is chosen. The sa me distribution over day and 
evening is used as for the canal; in this case al so PWCs are considered with a use of 1 h per 
day, equally divided over day a nd evening time. Outboard engines in this case are considered 
to be used only part of the time, leading to an  engine use varying from 1/2 h (sailing boat) to 3 
h (motor boat). Another aspect in this case coul d be the disturbance of people in one craft by 
another craft. For this situation a typical minimum passing distance of 25 m is chosen; all 
others assumptions are taken as identical.  
Marina 
For a marina also a distance of 200 m is arbitr arily chosen, but the gl obal effect of other 
distances is indicated. It is assumed that engi nes are used for 1/3 h fo r each boat to leave and 
enter a marina. Other activities in the marina are neglected as  well as sound re duction through 
screening by buildings  and other obstacles. 
Additional remarks 
It should be clarifie d that the sound production is lowe r when less power is used (lower 
speeds) and higher when more throttle and th us higher speeds are used. For outboard and 
inboard engines the data show about 8 dB(A) higher levels by using fu ll throttle than the 
conditions assumed here as normal; for PWCs higher levels by up to 15 dB(A) have been 
reported depending on the use of th e craft. Though these circumstan ces have a direct effect on 
the higher or lower maximum sound levels, the effect on the equivalent levels is much less, 
due to the effect of an also changed passing sp eed. It is questionable whether the disturbance 
 
EN 75   EN in case of increased use of pow er is mainly due to the highe r sound level or due to the 
disapproval of the type of be haviour and other disturbing e ffects like higher waves. 
 
EN 76   EN ANNEX XII :  Share of compliance costs in turnover, impact on competitiveness 
All SMEs for which the share of compliance cost s in yearly turnover of engine sales on the 
EU market could be calculated will – at least in relative terms – face much higher compliance 
costs than their larger competitors. Although larg er engine manufacturers and marinisers are 
likely to have higher absolute compliance co sts, the burden on SMEs is likely to be 
substantially higher. The compliance costs / sales ratio offers an indication of the impact higher emission standards may have on companie s’ operations and, when considering the 
ratio for a series of companies, the imp act higher emission standards may have on the 
company’s competitiveness. 
The ratio reveals that SMEs face a majo r burden and may see their competitiveness 
deteriorate as a result of hi gher exhaust emissions standards.  Compliance costs of SMEs for 
the proposed emissions standards range betw een 5,75% and 67,35% of annual turnover when 
the stricter limits will be applied. Large engi ne manufacturers have a much more moderate 
ratio, varying between  0,06% and 2,76%.  
Relationship between the level of compliance costs and competitiveness effects 
Significance of 
compliance costs Possible actions Possible consequences for 
competitiveness 
Insignificant No action Business as usual 
Increase the selling price Decrease  in sales, shrinking market* 
Absorb the compliance costs Decrease in profits, less investments 
Significant 
Modify production function Depending on how the new 
combination of inputs affects the 
selling price 
Increase the selling price** Decrea se in sales, shrinking market* 
Shift the focus of the business Survival as a niche player Very significant 
Cease operation Out of market 
* The actual effect depends on the price elastic ity of demand for recreational craft engines. 
** A further increase of the selling price will only be possi ble if the price elasticity of demand for recreational 
craft engines is very inelastic. 
Source: ARCADIS Impact Assessment Study (2008), p. 90-93 
 
EN 77   EN ANNEX XIII :  Impact of price effects on the number of jobs  
The number of jobs in the recreational marine  engine manufacturing and marinising industry 
in Europe on which the study is based for deri ving the likely number of job losses is listed in 
the following Table. The number of employees  directly involved in  the manufacture and 
marinisation of CI and SI OB engines in the EU is probably higher than the number of jobs 
indicated in the following Table. Only taking into account those compan ies having replied to 
the questionnaire and/or bei ng interviewed the number of employees involved in the 
production of CI engines in the EU amounts to 1 600 people. The total number of employees 
directly involved in the manufacture and customis ation of SI OB engines in the EU is slightly 
over 400. The numbers of 1 600 and 400 employees wi ll be used for quantifying job losses in 
the EU based CI and SI OB engine  manufacturing / marinising chain.  
The assumptions concerning the price elasticity  of demand, employment elasticity and the 
multiplier for assessing the indi rect employment effects in the supply chain are developed in 
ECNI Impact Assessment (2006). The elasticity of demand for marine engines, which is a 
derived demand of the elasticity of demand for boa ts, is set at -2. This means that for every 
1% price increase the quantit y demanded would fall by 2% . Similarly, the employment 
elasticity provides an indication of the percentage change in direct employment that is 
associated with a change in output. The employment elastic ity is set at 0,35. Finally, the 
multiplier for assessing the overall (direct and in direct) employment effect is 1,6 meaning the 
indirect employment effect amounts to 60%  of indirect employment effect.  
Based on the above assumptions, following Table provides the potential job losses in the EU 
CI engine, SI OB engine and PW C manufacturing chain. No job lo sses in the EU SI IB engine 
manufacturing chain as we assu med production of SI IB engines in the EU to be negligible. 
Potential job losses in the CI engine manufacturing chain 
Option Number 
of direct 
jobs % 
increase 
in 
average 
retail 
price  % 
decrease 
in 
demand % 
decrease 
in direct 
jobs Direct 
job 
losses Indirect 
job 
losses Total 
job 
losses 
min 1,24% 2,48% 0, 87% 13,9 8,3 22,2 
max 4,10% 8,20% 2,87% 45,9 27,6 73,5 Option 2 
max 3,30% 6,61% 2,31% 37,0 22,2 59,2 
min 0,27% 0,53% 0, 19% 3,0 1,8 4,8 
max 1,72% 3,45% 1,21% 19,3 11,6 30,9 Suboption 
3.1 
max 1 600 
3,29% 6,57% 2,31%  36,8 22,1 58,9 
 
 
 
EN 78   EN Potential job losses in the SI OB engine manufacturing chain 
Scenario Number 
of direct 
jobs % 
increase 
in 
average 
retail 
price % 
decrease 
in 
demand % 
decrease 
in direct 
jobs Direct 
job 
losses Indirect 
job 
losses Total 
job 
losses 
min 0,54% 1,07% 0, 38% 1,5 0,9 2,4 
Option 2 
max 0,54% 1,09% 0,38% 1,5 0,9 2,4 
min 0,48% 0,95% 0, 33% 1,3 0,8 2,1 Suboption 
3.1 max 400 
0,48% 0,97% 0,34% 1,4 0,8 2,2 
Potential job losses in the PWC manufacturing chain 
Scenario Number 
of direct 
jobs % 
increase 
in 
average 
retail 
price % 
decrease 
in 
demand % 
decrease 
in direct 
jobs Direct 
job 
losses Indirect 
job 
losses Total 
job 
losses 
min 0,16% 0,32% 0, 11% 0,3 0,2 0,5 
Option 2 
max 0,16% 0,32% 0,12% 0,4 0,2 0,6 
min 0,18% 0,35% 0, 11% 0,3 0,2 0,5 Suboption 
3.1 max 300 
0,18% 0,35% 0,12% 0,4 0,2 0,6 
Source of all Tables: A RCADIS Impact Assessment Study (2008), p. 98-100 
 
  
 
EN 79   EN ANNEX XIV :  SME Test  
The SME Test  
(1) Consultation with SMEs 
representatives  See section 2.2. 
(2) Preliminary assessment of 
businesses likely to be affected  See section 3.4 
(3) Measurement of the impact on SMEs See sections: 
- 6.1.2; Option 2, Economic impact - 6.1.3 Option 3, Sub-option 3.1, Economic 
impact 
- 6.1.3 Option 3, Sub-option 3.2, Economic 
impact 
- 6.1.3 Option 3, Sub-option 3.3, Economic 
impact 
  
(4) Assess alternative options and 
mitigating measures  See sections: 
- 6.1.3 Option 3, Sub-option 3.1, Economic 
impact 
- 6.1.3 Option 3, Sub-option 3.2, Economic 
impact 
- 6.1.3 Option 3, Sub-option 3.3, Economic 
impact 
 
 The preferred sub-option 3.3 envisages some 
general mitigating measures common to all enterprises, as well as a specific transitional 
 
EN 80   EN period for SMEs placing on the EU market the 
SI outboard engines.