COMMISSION STAFF WORKING PAPER IMPACT ASSESSMENT
Date: 2011-07-26
Institutions: European Commission
Subjects: engine, noise, pleasure craft, pollution control measures, small and medium-sized enterprises

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} 

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Contents: 

1. Introduction 

1.1 Overview of the EU legislation for Recreational Craft 
1.2. Overview of the Recreational Craft market in the EU 

2. Procedural issues and consultation of interested parties 

2.1 External expertise  
2.2 Consultation of external stakeholders 
2.3 Consultation of the Commission services  
2.4 Internet public consultation 
2.5 Consultation with SMEs representatives   
2.6 Opinion of the impact assessment board   

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3. Problem definition 

                                   3.1.2.1 EU-US trade relations for RCD 

3.1.1.1 Impact of emissions to the air  
                                   3.1.1.2 Impact of emissions to water   

3.1.1 Effects on environment and health 

3.1 Exhaust emissions caused by recreational craft 

                       3.1.2.2 Different EU/US emission regulations 

3.1.2 The international context - emission regulations in the US 

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3.1.3 The EU Internal Market context-risk of diverging national standards  15 
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3.2 Noise emissions from recreational marine engines 
3.3 Safety and design concerns 
3.4 Who is affected?   
3.5 Legal certainty and simplification - alignment with the NLF 
3.6 Consistency with EU Policies 
3.7 Does the EU have right to act 
3.8 How the current situation is likely to evolve 

4. Objectives   

5. Policy options 

5.1 Policy options discarded early in the impact assessment process  

                       5.1.1 Self regulation for exhaust emissions 
                       5.1.2 Discontinuing existing EU action 

           5.1.3 Modification of essential requirements on safety and design 
5.2 Policy options retained for further analysis 

5.2.1 Exhaust emission limits for engines 
5.2.2 Noise emission limits for engines 
5.2.3 Alignment of the RCD with the New Legislative Framework   

6. Analysis of impacts 

6.1 Impact of stricter exhaust emissions limits 
                       6.1.1 Option 1 - No change of limits   

6.1.2 Option 2 - Stage II of the exhaust emissions limits 

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6.1.3 Option 3 - Stage II of the limits with mitigating measures 

6.2 Impact of stricter noise emissions limits   
6.3 Impact of the measures aligning the RCD with the NLF  

7. Monitoring and evaluation 

Glossary 

Annexes 

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Overview of recreational craft and engines for recreational craft sector 
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Public consultation on a possible approach to revision of the RCD   
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Schematic representation of different drive principles for boat engines 
Annual average air concentrations in Europe - affected locations 
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Overview of the exhaust and noise emissions limits in the EU and the US  54 
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Analysis of 5 different scenarios 
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Annex I 
Annex II  
Annex III 
Annex IV 
Annex V 
Annex VI 
Annex VII  Methodology used for environmental impact analysis 
Annex VIII  The calculation of the exhaust emission reductions   
Annex IX   Monetization of environmental benefits 
Annex X   Methodology and assumptions used for economic impact  
analysis, calculation of compliance costs 
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Assumptions made to estimate environmental noise impact–typical cases  74 
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Share of compliance costs in turnover, impact on competitiveness   
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Impact of price effects on the number of jobs 
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Annex XI 
Annex XII  
Annex XIII 
Annex XIV  SME test 

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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  Recreational  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 when designing crafts in order to place it on the 
EU  market.  The  manufacturers  must  fulfil  several  obligations  in  order  to  show  that  their 
product complies with the Directive, including a Declaration 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 the use and maintenance of the product. 

The amended Directive 2003/44/EC introduces specific requirements for propulsion engines, 
for  both  the  compression  ignition  (CI)  engines  and  the  spark  ignition  (SI)  engines.  The 
Recreational  Craft  Directive  covers  pollutants  from  engines  exhaust  emissions  such  as 
particulate matters (PM), nitrogen oxides (NOx) and hydrocarbons (HC). It does not address 
CO2 or other green house gas (GHG) emissions. Currently no inventory or data is available on 
GHG emissions from recreational craft engines. Nevertheless, GHG emissions 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  provides  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  craft  sector  consists 
mainly of small and medium enterprises (more 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  recreational  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  Europe  involve  some  37  000  companies  which 
represent  a  wide  range  of  aactivities  such  as  marinas,  boatyards,  marine  equipment 
manufacturers, hire charter and sailing schools, marine solicitors, insurance brokers etc. The 
sector  directly  employs  some  272  000  workers  and  its  annual  turnover  is  estimated  at  23.4 
billion €. The approximately 2 600 EU boat builders 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 categories: the original engine 
manufacturers and the so-called marinisers. While original engine manufacturers are mainly 
large  international  companies,  marinisers  are  exclusively  very  small  companies  (ca.  25 
employees),  producing  on  average  500  units  per  year.  The  latter  adapt  engines  which  are 

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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) 

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originally  produced  for  other  purposes  such  as  automotive  engines  and  convert  these  for 
marine use. The EU counts some 40 engine manufacturers and marinisers.  

The recreational craft manufacturing sector is strongly export oriented 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  commissioned  to  examine  further  improvements  of 
environmental  characteristics  of  recreational  marine  engines  and  the  impact  thereof.  The 
studies  are  publically  available  on  the  European  Commission’s  website,  DG  Enterprise  and 
Industry, Maritime Industries. 

•  TNO2 “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.  (“Stocktaking  study”).  The  Commission  requested 
this  study  after  having  introduced  environmental  requirements  in  the  Recreational 
Craft  Directive.  Its  objective  was  to  evaluate  the  environmental  impact  from 
propulsion  engines  used  in  recreational  craft.  The  study  identified  four  possible 
options  for  further  emission  reduction  measures,  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 measured in detail the impacts and distributive effects of the 
four  possible  scenarios  for  emission  reduction  measures  as  identified  in  the  TNO 
study. It was concluded that each of the scenario options investigated would result in a 
relatively  low  emission  reduction,  and  would  entail  disproportionate  cost  for  certain 
European SMEs.  

•  ARCADIS4  “Complementary  Impact  Assessment  Study  on  possible  emission 
reduction  measures  for  recreational  marine  engines”  –  June  2008.  Following  the 
results  of  the  previous  study,  the  Commission  launched  another  study  in  order  to 

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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  
Study on the Feasibility and Impact of Possible Scenarios for Further Emission Reduction Measures for 
Recreational  Craft  Engines 
Impact  Assessment  Report”,  26  October  2006,  ECNI”. 
http://ec.europa.eu/enterprise/sectors/maritime/documents/index_en.htm  
Complementary  Impact  Assessment  Study  on  possible  emission  reduction  measures  for  recreational 
marine 
Enterprise 
http://ec.europa.eu/enterprise/sectors/maritime/documents/index_en.htm  

ARCADIS 

engines, 

2008, 

June 

DG 

for 

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identify and assess new scenarios which would 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 and 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  participation  of  the  national  public  authority  experts,  the 
representatives  of  industry,  customer  associations,  standardisation  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 engines and to collect the opinions and comments of 
the  main  stakeholders.  Stakeholders  contributed  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 revised in the Recreational Craft 
Directive.  The  participating  experts  –  representatives  of  market  surveillance  authorities, 
notified  bodies  and  industry  associations  -  addressed  recommendations  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 the 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  actively  participated  in  the  preparation  of  the 
IA: SG, DG ENV, DG JRC, DG SANCO, DG MARE .Other services were informed about all 
steps  taken,  but  did  not  attend  ISSG  meetings:  LS,  DG  ECFIN,  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  reflects  the  main  concerns  and  conclusions 
expressed by the services.  

2.4 Internet public consultation: 

A  public  internet  consultation  was  organized  between  11th  May  and  19th  July  2009.  The 
Commission services received 32 responses to the questionnaire published in English only. 16 
replies  were  sent  on  behalf  of  various  institutions,  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  the  internet  public  consultation  was  to  seek  views  and  opinions  of 
citizens,  the  representatives  of  enterprises  and  the  public  authority’s  representatives  on 
various  issues  that  may  need  to  be  addressed  in  a  draft  proposal  to  further  amend  the 
Directive.  The  consultation  revealed  overall  support  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 common 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 

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further reduction of noise limits of marine engines would not effectively solve the problem of 
excessive noise in the exposed areas. Respondents suggested that local restrictions on the use 
of boats will better address this problem.   

The consultation highlighted that the specificities of the recreational marine 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 private 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 

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Meetings with SMEs 

Consultation with SMEs via Internet Public Consultation 

Round table discussions with the representatives 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 concluded that the IA report 
presents an analysis of economic, environmental and social impacts while the assessment is 
not  yet  sufficiently  clear  and  needs  to  address  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  impacts  of  emissions.  The  justification  of  the 
emissions option needs particular work, informed by a clear EU-US comparison. The impact 
analysis  should  cover  all  objectives.  The  views  of  stakeholders  should  be  described  more 
consistently, and views of health and environment stakeholders included. 

On  the  base  of  the  1st  IAB  opinion  the  problem  definition  has  been  redrafted  in  order  to 
clearly  explain  both  the  environmental  and  economic  concerns  with  regard  to  the  exhaust 
emission  limits.  The  description  of  the  impact  of  each  option  was  completed  by  the 
monetization  of  environmental  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  reflected  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 comparison with other relevant EU legislations. The assumptions and 
methodology used for the calculations are addressed in the main text. An evaluation of how 
the  policy  options  meet  the  objectives  has  been  added.  The  stakeholders’  opinions  are 
reflected  throughout  the  IA  and  in  its  analytical  part.  A  summary  of  the  internet  public 
consultation is provided. 

The  revised  IA  was  resubmitted  to  the  IAB  on  5th  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 

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measures  have  been  further  clarified  and  the  proportionality  of  options  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 the market  of recreational 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-ignition engines (called SI 
or  petrol  engines)  or  compression  ignition  (CI  or  diesel  engines)  both  for  inboard  and 
outboard use (see information on the specific engine terminology in Annex III). 

3.1.1.1 Impact of emissions to the air 

According to the air emission inventory for Europe CORINAIR,5 the overall emissions from 
recreational  craft  are  in  general  minimal  compared  with  other  pollution  sources  such  as 
energy producing industries, manufacturing industries, road transport, etc. Recreational crafts 
are estimated to contribute to approximately 0.5% of  total hydrocarbon (HC) emissions and 
0.1%  of  total  NOX  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 craft at certain times of peak activity. Such affected locations are 
the areas of big lakes and the attractive sea shores. Geographically, 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 eighties local authorities in Germany, Switzerland 
and Austria bordering on Lake Constance started to regulate the use of boats and the exhaust 
emissions  from  boats  to  preserve  a  high  quality  of  the  air  and  the  drinking  water.  As  a 
consequence,  in  order  to  ensure  a  high  protection  of  the  environment  while  ensuring  the 
correct functioning of the internal market, the so-called Stage I of the exhaust emission limits 
were adopted at EU level. 

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CORINAIR  European  Topic  Centre  in  Air  Emissions:  The  results  of  an  in-depth  study  published  in  1998,  CORINAIR 
1994 Inventory were reconfirmed in 2007. 

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Figure  1  indicates  annual  average  NOx  emissions  made  by  various  sources  of  pollution. 
While it does not address the short term (or peak) periods, it can be deducted that for areas 
suffering  from  NOx  concentrations  above  the  Environmental  Quality  Standard  (EQS)6,  the 
short  term  concentrations  will  be  more  significant.  Information  about  the  EU  annual  air 
concentrations of particulate matters (PM) is available in Annex IV. 

Figure 1: Annual average NOX air concentrations  

Source: The Complementary Impact Assessment Study: ARCADIS (2008), p.58  

As  indicated,  the  most  important  air  pollutants  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 them may affect human health either directly 
or indirectly. Nitrogen compounds derived from NOx emissions are considered as a particular 
harmful  impact  from  exhaust  emissions.  Nitrogen  dioxide  (NO2)  causes  direct  acute  and 
chronic effects to the respiratory system. Furthermore, NOx contribute to the nitrogen load in 
the  environment  which  can  result  in  significant  impacts  caused  by  eutrophication7  of 
terrestrial  and  aquatic  environments.  Moreover,  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 result in the formation of photochemical smog. In 2008, the health-
related  ozone  target  was  exceeded  at  35  %  of  all  rural  background  measurement  stations 

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EQS is a concentration established to ensure protection against exposure. 
Eutrophication  is  an  increase  in  the  concentration  of  chemical  nutrients  in  an  ecosystem  to  an  extent 
that increases the primary productivity of the ecosystem. 

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reporting to the EEA8. NOx emissions can also occur naturally, e.g. in salt marshes, estuaries 
and shallow water areas. 

The contribution of recreational craft to the emissions of PM is rather small (see Table 1 - 3). 
The following tables show estimated concentrations of pollutants (NOx, PM, CO) measured 
in marine environment and compared to the environmental quality 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 coast 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   

NOx short term 

PM long term   

PM short term 

CO long term   

CO short term 

40 

200 

40 

50 

350 

10 000 

17,54 

599,47 

0,26 

0,59 

231,26 

3093,82 

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10 

EEA SOER 2010–Thematic Report Air Pollution at http://www.eea.europa.eu/soer/europe/air-pollution 
Directive 2008/50/EC refers to a limit value for NO2 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 NO2 and NO) only since NO 
emissions can be transformed into NO2 in the atmosphere.  

Long-term concentration represents an annual mean 

- Short-term ambient NO2 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 

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Table 2: Estimated concentrations of selected pollutants for Lake Marina 

Pollutant   

EQS (µg/m3) 

Current situation (baseline) 
(µg/m3) 

NOx long term   

NOx short term  

PM long term   

PM short term 

CO long term   

CO short term 

40 

200 

40 

50 

350 

10 000 

13,17 

213,97 

0,27 

0,56 

137,98 

1121,75 

Table 3: Estimated concentrations of selected pollutants for Inland Waterways 

Pollutant   

EQS (µg/m3) 

Current situation (baseline) 
(µg/m3) 

NOx long term   

NOx short term 

PM long term   

PM short term 

CO long term   

CO short term 

40 

200 

40 

50 

350 

10 000 

0,16 

2,5 

0 

0,02 

3,73 

29,64 

Source of the tables: Environmental Impact Assessment Study, ECNI (2006), p.152 

The fate of exhaust emissions entering the atmosphere is complex, and heavily influenced by 
the  prevailing  meteorological  conditions  as  well  as  the  topography  of  the  land  and  the 
vegetation present. Whilst some emissions will travel 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 water 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 highly toxic. However, the concentration of CO 
in  the  open  air  is  short-living  and  rather  small  as  CO  quickly  oxidizes  and  forms  CO2.  It 
means that marine ambient is not normally 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  living  quarters  within  an 

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enclosure and the engine compartment to be ventilated. 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 minor 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 was found that HC from recreational 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 positively 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 drinking water legislation.  

3.1.2 The international context - emission regulations in the US 

3.1.2.1 EU-US trade relations for RCD 

The  number  of  motorboats  and  personal  watercrafts  outreach  the  other  boat  categories.  The 
sales figures of engines provided in tables 4 and 5 underline the importance of the EU and US 
markets.  For  SI  (petrol)  engines,  the  latter  represents  more  then  half  of  the  sales  in  value 
terms  and  more  than  one  third  of  units  sold  at  the  world  market.  Furthermore  there  is  a 
dominance of SI engines at world 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 the EU and US market explains the continued effort to align 
exhaust emission regulations on both 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) 

Engine category 
(in kW) 

Unit sales 

Sales value (in million €)  

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 

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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 

Total 

4 119 

48 070 

5 896 

80 

933,6 

117,8 

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 category in units and value in Europe, U.S. and the 
rest of the world (2007) 

Engine category (in 
kW) 

Unit sales 

Sales value (in million €) 

EU 

< 18 

12 800 

18 – 37 

37 – 75 

9 200 

7 600 

US 

865 

622 

514 

75 - 130 

3 600 

1 147 

Other 

EU 

60,8 

82,5 

91,4 

60,8 

Other 

US 

4,1 

5,6 

6,2 

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 for 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  from  SI  and  CI  engines.  Standards  for  CI 
engines were introduced in 1998 and been progressively reinforced until 2008 (CFR 40 Part 
1042).  Since  2001  the  Californian  Air  Resources  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  look  is  dedicated  to  the  comparison  of  the  main  exhaust  emission 
limits for SI outboard engines in the EU and the US. 

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Table 6: Comparison of the applicable limits for SI OB marine engines 

Power (PN) 

Carbon Monoxide (CO) 

Hydrocarbons + Nitrogen Oxides 
(HC + NOX) 

(kW) 

2,5 

3 

4,3 

10 

30 

40 

50 

100 

EU 

US 

EU 

US 

(g/kWh) 

390 

350 

290 

210 

170 

165 

162 

156 

488 

485 

479 

450 

350 

300 

300 

300 

36 

34 

30 

25 

22 

22 

22 

21 

30 

30 

30 

21 

18 

17 

17 

16 

Table 6 compares the currently applicable emission limits in the EU with the most recently 
adopted  US  regulation  which  shows  lower  limit  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  which  allows  the  engine  manufacturer  a  certain 
degree of freedom when calibrating engines to meet the exhaust emission limits including CO 
and PM. HC emissions are unburned residues of fuel, where NOx is the reaction product after 
combustion. When  optimising  the  engine  performance,  HCs  and  NOx  perform  in  opposite 
direction,  if  one  goes  up,  the  other  goes  down.  Other  differences  of  EU  and  US  emission 
limits  for  various  types  of  engines  are  highlighted  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  the  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 not 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, which for most manufacturers who supply engines 
to the EU and to the US markets need to be paid twice. An enquiry among the representative 
companies  in  this  market  highlighted  that  the  average  costs  per  engine  is  approximately  20 
000 € which in case of a small engine manufacturer 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  expect  would  limit  production  costs  due  to  the 
advantages of scale and lower costs of testing procedures. 

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If  the  EU  and  the  US  are  not  able  to  agree  on  a  common  set  of  marine  engine  exhaust 
emission  standards,  it  is  unlikely  that  the  rest  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 exhaust emission limits in the future.  

3.1.3 The EU Internal Market context - risk of diverging national standards 

Some of the EU regions and local areas are particularly 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  RCD  is  a  full  harmonisation  directive,  Member 
States  can  however  not  introduce  individual  national/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  apply  this  measure  until  the  extreme  such  as  a 
complete ban of use of some boats (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,  Protocol  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  exhaust  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 shore. 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  extreme  cases  the  permanent  exposure  to  noise 
will cause hearing impairment, hypertension, 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  essential  safety  requirements, 
namely  the  boat  design  categories.  They  propose  to  extend  and  re-define  boat  design 
categories  in  order  to  better  reflect  the  specific  risks  of  each  boat  category  in  relation  to  its 
use. 

The essential requirements for safety have also been 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  the  philosophy  of  the  New  Approach  which  is  limited  to  fix  the 
essential requirements in the legislation and leaves the definition of technical solutions to be 
fixed in Harmonised Standards. 

A  small  modification  has  been  discussed  for  the  definition  of  the  discharge  prevention  in 
sense of strengthening the requirement to install the holding tanks mandatorily and not only 
voluntarily. 

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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  sector  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 consultation has shown that boat builders are not likely 
to  be  affected  by  the  restricted  exhaust  emissions  since  most  boats  are  designed  to  host 
differently designed engines. The choice of the engine is often left to the customer.  

The other group of SMEs consists of engine manufacturers 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 marinisers buy already compliant engines used 
for different applications (on-road, non-road), they will not be likely affected by the changes, 
too.  

Therefore,  the  preliminary  assessment  leads  to  the  conclusion  that  the  small  and  medium 
sized  engine  manufacturers  are  the  main  affected  party.  Only  a  few  engine  manufacturers 
falling  into  this  category  were  identified.  Despite  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  shown  that  there  is  at  least  one  independent  SME 
engine manufacturer.  

3.5 Legal certainty and simplification - 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 national legislation, is appropriate, or whether a 
regulation should be envisaged instead, the current positive experience with the application of 
this directive did not show any reason for a change. 

On 9 July 2008, the Council and the European Parliament adopted 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  order  to  ensure  further  consistency  with  other 
product legislation, it is also appropriate to align certain provisions of the RCD Directive with 
the  Decision,  in  so  far  as  sector  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 

12 

Regulation  (EC)  No  765/2008  lays  down  horizontal  provisions  on  the  accreditation  of  conformity 
assessment bodies, on the CE marking and on the Community market surveillance 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. 
The Decision is a sui generis instrument, which provides common principles and reference provisions 
for the purposes of legislation based on the New Approach principles. The Decision 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 take the provisions of the Decision into account whenever legislation 
is drawn up which concerns a product already subject to other Union acts. 

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(1)  horizontal  definitions  (e.g.  placing  on  the  market,  manufacturer,  importer,  distributor, 
etc.), (2) obligations of economic operators (including obligations to ensure traceability13), (3) 
harmonised  standards  and  presumption  of  conformity,  (4)  formal  objection  to  harmonised 
standards,  (5)  requirements  for  conformity  assessment  bodies  and  for  authorities  notifying 
them  as  well  as  for  notification  procedures,  (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  defined  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  environment  in  every  Union  policy,  especially  those 
affecting the maritime environment. The Recreational 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  Directive  contributes  to  a  progressive  reduction  of  emissions,  in 
particular  with  regard  to  localised  areas  such  as  marinas  and  harbours,  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 air pollution on human health and environment as 
specified in the Directive 2008/50/EC on ambient air quality and cleaner air for Europe.18 The 
approach followed to regulate recreational craft 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  ceilings  Directive  2001/81/EC20establishes  legally  binding  limits  to  be 
obtained  by  2010  for  the  total  permissible  emissions  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 
16 

COM (2019) 2020 final 
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.  
See the link: http://europa.eu/legislation_summaries/environment/air_pollution/l28031a_en.htm#KEY 
See the link: http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32008L0050:EN:NOT 
OJ L59, 27.2.98 

17 
18 
19 
20 
emission ceilings for certain atmospheric pollutants,  OJ L 309, 27.11.2001, p.22 

Directive 2001/81/EC of the European Parliament and of the Council of 23 October 2001 on national 

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pollutants  including  nitrogen  oxides.  Current  forecast  suggest  11  Member  States  will  not 
comply with their ceilings for NOx.  Therefore, more stringent emission 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 across national waters, the significant part of 
recreational craft cruises is international. In the absence of common emission limits  the EU 
national  administrations  used  to  create  their  national  abatement  strategies,  which  solved  the 
problem  locally  but  created  another  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 economic 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  revision  of  these  limits  is  within  the  exclusive 
competence of the Union, and therefore, the application 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  emission  abatement  technologies  for  recreational 
marine engines.  

Lower  emission  requirements  for  recreational  craft  engines  will  be  a  disincentive  for 
European  manufacturers  to  innovate  and  thus  lead  to  a  situation  where  in  a  longer  term 
perspective  they  would  loose  their  competitive  position.  This  will  be  particularly  true  for 
enterprises – mostly SMEs - supplying solely the EU market. 

Finally  the  EU  market  could  also  attract  new  third  country  manufacturers  which  may 
strengthen their position in the EU market by selling lower environmentally performing and 
therefore cheaper engines 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.   

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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 regulatory conditions with the EU main trading partners and a smooth 
functioning of the internal market for RCD. 

GENERAL 

SPECIFIC 

OPERATIONAL 

1)  Protect  environment  and 
human health  

1) 
the 
Improve 
environmental  performance 
of RC 

1)  Revise  exhaust  emission 
limits. 

2)  Revise  limits  for  noise 
emissions 

Revise 
3) 
characteristics of the RC 

safety 

1)  Revise  exhaust  emission 
limits. 

2)  Improve  the  functioning  of 
the internal market  

3)  Prevent  fragmentation  of 
the  internal  market    caused 
national 
by 
requirements 
the 
on 
characteristics of RC 

different 

Protect 

(SMEs 
from 

vulnerable 
4) 
in 
enterprises 
the 
particular) 
worsening  their  position  on 
the  market  and  potential  job 
losses because of complying 
with the new legislation.  

Introduce  mitigating 
4) 
the  most 
measures 
market 
vulnerable 
operators in Europe (SMEs).  

RC 

for 

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the  EU  RC 
5)  Provide 
industry  as  well  as  citizens 
with legal certainty.  

5)  Align  the  RCD  with  the 
NLF 

3) Promote the approximation 
of 
limits 
worldwide 

emission 

the 

Reduce 

additional 
6) 
compliance 
from 
different regulatory regimes 

costs 

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 further emission limits by a non-regulatory measure 
(e.g.  by  means  of  a  voluntary  industry  code).  The  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 limits of the non-legislative instrument and 
the  legally  binding  ones  of  the  Directive  (and  other  legislation  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  globally  operating  industry  stakeholders  on  the 
one  hand  and  those  that  are  operating  exclusively  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 benefit 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  monitoring  and  enforcement  tools  could  be 
developed  and  implemented  to  ensure  a  proper  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. 

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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. introduced 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 manufacturers would have fewer incentives to invest 
into  the  development  of  cleaner  models.  Furthermore,  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 Member States. As the option would not lead to the 
requested improvement of environmental characteristics of marine engines 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,  while  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 engine 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 craft. 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  unlikely  that  the  consumers  will  examine  the 
engines' labels before deciding to buy a boat. The usefulness of such label would therefore be 
questionable and disproportionate to the burden 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  factor  entering  in  the  purchasing  choice  is  the  brand 
name of the car. The environment criterion therefore is not an important factor in the buying decision. 
This would even more true in case of individual consumers rather than of companies.  

EN 

21 

   EN 

 
                                                 
As  a  significant  part  of  the  recreational  craft  placed  on  the  EU  market  are  second-hand22  
boats  imported  from  third  countries,  the  responsibility  of  testing  the  boat,  estimating  the 
emission limits and affixing the label would lay in this case on the private 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 labels 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 additional administrative burden for the industry.  

5.1.3 Option 3 - Modification of essential requirements on safety  

A  revision  of  safety  requirements,  in  particular  with  regard  to  new  boat  design  categories 
should  be  achieved.  However,  the  TNO  Study  2004  concluded  that  there  is  no  scientific 
evidence for the need to change the design categories.   

In spite of some minor clarifications made in the essential safety and design requirements, the 
concerns  described  above  have  not  been  further  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 possibility of introducing a new Stage of the exhaust emission limits. 
Five possible scenarios to restrict the limits depending on the engine’s power (PN) have been 
discussed.  Four  scenarios  were  developed  by  TNO  in  the  Stocktaking  Study  2004  and 
assessed  by  ECNI  in  the  IA  Study  2006.  The  introduction  of  these  four  scenarios  was  the 
answer  to  a  request  of  the  Council  and  the  European  Parliament  to  develop  more  stringent 
exhaust emission limits based on the technological development in the sector. These scenarios 
considered  the  alignment  with  the  NRMM  Directive  as  regards  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 techniques 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 not 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 

22 

   EN 

 
 
                                                 
Table 7: Overview of five scenarios 

Scenario 1   Engine category 

Legislation to 
comply with 

Comment 

SI engines  

All SI engines 

RCD Stage I  

CI engines  

 PN > 37kW 

NRMM Stage IIIA23 

Limits  of  4-stroke  SI  engines 
applicable for all engines 

Limits for propulsion engines of 
inland waterway vessels 

PN < 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  

PN < 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  

 PN > 30kW 

RCD Stage I  

75%  of  HC+NOx  limits  of  4-
stroke SI engines  

PN < 30kW and 
PWC engines  

RCD Stage I  

CI engines  

PN < 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 

23 

   EN 

 
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
                                                 
Scenario 4  

SI engines  

 PN > 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 engines 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 costs and possible job losses would outweigh the 
reduction of the exhaust emissions. Annex VI provides a detailed comparison of the scenarios.  

Following  this  analysis,  the  scenario  5  seems  to  be  the  most  suitable  scenario  for  further 
evaluation. Consequently, this scenario is considered in the Impact Assessment as option 2.  

Option 3 - Stricter exhaust emission limits (Stage 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.  Therefore,  option  3  was  developed  to  look  into 
different  possibilities  to  tighten  the  rules  for  exhaust  emissions  while  at  the  same  time 
including a mitigating measure to limit negative economic and social impacts. The option 3 is 
divided into sub-options according to the type of mitigating measures used. 

EN 

24 

   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 enshrined in Article 4 of Directive 97/68/EC24  on the emission of 
gaseous and particulate pollutants from engines to be installed in non-road mobile machinery 
(NRMM). Under this directive a CI engine manufacturer may place on the market, on request 
by an equipment manufacturer and when permission 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 stage of emission limits." The idea for the RCD is 
to  allow  the  engine  manufacturers  to  place  on  the  market  a  limited  number  of  recreational 
marine engines compliant with the previous stage 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  manufacturers  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  traded  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 due 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 Directive where it was rejected because of its 
incompatibility with the EU legislative and administrative system. 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 decrease the cost of compliance with new emission 
limit values. 

Sub-option 3.2 – Use of a transitional period 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 proposed as an alternative mitigating measure   to 
grant additional lead time to all engine manufacturers before their engines shall comply with 
the new emission standards. It gives the companies more time to redesign the engines and to 
adapt  the  production  lines  to  the  new  technologies.  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  years)  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 

25 

   EN 

 
                                                 
Option 2 – Stricter noise emission limits   

This option looks into the introduction of stricter noise limits for engines on the EU level and 
how these would contribute to the abatement of noise produced by recreational craft. 

5.2.3 Alignment of the RCD with the 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  brought  in  line  with  the  principles  of  New 
Legislative  Framework.  It  means  basically  the  inclusion  of  the  chapters  describing  the 
obligations  of  economic  operators,  the  competences  of  conformity  assessment  bodies  and 
market  surveillance  authorities,  new  conformity  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 option: environmental and trade concerns. Firstly, 
it has been demonstrated in Section 3.1.1.1 (see Table 1) that NOx concentrations do exceed 
the  environmental  quality  standards  in  coast  marinas.  Secondly,  if  the  current  limits  would 
continue  to  apply,  the  engine  manufacturers  and  especially  marinisers  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  regional  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 technological progress of 
the  recreational  marine  engines  as  well  as  the  EU  commitment  to  support  less  polluting 
technologies  and  the  alignment  of  the  limit  levels  internationally.  The  option  would  also 
prevent  a  fragmentation  of  the  Internal  Market  because  the  restricting  of  the  limits  would 
satisfy  those  Member  States  who  would  intend  to  introduce  various  restrictive  measures 
aiming at reducing emissions from recreational crafts.  

Environmental impact 

In order to assess the environmental impacts a formulaic approach 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 certification costs to the increased price of 
the cleaner engine.   

EN 

26 

   EN 

 
                                                 
For  the  purpose  of  modelling  air  quality,  it  has  been  assumed  that  all  emissions  from 
recreational craft exhausts enter the air. The assessment does not consider the impact of so-
called wet exhaust emissions to the water because only a marginal proportion of the exhaust 
pollutants remain in the water. 

Table 8: Total emissions change measured in tons per year 

Option 1 - No change of the limits 

Option 2 - Stage II 

HC+NOx 
(tons/year) 

PM 
(tons/year)  

CO 
(tons/year) 

40 907 

30 061 

539 

296 

153 142 

184 634 

Source: ARCADIS Complementary Impact Assessment Study July 2008, p.57 

According to the findings of the adopted approach the yearly emissions of HC+NOx, PM for 
Stage II are lower than for the baseline 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  developed  for  the  CAFE  Programme  (2005)27  have  been  used. 
Environmental  benefits  are  expressed  as  monetized  damage  savings  per  tonne  of  the  air 
pollutant. The methodology of monetization is described in Annex IX. 

For  calculation  purposes  we  assume  the  NOx  emissions  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 
27 
28 

Detailed calculation of the emission reductions available in Annex VIII 
http://www.cafe-cba.org/assets/marginal_damage_03-05.pdf. 
Source: ARCADIS Complementary Impact Assessment Study July 2008, page 57 

EN 

27 

   EN 

 
  
  
 
 
 
 
 
 
 
                                                 
Economic impact 

Compliance costs are purely related to costs incurred 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 learn over time to produce the engines 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 costs 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 (PN < 75kW). The higher costs indicated in Table 11 relate to engine 
manufacturers  which  serve  only  the  EU  market  and  have  no  exports  to  the  US  including 
indirect  ones  via  boats  in  which  their  marinised  engines  are  mounted.  Small  and  medium 
sized  engine  manufacturers  may  face  the  temporary  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 calculation of compliance costs are provided in Annex X. 

It has to be noticed that the 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 standards 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 market already. Their fixed costs will be limited to 
re-certification  and  related  testing  and  calibration.29  The  situation  is  however  different  for 
those  companies  which  supply  only  the  EU  market  which  have  to  bear  the  full  compliance 
costs. These are mainly SMEs. 

Option  2  (Stage  II)  would  be  effective  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  for  SMEs  as  they  would  be  unable  to  comply 
timely with the new exhaust emission limits.  

29 

These are common for CI and SI engine manufacturers.  They can reach up to 19 900€. The table in 
Annex X provides the details. 

EN 

28 

   EN 

 
 
                                                 
Indeed  SMEs  do  not  have  the  same  liquidity  and  access  to  finance  as  bigger  companies  to 
finance these investments. Hence they supply a limited market they will not be able to spread 
fixed costs over a larger production and use economies of scale, as bigger manufacturers can. 
The  SME  engine  manufactures  also  do  not  benefit  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  high,  companies  are  likely  to  discontinue  the 
production of certain models. Discontinuing product ranges is often very costly, especially if 
products have not reached the end of their lifetime 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.  Recreational  craft  engine 
manufacturers generally keep a wider range of power categories of engines. 

The  stakeholders’  consultations  revealed  that  SME  SI  engine  manufacturers  producing  low 
power engines will have the highest difficulties to comply with the new Stage II limits due to 
their limited R&D capacity to redesign the engines. Low power SI outboard engines (i.e. PN < 
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  provided  in  the  current  RCD  aim  at  avoiding  any 
serious risk of expose for the boat user and other persons. Even 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  craft  may  be  reflected 
upon in a future revision.  

Keeping CO emission limit values at the current 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  technology  which  is  not  yet  technically  feasible  in  the  marine 
environment.  The  development  of  catalyst  outboard  program  would  likely  require  2-3  year 
completing and converting all outboard engine categories to catalyst technology is likely take 
8-9  years32.  The  costs  of  redesigning  an  engine  family  can  run  up  to  30  million  €  which 

30 
31 
on competitiveness of large and small companies described in Annex XII 

That is small and medium sized engine manufacturers producing low power engines  
Based on consultation results. ARCADIS Impact Assessment Study (2008), p. 90-93. Details of impact 

32 
Utilizing Catalyst Technology , Mercury Marine,  CARB Technical Seminar, 2010 

Source:  Development  and  Demonstration  of  a  Low  Emission  Four-Stroke  Outboard  Marine  Engine 

EN 

29 

   EN 

 
                                                 
represents  10–25  %  of  EU  annual  sales  of  a  large  outboard  engine  manufacturer  in  this 
particular  engine  category.  The  costs  may  be  especially  critical  for  some  solely  EU  based 
small and medium sized SI engine 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  seriously  hit  by  the  economic  and  financial  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 negative economic/social impacts.  

Sub-option 3.1 – Use of a flexibility scheme 

In  this  sub-option,  the  mitigating  measure  considered  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  legislation  (see  under  5.2.1.),  the  objective  is  to  allow  companies  to 
optimise their strategy for complying with the required new emission standards and the reach 
the same absolute level of emission 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 Option 2 (Stage II), which is demonstrated in 
the tables below.  

Table 12: Total emissions change measured in tons per year 

Option 1 - No change 

Sub-option 3.1 - Stage II + Flexibility scheme 

HC+NOx 
(tons/year) 

PM 
(tons/year)  

CO 
(tons/year) 

40 907 

31 105 

539 

387 

153 142 

180 698 

Source: ARCADIS Complementary Impact Assessment Study July 2008, Table 5.5, page 57 
Table 13: Average percentage change / year compared to Option 1 36 

Sub-option 3.1 - Stage II + Flexibility scheme 

-23,96% 

-28,20% 

+17,99% 

HC + NOx 

PM 

CO 

33 
34 
35 

36 

Source: The Complementary Impact Assessment Study, ARCADIS (2008) 
Source: Information provided by ICOMIA 
According to the available information there is just one company actually relying on the ABT system; 
other engine manufacturers  consider the administrative costs involved too high. 
Detailed calculation of the exhaust emission reductions is provided in Annex VIII. 

EN 

30 

   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 the market of more polluting engines. 

Furthermore the objective of the flexibility scheme 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  last  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 limited period, which may result in a substantial 
increase  of  costs.  The  possibility  to  use  a  limited  number  of  previous  stage  engines  allows 
balancing this peak in investment costs.   

This scheme can however not be directly transposed 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 manufacturer and not to the boat 
producer.  

While in case of NRMM the OEM will only use the flexibility scheme when it is needed to 
overcome  a  momentary  period  of  peak  R&D  investments,  the  engine  manufacturers  in  the 
case of recreational craft would be tempted to fully 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 

31 

   EN 

 
 
 
 
 
 
 
                                                 
economically needed. This measure would disqualify its mitigating effect for the companies 
in  serious  economic  troubles  and  would  result  in  an  indirect  postponement  of  the 
implementation date of the new Stage of exhaust emission limits. 

Other  problems  could  also  rise  from  the  implementation  of  the  flexibility  scheme.  In  the 
framework  of  the  NRMM  Directive,  the  flexibility  scheme  is  managed  by  the  established 
national  approval  authorities.  It  would  be  necessary  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 administrative procedure. The administrative burden 
could be substantial for SMEs, as the latter may incur 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  flexibility  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  possibilities  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 transitional period of 3 years to all engine manufacturers 
so that they have enough time to adapt to the new rules. The transitional period reflects the 
time  when  the  exhaust  emission  limits  will  become  fully  applicable  in  the  US  so  the 
production of majority of engine 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 change / year compared to Option 138 

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 

HC + NOx 

PM 

CO 

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 

32 

   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 decrease of PM than the 
flexibility scheme (presented in Sub-option 3.1). These results are given assuming that during 
the  3-year  transitional  time,  the  possibility  to  continue  placing  on  the  market  the  engines 
compliant with the previous stage of emissions will 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 problems to have all their engines 
certified  on  time  unless  they  are  allowed  specific  additional  lead  time.  Such  a  specific 
measure  would  therefore  help  to  limit  and  spread  out  the  compliance  costs,  i.e.  guarantee  a 
better scheduling of investments rather than having 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 manufacturers 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 costs will be probably lower as the majority of 
engine  manufacturers  will  have  spent  the  R&D  costs  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  period  for  all  engine  manufacturers  +  a  specific 
transitional  period  for  small  and  medium  sized  engine  manufacturers  placing  on  the  EU 
market the SI outboard engines ≤ 15 kW (3+3 years). 

For  a  very  limited  number  of  small  and  medium  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 Annex XIV, it is recommended to add an 
additional SME specific mitigating measure. One SME that would be eligible for this measure 
has been identified during the stakeholder’s consultation although a few others may also exist.   

39 

Commission Recommendation on the definition of SMEs , OJ, L124, 20.5.2003 , p.36 

EN 

33 

   EN 

 
 
                                                 
Environmental impact 

The  mitigating  measure  as  proposed  in  this  option  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  tons/year  of  HC+NOx  emissions  more  comparing  to  Sub-option 
3.2.  It  would  represent  0,015  %  of  the  total  annual  HC+NOx  emissions  from  recreational 
craft. This figure does not make a real difference in the overall annual exhaust emissions from 
the recreational marine engines. The PM emissions 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 granted to those small and medium sized engine manufacturers who 
place  on  the  EU  market  the  low  power  SI  outboard  engines.  Contrary  to  a  complete 
exemption from the Stage II for SME SI engine 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  disproportionate  competitive  advantage.  The  proposed 
additional transitional period gives a limited number of companies 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  period  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  medium  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  European  market  and  do  not  have  a  chance  to 
increase  their  production  capacity  and  consequently  their  market  share  due  to  the  limited 
capacity  to  invest.  The  proposed  mitigating  measure  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 specific time granted to SMEs did not receive any 
objection from stakeholders. 

Final comparison of the options  

Table 19: Comparison of the environmental impact 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 
scenario 

I.  –  Baseline 

0% 

0% 

0% 

EN 

34 

   EN 

 
  
Option 2 – Stage II of the limits 

-26,51% 

-45,08% 

20,56% 

Sub-option  3.1  –  Stage 
Flexibility scheme 

II  + 

-23,96% 

-28,20% 

17,99% 

Sub-option  3.2  –  Stage 
Transitional period 

II  + 

Sub-option  3.3  –  Stage 
II  + 
Transitional  period  +  Specific  time 
for SI engine SMEs 

-19,88% 

-33,81% 

15,42% 

-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  that  the  overall  damage  savings  would  be  even 
higher if the savings of HC emissions are included.  

Table 20: Comparison of environmental benefit / 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 

Sub-option  3.3  –  Stage  II  + 
Transitional  period  +  Specific 
derogation for SI engine SMEs 

7,1 M€ - 34,2 M€  2,4 M€ - 13,7 M€ 

2 M€ - 8 M€  

1,8 M€ - 5 M€ 

7,1 M€ - 34,1 M€  2,4 M€ - 13,7 M€ 

2 M€ - 8 M€  

1,8 M€ - 5 M€ 

EN 

35 

   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  recreational  craft  sector.  The  administrative  costs  for  national  market 
surveillance authorities which would 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  savings  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) 

Option 2 – Stage II of the limits 

Net benefit (M€) 

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  entail  a  price  effect 
(price  increase)  and  could  also  generate  a  disruption  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  craft  industry  to  amount  to  approximately  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  elasticity  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 generate too low profit to invest money to make 
them compliant with the new limits. Such a discontinuation is probable for Option 2 and Sub-
option 3.1. Job losses in marketing and sales positions 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 

36 

   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 costs will arise in this sub-option, they will be 
spread  over  a  longer  period  of  time.  Therefore,  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 period of time. This will allow the manufacturers to reduce 
the price increase to a minimum, and to keep their 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 period 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 social 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  secondly  they  provide  the  common 
legislative  framework  for  the  engine  manufacturers  operating  within  the  EU  market  and 
thirdly  ensure 
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 sector, the Sub-option 3.3 meets the best designed objectives.  

the  alignment  of  engine  emission 

requirements  with 

Sub-option 3.3 is the most efficient compromise for SMEs in terms 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  option  with  the  baseline 
scenario  and  with  the  EQS.  The  preferred  option  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 

Preferred option 
(µg/m3) 

NOx long term   

NOx short term 

PM long term   

EN 

40 

200 

40 

37 

 (µg/m3) 

17,54 

599,47 

0,26 

14,07 

480,89 

0,17 

   EN 

 
 
 
PM short term 

CO long term   

CO short term 

50 

350 

0,59 

231,26 

0,39 

266,78 

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 

Preferred option 
(µg/m3) 

NOx long term   

NOx short term  

PM long term   

PM short term 

CO long term   

CO short term 

40 

200 

40 

50 

350 

 (µg/m3) 

13,17 

213,97 

0,27 

0,56 

10,56 

171,65 

0,18 

0,37 

137,98 

159,17 

10 000 

1 121,75 

1 294,05 

Table 25: Estimated concentrations of selected pollutants for Inland Waterways 
EQS (µg/m3) 

Pollutant   

Current situation 
baseline 

Preferred option 
(µg/m3) 

NOx long term   

NOx short term 

PM long term   

PM short term 

CO long term   

CO short term 

40 

200 

40 

50 

350 

 (µg/m3) 

0,16 

2,5 

0 

0,02 

3,73 

0,13 

2,01 

0 

0,01 

4,30 

10 000 

29,64 

34,19 

6.2 Impact of the noise emissions limits for engines  

Option 1: Impact of no policy change 

The  current  noise  limits  for  recreational  craft  would  remain  as  provided  by  the  amendment 
Directive 2003/44/EC. They were harmonised to ease the functioning of the internal market.  

EN 

38 

   EN 

 
 
 
 
 
 
Table 26: Current noise emission limits in the RCD 

Rated engine power 
(kW) 

PN ≤ 10 

10 < PN ≤ 40 

PN > 40 

Maximum sound pressure 

 Level = LpASmax (dB) 

67 

72 

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 specifically 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  restriction  restricted  use  of  the  craft  at  certain 
hours  seem  to  be  more  effective  measure  for  further  reducing  noise.  Table  27  shows  that 
speed  limits  or  restricted  use  at  certain  hours  could  be  a  more  effective  solution  than  a 
requirement for all boats or engines to meet severe standards. 

Table 27: Estimated environmental sound impact for some typical cases, expressed in dB41  

Low Intensity 

High intensity 

Situation 

Intensity  (number 
of hours) 

Sound 
(dB) 

Impact 

Intensity  (number 
of hours) 

Sound 
(dB) 

Impact 

Canal (50 m) 

15 

Lake (200m) 

Boats 

PWC 

Marina (200m) 

Boats 

Passing (25 m) 

Boats 

PWC 

10 

0.2 

1 

2 

2 

43 

50 

42 

40 

38 

45 

45 

40 

0.8 

7 

20 

20 

Source: Stocktaking Study, TNO (2004) 

These levels should be compared against following target values:  

47 

56 

48 

49 

48 

55 

41 

Assumptions for measurement of environmental noise impact settled in Annex XII 

EN 

39 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
                                                 
Table 28: The permissible levels differentiated for different types of areas and their use 

Area concerned 

Residential Area 

Recreational Area 

Park / Nature Conservation Area 

Source: Stocktaking Study, TNO (2004) 

Target value (in dB) 

55 

40-60 

30-40 

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 environmental 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 conservation areas it is clearly too 
high. In those  cases additional measures  such as speed limits and restrictions 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 limits 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-made, measures, this could lead to trade distortion or barriers to trade 
within the EU, or measures having an equivalent effect to a quantitative 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 noise 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 boat does not entirely result from the engine's noise emissions but 
rather,  they  are  a  result  of  a  combination  of  factors  (use/speed  of  the  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 engines, 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 subjective and personal aspects such as the feeling about the type of 
source  and  the  usefulness  of  the  source  and  its  use.  The  use  of  a  recreational  craft  can 
therefore be just as important as the sound emission of that craft; and even the sound emission 

EN 

40 

   EN 

 
of the craft is determined largely by its user. In addition, several studies have shown that the 
perceived annoyance is not based on the sound levels 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 reduction for the overall craft when decreasing the 
noise emissions from the engines.  

Table 29: Overall sound reductions that can be obtained from reducing noise from engines  

Sound reduction of the engine 

Type of engine  

(in dB) 

Outboard PN > 40 kW 

-6 / -8 

Outboard 10 < PN < 40 kW 

-4 / -5 

Outboard PN < 10 kW 

-4 / -5 

PWC PN > 40kW 

-4 

-3 

Source: Stocktaking Study, TNO (2004) 

Total  craft’s  sound  reduction 
obtained (in dB) 

-3 

-3 

-3 

-3 

-2 / -1 

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  engines  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 federal level related to 
noise of recreational crafts in the US. California as the state with the highest concentration of 
recreational crafts specifies a single limit of 75 dB for all engine power categories whereas the 
EU requires tougher limits for smaller power ranges. Thus, a more severe limit value of EU 
noise limits would disalign the rules with the US.  

Despite positive reactions from some Member States on legislative restriction of noise limits, 
the  option  is  strongly  opposed  by  the  industry.  The  letter  points  out  the  findings  of  TNO 
Study  2004  and  underlines  in  particular  the  limited  environmental  benefit  entailed  by  the 

42 

Stocktaking Study, TNO (2004), p. 67 

EN 

41 

   EN 

 
                                                 
introduction  of  stricter  noise  emission  limits,  the  importance  of  the  changes  necessary  to 
achieve a small emission reduction and the costs entailed by such changes. 

This  leads  to  the  conclusion  that  current  noise  limits  are  necessary  to  guarantee  the 
functioning of the internal 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  codify  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  positive,  since  the  horizontal  provisions  clarify 
certain issues43 which are uncertain for the moment. Legal certainty will be beneficial for all 
parties:  economic  operators,  national  and  European  Union  administration  as  well  as 
consumers. Certain new obligations set for economic 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 compliance of the product. However, these impacts should be largely 
overweighed  by  the  benefits  stemming  from  these  provisions  for  consumers  in  terms  of 
increased safety of recreational craft and for national administrations in terms of reduced costs 
following clearer new rules on responsibilities 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 appointed or withdrawn 
from  the  list  of  the  bodies  notified  to  make  a  conformity  assessment  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  certification  requirements  in  the  EU  and  the  US.  The 
preferred  option  is  based  on  aligning  the  rules  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 

44 

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. 
The  impact  of  the  alignment  with  the  NLF  is  closely  evaluated  in  the  Omnibus  Impact  Assessment 
(COM 
     proposal aligning several directives to the NLF at the same time).      

EN 

42 

   EN 

 
                                                 
The Commission will be able to detect any problems 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 contain at least the following elements  

• 

• 

• 

• 

an evaluation of the situation concerning the safety of products  

an evaluation of the effectiveness of the RCD  

effectiveness of tracking non-compliant products 

effectiveness  of  stricter  exhaust  emission  limits  through  air  pollution 
measurement in marine/lake/inland waterway areas. 

The Commission will provide a guidance document to the Member States on key monitoring 
indicators.  The  Commission  services  will  evaluate  national  reports  and  publish  a  summary 
report 

There is also a reporting obligation on market surveillance 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 functioning of the RCD.  

The  new  information  exchange  systems  provided  by  Art.  23  of  Regulation 
765/08/EC framework will allow the Commission to monitor the effectiveness of the 
RCD.  

The  group  of  notified  bodies  (RSG),  organizes  one  plenary  session  and  two  sub-
groups per year. It coordinates the common application of the conformity assessment 
rules  and  issues  Recommendations  for  use  (RFU),  the  number  of  which  provides  a 
good indicator on the possible need for clarification and application of the RCD. 

Requests  &  remarks  received  by  the  Commission  from  the  public  will  help  to 
monitor the eventual infringements of the internal market.  

All  important  information  about  the  functioning  of  the  RCD  is  published  on  a 
dedicated  CIRCA  website  which  can  be  consulted  by  Member  States,  professional 
associations and NGOs.  

EN 

43 

   EN 

 
Glossary 

2s   
4s  
ABT  
CARB   
CI  
CO  
DI  
DIY  
EEA 
EFI  
EPA  
EUROMOT  
EQS  
GHG    
HC  
IB  
IMEC   

Mariniser  

NLF  
NOx  
NO 
NO2 
NRMM  
OB  
OEM    
PM  
PWC    
RCD    
R&D    
SI  
SME    
SOER 2010 
SOx  
TA  
TFEU   
UN-ECE  

2-stroke 
4-stroke 
Averaging, Banking and Trading System (flexibility system in the US) 
California Air Resources Board 
Compression ignition (diesel) engine 
Carbon Monoxide (emission component) 
Direct Injection 
Do it yourself 
European Environment Agency 
Electronic fuel injection 
United States Environmental Protection Agency 
European Association of Internal Combustion Engine Manufacturers 
Environmental Quality Standard 
Green House Gas Emissions 
Hydrocarbons (emission component) 
Inboard Engine 
International Council  of  Marine Industry Associations' Marine  Engine 
Committee 
a  company  which  purchases  engines  from  the  engine  manufacturer 
producing engines for different applications (automotive, non-road use) 
and convert or adapt them for marine use 
New Legislative Framework 
Oxides of Nitrogen (emission component) 
Nitric Oxide 
Nitrogen Dioxide 
Non-Road Mobile Machinery 
Outboard Engine 
Original equipment manufacturer 
Particulate Matter (solid emission pollutant) 
Personal Watercraft 
Recreational Craft Directive, 94/25/EC 
Research and Development 
Spark ignition (petrol) engine 
Small and medium enterprise 
The European environment – state and outlook 2010 
Oxides of Sulphur (emission component) 
Type Approval 
Treaty of Functioning of the European Union 
Economic Commission for Europe of the United Nations 

EN 

44 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
ANNEX I: Overview of recreational craft and engines for recreational craft sector  

Economic importance of the recreational craft sector per country (2004) 

Country  

GDP €  

Employment 

Austria 

Belgium 

Bulgaria 

Croatia 

Cyprus  

TOTAL  

Recreational craft 
sector contribution 

Total labour 
force 

Recreational craft 
sector employees

214.000.000 

55.000 

0,03%

4.300.000 

960 

0,02%

279.000.000 

55.000 

0,02%

4.440.000 

940 

0,02%

12.100.000 

14.000 

0,12%

3.830.000 

440 

0,01%

16.900.000 

153.000 

0,91%

1.700.000 

3.470 

0,20%

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 

324.000 

0,18%

2.860.000 

5.290 

0,18%

Estonia  

Finland 

France 

5.220.000 

13.000 

0,25%

609.000 

470 

0,08%

139.000.000 

386.000 

0,28%

2.600.000 

6.750 

0,26%

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  

Hungary 

Ireland  

Italy  

Latvia 

150.000.000 

225.000 

0,15%

4.370.000 

4.270 

0,10%

68.300.000 

8.000 

0,01%

4.200.000 

280 

0,01%

121.000.000 

123.000 

0,10%

1.800.000 

2.850 

0,16%

1.230.000.000 

2.920.000  0,24% 23.600.000 

92.000 

0,39%

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 

Poland  

Portugal  

Romania  

169.000.000 

525.000 

0,31%

2.400.000 

6.600 

0,28%

162.000.000 

106.000 

0,07% 17.600.000 

2.910 

0,02%

124.000.000 

128.000 

0,10%

5.100.000 

2.480 

0,05%

44.900.000 

10.000 

0,02%

9.900.000 

330 

0,00%

EN 

45 

   EN 

 
 
  
Slovakia  

Slovenia  

Spain  

Sweden  

28.500.000 

1.000 

0,00%

3.000.000 

65 

0,00%

18.300.000 

32.000 

0,17%

857.000 

716 

0,08%

665.000.000 

487.000 

0,07% 17.100.000 

9.020 

0,05%

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 

UK 

219.000.000 

152.000 

0,07% 23.800.000 

5.370 

0,02%

1.440.000.000 

1.490.000  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 

Finland 

France 

Germany 

Greece 

Ireland 

Italy 

Netherlands 

Portugal 

Spain 

Sweden 

UK 

30 

58 

156 

412 

87 

4 

800 

450 

55 

25 

50 

500 

2 627 

1 

0 

7 

11 

0 

0 

10 

1 

0 

3 

3 

5 

41 

EN 

46 

   EN 

 
 
 
 
 
 
 
 
  
 
 
 
Croatia 

Norway 

Switzerland 

Turkey 

65 

95 

18 

300 

478 

1 

2 

7 

0 

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 manufacture 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  manufacturers  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 

Recreational marine engines  in the EU

86%

shaftdrive diesel
9%

inboard

2,5%

sterndrive diesel

2%

sterndrive 
petrol

outboard

Source: Stocktaking Study: TNO (2004)  

EN 

47 

   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  engines  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 diesel 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  only  represent  only  7,  5%  of  worldwide  sales 
(approximately 10 000 units per year in Europe 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  and  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 

48 

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ANNEX  II:  Public  consultation  on  a  possible  approach  to  revision  of  the  RCD, 
summary of responses 

1. 

Introduction 

The  European  Commission  launched  an  open  public  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  Craft  Directive  have  been  identified  in  close 
consultation with stakeholders. They address the needs for: 

1.  further  improving  the  environmental  performance  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 Directive which are not covered by previous 

two points. 

The main objective of this public consultation was to ask citizens and stakeholders for their 
views and opinions on the various issues that might 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 identified 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  were  sent  on  behalf  of  an  organisation  or 
institution, 9 by enterprises and 7 by individual citizens. 

Most  of  the  contributions  sent  by  organisations  were  from  public  authorities.  However, 
industrial organisations, notified bodies and non-governmental organisations also made their 
voices heard. Boat manufacturers and SMEs in particular 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  performance  of  recreational  marine  engines: 

need for further reducing emissions of air pollutants 

About 65 % of respondents agreed with the approach of further reducing the exhaust emission 
limits  for  recreational  marine  engines,  provided  sufficient  attention  is  paid  to  mitigating 
measures  for  small  and  medium-sized  enterprises,  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,  there  is  also  strong 
support  for  exempting  SMEs  from  complying  with  any  new  limits,  especially  amongst 
enterprises  and  citizens.  By  contrast,  19 %  of  the  respondents,  in  particular  institutions, 
disagreed with mitigating measures for SMEs. 

EN 

49 

   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  performance  of  recreational  marine  engines: 

need for further reducing noise 

The  idea  of  regulating  noise  from  recreational  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 among 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 specially 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 partly 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  exempted  from  the  Directive  as  this  would  create 
confusion  and  leave  room  for  possibly  side-stepping  the  system.  Objections  were  raised 
against exempting craft intended to carry passengers for commercial purposes, but such craft 
are regulated by other EC legislation.  

The  discussion  about  the  status  of  amphibious  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  strongly  support  clearly  defining  the 
obligations  of  economic  operators.  There  were  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  defining  the  obligations  of  each  link  in  the 
economic chain, whereas manufacturers and citizens 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  been  using  the  various  conformity  assessment 
modules before they are introduced in the new legal framework. The choice of those modules 
seems to be adequate and sufficient in the view of the vast majority of the respondents. 

EN 

50 

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9.  Post-construction assessment procedure 

Post-construction  assessment  (PCA)  is  a  special  conformity  assessment  procedure  used 
preferably  by  importers  when  neither  the  manufacturer  nor  the  manufacturer’s  authorised 
representative takes  responsibility 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 widening the scope of the PCA to other products 
differ  between  stakeholders.  There  are  equal  numbers  of  supporters  and  opponents. 
Institutions  support  the  idea  that  post-construction  assessment  should  apply  to  all  products 
covered by the Directive. By contrast, some manufacturers 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  market  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 preventive measures and enhanced cooperation between 
market  surveillance  authorities  and  customs  authorities  are  the  most  powerful  tools. 
Institutions  are  in  favour  of  tighter  controls  at  borders  and  even  obligatory  registration  of 
boats, whereas manufacturers and citizens prefer 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 

o 

Revision of the wave height of design categories is needed, as it appears inadequate for 
some categories. 

Partly  completed  boats  should  be  accompanied  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 

51 

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ANNEX III: Schematic representation of different drive principles for boat engines  

Types of engines involved in the motorboats and personal watercraft are: 

(cid:153)  Spark-ignition [SI] engines (called also petrol engines)  

Outboard engines 

(cid:190)  Inboard (stern-drive) engines 
(cid:190)  Inboard (shaft-drive) engines 
(cid:190)  PWC engines - used in the personal watercrafts 

(cid:153)  Compression-ignition [CI] engines (called also diesel engines) 

Inboard (stern-drive) engines 

(cid:190)  Inboard (shaft-drive) engines 

EN 

52 

   EN 

 
 
 
 
 
 
 
 
ANNEX IV:  Annual average air concentrations in Europe - affected locations   

Annual average PM air concentrations  

EN 

53 

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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) 

Type 

Carbon monoxide 
n  

CO = A + B/PN

Hydrocarbons 
n 
HC = A + B/ PN

A 

B 

n 

A 

B 

n 

Nitrogen 
oxides 

NOx  

Particulates 

PT  

Two-stroke 
spark ignition 

Four-stroke 
spark ignition 

Compression 
ignition 

150,0  600,0  1,0

30,0 

100,0 

0,75 

10,0 

150,0  600,0  1,0

6,0 

50,0 

0,75 

15,0 

Not 
applicable 

Not 
applicable 

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, PN is the rated engine power in kW.  

US EPA standards for marine CI engines (CFR 40 Part 1042) 

Maximum 
Engine Power 

L/cylinder 

<19 kW 

19 to <75 kW 

<0,9 

<0,9a 

PM 
g/bhp-hr 

(g/kW-hr) 

NOx + HC 

g/bhp-hr 

(g/kW-hr) 

0,30   (0,40) 

5,6 (7,5) 

0,22   (0,30) 

5,6 (7,5) 

0,22   (0,30)b 

3,5 (4,7)b 

75 to <3700 kW 

<0,9 

0,11   (0,15) 

4,3 (5,8) 

0,9-<1,2 

0,10   (0,14) 

4,3 (5,8) 

1,2-<2,5 

0,09   (0,12) 

4,3 (5,8) 

2,5-<3,5 

0,09   (0,12) 

4,3 (5,8) 

3,5-<7,0 

0,08   (0,11) 

4,3 (5,8) 

Applicable  for 
model year 

2009 

2009 

2014 

2012 

2013 

2014 

2013 

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) NO

-HC in 2014 
X

EN 

54 

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US EPA standards for marine SI engines (CFR 40 Part 1045) 

Type of engine  Rated Engine 

Power 

PN 

 (kW) 

Carbon 
monoxide 

Hydrocarbons + 
Nitrogen Oxides 

CO 

HC + NOX 

Applicable 
for model 
year 

Stern-drive and 
inboard engines 

PN ≤ 373 

373 < PN ≤ 485 

PN > 485 

 (g/kWh) 

75 

350 

350 

Outboard 
engines and 
PWC engines 

PN ≤ 4,3 

500 – 5,0 x PN 

40 > PN > 4,3 

500 – 5,0 x PN 

PN >.40  

300 

 (g/kWh) 

5 

16 

22 

30 

7,15

+

7,15

+

⎛
⎜
⎜
⎝

⎛
⎜
⎜
⎝

50
PN

9.0

50
PN

9.0

⎞
⎟
⎟
⎠

⎞
⎟
⎟
⎠

2010 

The US EPA rules include a couple of mitigating 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 provisions and hardship relief provisions). 

Comparison of the exhaust emissions limits in the EU and the US for CI engines 

Power (PN) 

Particulates (PM)  

Hydrocarbons + Nitrogen 
Oxides (HC + NOX) 

(kW) 

PN < 37 

37 ≤ PN <75 

75 ≤ PN < 3700 

EU 

US 

EU 

US 

(g/kWh) 

1 

0,3 

0,15 

11,4 

11,3 

11,3 

11,4 

4,7 

5,8 

1 

1 

1 

EN 

55 

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PN < 3700 

1 

0,14 

0,12 

0,12 

0,11 

11,3 

5,8 

5,8 

5,8 

5,8 

Limits for non road mobile machinery CI engines - Stage IIIA 

Swept Volume SV 

 (L/cyl) 

SV < 0,9  

0,9 ≤ SV < 1,2  

PN 

(kW) 

P ≥ 37 

1,2 ≤ SV < 2,5  

 37 ≤ P < 75  

2,5 ≤ SV < 5  

 5 ≤ SV < 15  

15 ≤ SV < 20  

20 ≤ SV < 25  

25 ≤ SV < 30  

PM 

HC+NOx 

(g/kWh) 

(g/kWh) 

0,4 

0,3 

0,2 

0,2 

0,27 

0,5 

0,5 

0,5 

7,5 

7,2 

7,2 

7,2 

7,8 

9,8 

9,8 

11 

EN 

56 

   EN 

 
 
 
 
 
 
 
 
 
 
 
 
Development of the exhaust emission limits applying to engines of power ratings (5kW 
and 40kW) in the EU and the US 

)
h
W
k

/

g
(

x
O
N
+
C
H

200

180

160

140

120

100

80

60

40

20

0

5 kW

40 kW

EPA 2001 EPA 2006

RCD SI 2s

/ CARB
Tier1

CARB
Tier2

Regulation

RCD SI 4s EPA 2008

/ CARB
Tier3 

EPA 2008
/ CARB
Tier4 

The following conclusions were drawn from this figure in the report: 

(1) 

(2) 

(3) 

(4) 

(5) 

Current EU Stage I. (amendment of the RCD 2003/44/EC) requirements for 2-stroke 

engines are similar to the obsolete US EPA 2006 requirements  

Current EU Stage I 4-stroke requirements are between the CARB Tier 2 and Tier 3 

requirements  

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 

The  US  EPA  2008  requirements  (40  CFR,  part  1045)  for  SI  inboard  engines  are 

consistent with the requirements adopted by CARB Tier 4 

Proposed  EU  Stage  II  would  align  with  the  harmonised  US  EPA  2008  limits  and 

Californian CARB limits.  

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ANNEX VI:  Analysis of 5 different scenarios 

Scenarios assessed in ARCADIS Complementary 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  different  scenarios,  insight  is  provided  in  the 
sensitivity of the ranking of the scenarios. Finally, the environmental benefits are compared to 
the corresponding compliance costs. In this way, 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  versa,  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  calculating  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) 

(7) 

(8) 

Effectiveness – how well does each of the scenarios achieve the objectives (reducing 

exhaust emissions)? 

Efficiency – the level of resources needed to achieve the stated objectives (impacting 

technical, economic and social 

Consistency  –  the  balance,  trade-offs  and  synergies  of  positive  and  negative 

(un)intended (in)direct effects on economic, social and environmental systems  

In the following table the environmental and socio-economic impact of the various scenarios 
are presented through a number of synthetic indicators. The second 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 point of view. However, (social) cost-efficiency 
should also be considered, as the means by which  the environmental objectives are realised 
should  be  proportionate  to  the  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 emissions 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 study "Estimates of the 
marginal external costs of air pollution in Europe" 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+NOx emissions is split up between NOx and HC, 
we  only  rely  on  the  NOx  marginal  external  costs  as  a  proxy  for  the  social  benefits  of  the 
reduction in HC + NOx emissions.  

EN 

58 

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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. Scenario 5 realise emission reductions in a more cost-efficient way. The 
potential compliance costs and job losses per kiloton 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-effectiveness criteria. Industry pointed out that the higher socio-
economic  impacts  per  kiloton  reduction  for  the  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 

2 

3 

4 

5 

8,14 

12,65 

13,39 

9,39 

10,85 

0,09 

0,11 

0,11 

0,11 

0,24 

8,99 

6,75 

6,75 

23,75 

23,75 

13,63 

14,68 

14,68 

32,38 

32,38 

14,37 

12,44 

12,44 

29,59 

29,59 

10,37 

12,97 

12,97 

24,46 

24,46 

13,03 

0,83 

2,27 

1,93 

5,87 

Source: ARCADIS Complementary Impact Assessment Study (2008) 

EN 

59 

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ANNEX VII:  Methodology used for environmental impact analysis 

Initially,  fleet  composition  across  Europe  was  investigated,  including  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 situations. To quantify impacts, sensitive receptors such 
as  areas  of  conservation  and  residential  areas  were  modelled  in  the  scenario  building.  The 
engine  sizes,  types,  usage  and  distribution  within  the  fleet  were  used  to  calculate  the  total 
emissions  per  annum  arising  from  the  use  of  the  craft.  These  emissions  were  adjusted  by  a 
load factor to account for the fact that the engines 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 Environmental Part ECNI Study 2006 

The impacts relating to water quality were also considered in relation to quality standards and 
emissions. Although changes to the Recreational Craft Directive primarily limit emissions to 
air, there may be some benefit in reductions through pathways such as deposition and aqueous 
sources.  

EN 

60 

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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  the  available  numbers. 
Calculation  in  four-year  period  demonstrates  the  best  how  the  exhaust  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  percentage  reduction  calculated  for  4  years  is 
conforming to the percentage reduction calculated per one year. 

HC+NOx (Hydrocarbons+Nitrogen Oxides) 

Year 1 Year 2 Year 3  Year 4 

Tons / 4 
years 

Option 1 - Stage I 

Option 2 - Stage II 

40 907 40 907 40 907  40 907 

163 628

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

Option 2 - Stage II 

Sub-option 3.1 - Stage II + Flexibility scheme 

Sub-option 3.2 - Stage II + Transitional period 

Sub-option 3.3 - Stage II+Tran period+Spec time SI SMEs 

PT (Particulates) 

Year 1 Year 2 Year 3  Year 4 

Reduction 
compare 
to Opt. 1 

-26,51%

-23,96%

-19,88%

-19,87%

Tons / 4 
years 

Option 1 - Stage I 

539

539

539 

539 

2 156

EN 

61 

   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

Option 2 - Stage II 

Sub-option 3.1 - Stage II + Flexibility scheme 

Sub-option 3.2 - Stage II + Transitional period 

Sub-option 3.3 - Stage II+Tran period+Spec time SI SMEs 

CO (Carbon monoxide) 

Year 1 Year 2 Year 3  Year 4 

Reduction 
compare 
to Opt. 1 

-45,08%

-28,20%

-33,81%

-33,81%

Tons / 4 
years 

Option 1 - Stage I 

Option 2 - Stage II 

153142 153142 153142  153142 

612 568

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

Option 2 - Stage II 

Sub-option 3.1 - Stage II + Flexibility scheme 

Sub-option 3.2 - Stage II + Transitional period 

Sub-option 3.3 - Stage II+Tran period+Spec time SI SMEs 

Relaxation 
compare 
to Opt. 1 

20,56%

17,99%

15,42%

15,36%

EN 

62 

   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 surrounding sea areas under different sets of 
assumptions.  

Analysis follows the impact pathway methodology developed in the ExternE Project funded 
by EC DG Research. The pathway described 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 Assessment indicate the range of environmental 
benefits taking together results for all four methods. Environmental benefits are calculated for 
NOx and PM.  

Environmental  benefit  of  each  option  =  Amount  of  tonnes/year  of 
particular pollutant * Damage/tonne of particular pollutant 

Total emissions measured in tonnes per year produced by recreational crafts 

Option 1 - No change 

Option 2  

Sub-option 3.1  

Sub-option 3.2  

Sub-option 3.3 

NOx (tons/year) 

PM (tons/year)  

14 317 

10 521 

10 887 

11 470 

11 472 

539 

296 

387 

357 

357 

Source: ARCADIS Study, p. 54, the emissions of NOx measured as 35% of HC+NOx emissions 

EN 

63 

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Average damage savings / tonne of emissions per various air pollutants 

Measures 

Method 

Damage / tonne (€) 
NOx 

Damage / tonne (€) 
PM 

PM 
O3 
mortality, 
mortality,  Health  core, 
Health 
sensitivity, 
Crops, O3/health metric 

VOLY 
VOLY  median, 
median, 
Included,  Not 
included,  Included,  SOMO 
35 

PM 
O3 
mortality, 
mortality,  Health  core, 
Health 
sensitivity, 
Crops, O3/health metric 

median, 

VOLY 
VSL 
median, 
Included,  Not 
included,  Included,  SOMO 
35 

PM 
O3 
mortality, 
mortality,  Health  core, 
sensitivity, 
Health 
Crops, O3/health metric 

PM 
O3 
mortality, 
mortality,  Health  core, 
Health 
sensitivity, 
Crops, O3/health metric 

VOLY  mean,  VOLY  mean, 
Included, 
Included, 
Included, SOMO 0 

VSL  mean,  VOLY  mean, 
Included, 
Included, 
Included, SOMO 0 

PM 
O3 
mortality, 
mortality,  Health  core, 
Health 
sensitivity, 
Crops, O3/health metric 

VOLY 
VOLY  median, 
median, 
Included,  Not 
included,  Included,  SOMO 
35 

PM 
O3 
mortality, 
mortality,  Health  core, 
sensitivity, 
Health 
Crops, O3/health metric 

median, 

VOLY 
VSL 
median, 
Included,  Not 
included,  Included,  SOMO 
35 

PM 
O3 
mortality, 
mortality,  Health  core, 
Health 
sensitivity, 
Crops, O3/health metric 

PM 
O3 
mortality, 
mortality,  Health  core, 
Health 
sensitivity, 
Crops, O3/health metric 

VOLY  mean,  VOLY  mean, 
Included, 
Included, 
Included, SOMO 0 

VSL  mean,  VOLY  mean, 
Included, 
Included, 
Included, SOMO 0 

Inland 

4 400 

26 000 

6 600 

40 000 

8 200 

51 000 

12 000 

75 000 

Seas  

2 500 

13 000 

3 800 

19 000 

4 700 

25 000 

6 900 

36 000 

Source: Cost-Benefit Analysis of Air Quality Related 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 

64 

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ANNEX  X:  Methodology  and  assumptions  used  for  economic  impact  analysis, 
calculation of compliance costs  

Based  on  the  technologies  that  would  be  required  to  achieve  the  emission  limit  values,  the 
costs of bringing engines in compliance with the proposed environmental standards have been 
calculated for the selected basic scenario without flexibilities. Technical impacts linked to the 
application of the scenario are reflected in associated 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 currently 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 applicable its original application; 

Engine families and needs for simultaneous up-grading for the full engine range to 
continue component sharing; 

The  emission  reduction  technologies  already  available  for  the  engine  in  other 
applications; 

The production volumes between manufacturers 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  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 the first 
years after which they are fully amortized. 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 learn over time 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  development,  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 between 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 

65 

   EN 

 
testing,  the  upper  bound  a  situation  in  which  other  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 only serve the EU market and have no indirect 
exports  to  the  US  via  boats  in  which  their  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  the  majority  of  engine  manufacturers,  as  these 
costs have already been borne by road engine manufacturers.  

Variable costs  

Variable costs cover improved or added technology on every engine (after treatment systems, 
etc.). It usually includes costs on the material, the labour and the energy requirements. 

The unit variable costs per engine are ranged 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 

66 

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Unit costs per engine for CI engines 

Maximum 
Engine Power

L/cylinder

Units put on the market (1)

Fixed costs 
large 
manufacturers
/engine (2)

Fixed costs small 
manufacturers & 
marinisers/engine 
(3)

Variable 
costs/engine (4)

Costs linked to 
temporal 
discontinuation 
of engine 
models (5)

min max

min

max min

max

large 
manufactu
rers

small 
manufacturers 
& marinisers

<19 kW

<0.9

19 to <75 kW <0.9a

19-37

37-75

75 to <3700 kW <0.9

0.9-<1.2

1.2-<2.5

2.5-<3.5

3.5-<7.0

total

12.800

16.800

9.200

7.600

2.080

2.080

2.080

2.080
2.080

9.600

12.600

6.900

5.700

1.560

1.560

1.560

1.560
1.560

3.200      30 €    54 €         31 €           664 €        -   €        -   € 

4.200      30 €    54 €         31 €           664 €       14 €     384 € 

2.300      30 €   54 € 

      31 € 

        664 € 

    14 € 

  384 € 

1.900      30 €   54 € 

      31 € 

        664 € 

    14 € 

  384 € 

520      30 €    54 €         31 €           664 €       34 €       34 € 

520      30 €    54 €         31 €           664 €       34 €       34 € 

520      30 €    54 €         31 €           664 €       49 €       49 € 

520      30 €    54 €         31 €           664 €       51 €       51 € 
520      30 €    54 €         31 €           664 €     108 €     108 € 

40.000

30.000

10.000

3.689.250 €

EN 

67 

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.  

Transport engine to test location

Certification by notified body

Administration by manufacturer [40hours x 200€]

Engine testing [40 hours x 235€/h]

Periodical update of certificate

Typical costs [EUR, 2007] for 
engine >18kW, per engine family

500 €

1.500 €

8.000 €

9.400 €

500 €

19.900 €

Discontinuation costs  

These costs include loss of profit 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  generated  by  R&D  and  redesigning  engines  from 
scratch; this could result in the decision to discontinue the particular 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  obviously  affect  the  supplier  who  would  not  be 
receiving  any  new  orders  for  this  model.  Moreover,  the  discontinuation  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 compensate for these losses. If the price of the other 
models of the manufacturer increases, that will indirectly affect the consumer and its buying 
power. Similarly, for the small engine manufacturers 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-European  SI  manufacturers,  relying  on  the  US 
ABT do not have the possibility to rely on a mitigating measure in the EU, they might have to 
discontinue particular models or to stop putting these engines on the EU market. 

EN 

68 

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Unit costs per engine for SI engines 

Maximum 
Engine Power

L/cylinder

Units put on the market (1)

Fixed costs/engine  
linked to recertiication 
(2)

min

max

Other fixed costs/ 
engine (3)

Variable 
costs/engine (4)

min

max

SI Outboard

< 3

< 20

< 75

< 110

< 150

> 150

< 4

< 27

< 110

< 150

< 230

> 230

49.608 

            6 € 

              7 € 

84.652 

            6 € 

              7 € 

54.242 

            6 € 

              7 € 

10.524 

            6 € 

              7 € 

7.684 

            6 € 

              7 € 

4.119 

            6 € 

              7 € 

210.829 

Large companies using US ABT system

Small companies without export to US market 

                   1.688 € 

                   3.092 € 

SI Inboard

< 110

< 147

< 184

< 220

< 274

> 274

PWC

< 150

< 200

< 250

< 300

< 373

> 373

1.918 

          22 €              61 € 

2.214 

          22 € 

            61 € 

3.015 

          22 € 

            61 € 

1.018 

          22 € 

            61 € 

1.722 

          22 € 

            61 € 

296 

          22 € 

            61 € 

10.182 

                                          9.034  

            7 €                9 € 

        230.045   

         1 €             1 € 

         3 €             3 € 

         8 €             8 € 

       14 €           14 € 

       17 €           17 € 

       17 €           17 € 

         4 €         302 € 

         6 €         426 € 

         6 €         479 € 

         8 €         586 € 

         9 €         687 € 

       13 €      1.022 € 

       11 €           11 € 

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69 

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These  figures  are  for  guidance  only  and  should  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 flexibilities.  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 

Maximum 
Engine Power

L/cylinder

Units put on the market (1)

Total costs per year

total

large 
manufacturers

small 
manufacturers & 
marinisers

min

<19 kW

<0.9

19 to <75 kW <0.9a

19-37

37-75

75 to <3700 kW <0.9

0.9-<1.2

1.2-<2.5

2.5-<3.5

3.5-<7.0

12.800

16.800

9.200

7.600

2.080

2.080

2.080

2.080

2.080

9.600

12.600

6.900

5.700

1.560

1.560

1.560

1.560

1.560

3.200            389.997 € 

4.200            752.212 € 

2.300           411.926 € 

1.900           340.286 € 

520            133.383 € 

520            133.383 € 

520            165.806 € 

520            169.594 € 

520            288.609 € 

40.000

30.000

10.000         2.032.984 € 

max

7%       2.640.328 € 

13%       9.909.910 € 

7%      5.426.856 € 

6%      4.483.055 € 

2%          499.062 € 

2%          499.062 € 

3%          531.485 € 

3%          535.273 € 

5%          654.288 € 

    15.269.408 € 

14%

52%

29%

24%

3%

3%

3%

3%

3%

Costs linked to temporal discontinuation of engine models

        3.689.250 € 
       5.722.234 € 

64%       3.689.250 € 
100%     18.958.658 € 

19%

100%

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 include 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  would  have  significant  social  and  economic  impact  on 
suppliers and costumers 

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Total compliance costs (€ per year) - Option 2:  SI engines 

Maximum 
Engine Power

L/cylinder

SI Outboard

< 3

< 20

< 75

< 110

< 150

> 150

< 4

< 27

< 110

< 150

< 230

> 230

Units put on the market

min

Total costs per year
max

49.608 

84.652 

54.242 

10.524 

7.684 

4.119 

        352.902 € 

15%        367.189 € 

        765.919 € 

32%        790.299 € 

        778.853 € 

33%        794.475 € 

        212.807 € 

9%        215.838 € 

        176.455 € 

7%        178.668 € 

          94.581 € 

4%          95.768 € 

15%

32%

33%

9%

7%

4%

210.829 

     2.381.517 € 

100%     2.442.237 € 

100%

Large companies using US ABT system

        520.011 € 

Small companies without export to US market 

         1.766.667 € 
         4.668.194 € 

       520.011 € 

        1.766.667 € 
        4.728.914 € 

SI Inboard

< 110

< 147

< 184

< 220

< 274

> 274

PWC

< 150

< 200

< 250

< 300

< 373

> 373

1.918 

2.214 

3.015 

1.018 

1.722 

296 

10.182 

                                            9.034  

          49.608 € 

17%        696.673 € 

          60.879 € 

21%     1.078.359 € 

          85.002 € 

29%     1.627.794 € 

          30.136 € 

10%        658.649 € 

          53.266 € 

18%     1.288.563 € 

12%

19%

29%

12%

23%

          10.467 € 
        289.358 € 

        163.817 € 

4%        320.677 € 
100%     5.670.716 € 

6%
100%

       183.792 € 

  10.583.422 € 

          230.045   

     5.121.368 € 

Sub-option 3.1 – Stricter limits with granting flexibility scheme as a mitigating measure - 
compliance costs  

.  Compared  to  the  basic 
Costs  for  CI  engines  vary  between  1,2  M  €  and  8  M  €  per  year
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,  this  needs  to  be  regarded  as  an  underestimation  of  the  total 
impact of the flexibility scheme for the CI sector as the figure does not reflect the impact of 
lost  market  share,  nor  additional  benefits  linked  to  the  ability  for  companies  to  spread 
investment costs over time to meet the revised emission standards.  

Taking  into  account  the  lower  bound  of  the  variable  costs,  the  highest  contribution  of  this 
decrease  comes  from  the  implementation  of  the  flexibility  scheme  rather  than  from  the 
installation  of  an  exemption  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. 

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Total compliance costs (€  per year) - Sub-option 3.1:  CI engines  

Maximum 
Engine Power L/cylinder

<19 kW
19 to <75 kW <0.9a

<0.9

19-37
37-75

75 to <3700 kW <0.9

0.9-<1.2
1.2-<2.5
2.5-<3.5
3.5-<7.0

Units put on the market (1)

large 
manufacturers

total
   12.800                  9.600   
   16.800                12.600   
     9.200                  6.900   
     7.600                  5.700   

small 
manufacturers & 
marinisers
               3.200   
               4.200   
               2.300   
               1.900   

Total costs per year

min

max

           339.653 € 

28%          5.249.449 € 

66%

     2.080                  1.560                       520                133.383 € 
           133.383 € 
     2.080                  1.560   
           165.806 € 
     2.080                  1.560   
           169.594 € 
     2.080                  1.560   
           288.609 €  
     2.080                  1.560   
   40.000                30.000   
        1.230.428 €  

                  520   
                  520   
                  520   
                  520   
             10.000   

11%             499.062 € 
11%             499.062 € 
13%             531.485 € 
14%             535.273 € 

23%             654.288 €  
100%          7.968.619 €  

6%
6%
7%
7%

8%
100%

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  would  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  account  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

SI Outboard
< 3
< 20
< 75
< 110
< 150
> 150

SI Inboard
< 110
< 147
< 184
< 220
< 274
> 274

PWC

L/cylinder

Units put on the market

min 

max 

 Total costs per year 

< 4
< 27
< 110
< 150
< 230
> 230

                                          49.608  
                                          84.652  
                                          54.242  
                                          10.524  
                                            7.684  
                                            4.119  
                                        210.829  

Small companies without export to US market 

           352.902 € 
           765.919 € 
           778.853 € 
           212.807 € 
           176.455 € 
             94.581 € 
        2.381.517 € 
        1.766.667 € 
         4.148.184 € 

15%            367.189 € 
32%            790.299 € 
33%            794.475 € 
9%            215.838 € 
7%            178.668 € 
4%              95.768 € 
100%         2.442.237 € 

        1.766.667 € 
         4.208.904 € 

15%
32%
33%
9%
7%
4%

0%

< 150
< 200
< 250
< 300
< 373
> 373

                                            1.918  
                                            2.214  
                                            3.015  
                                            1.018  
                                            1.722  
                                               296  
                                          10.182  

             49.608 € 
             60.879 € 
             85.002 € 
             30.136 € 
             53.266 € 
             10.467 € 
           289.358 €  

17%            696.673 € 
21%         1.078.359 € 
29%         1.627.794 € 
10%            658.649 € 
18%         1.288.563 € 
4%            320.677 € 

    1 €  

        5.670.716 €  

12%
19%
29%
12%
23%
6%
100%

                                            9.034  
         230.045   

            163.817 € 

            183.792 € 

    4.601.358 €  

   10.063.411 €  

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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 mitigating measure. The transitional time of 3 years from 
entry into force means in fact a delay of 1 year of  Directive’s application when 2 years are 
presumably  dedicated  to  transposition  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 manufacturers (they will avoid 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 granted for Sub-option 3.2 
and 4-years for Sub-option 3.1 – duration 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 costs as sunk costs because they 
will  fulfil  already  the  US  limits  applied  earlier.  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 PN ≤ 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 only 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  decision  to  continue  with  the  production  of  some 
engine  categories  as  the  company  doesn’t  generate  sufficient  profit  to  finance  R&D  of  all 
engine  categories  in  one  and  they  are  dependant  on  the  external  financial  sources.  With  the 
granted  additional  lead  time  they  will  have  the  access  to  necessary  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 

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ANNEX XI:  Assumptions made to estimate the environmental noise impact – typical 
cases 

The  sound  impact  depends  on  the  number  and  duration  of  activities  (passing  craft,  circling 
craft), the sound emission per craft during that activity 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 open 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 between 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. Furthermore it is assumed that the craft are used for 80% during 
the daytime (7:00h to 19:00 h) and for 20 % during the evening (19:00 to 23:00h) and are not 
used during the night period; this division 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  distance  of  200  m  is  chosen.  The  same  distribution  over  day  and 
evening is used as for the canal; in this case also PWCs are considered with a use of 1 h per 
day, equally divided over day and 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 could 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  arbitrarily  chosen,  but  the  global  effect  of  other 
distances is indicated. It is assumed that engines are used for 1/3 h for each boat to leave and 
enter a marina. Other activities in the marina are neglected as well as sound reduction through 
screening by buildings and other obstacles. 

Additional remarks 

It  should  be  clarified  that  the  sound  production  is  lower  when  less  power  is  used  (lower 
speeds)  and  higher  when  more  throttle  and  thus  higher  speeds  are  used.  For  outboard  and 
inboard  engines  the  data  show  about  8  dB(A)  higher  levels  by  using  full  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 the craft. Though these circumstances 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 speed. It is questionable whether the disturbance 

EN 

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in  case  of  increased  use  of  power  is  mainly  due  to  the  higher  sound  level  or  due  to  the 
disapproval of the type of behaviour and other disturbing effects like higher waves. 

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ANNEX XII:  Share of compliance costs in turnover, impact on competitiveness 

All SMEs for which the share of compliance costs 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 larger engine manufacturers and marinisers are 
likely  to  have  higher  absolute  compliance  costs,  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  companies’  operations  and,  when  considering  the 
ratio  for  a  series  of  companies,  the  impact  higher  emission  standards  may  have  on  the 
company’s competitiveness. 

The  ratio  reveals  that  SMEs  face  a  major  burden  and  may  see  their  competitiveness 
deteriorate as a result of higher exhaust emissions standards. Compliance costs of SMEs for 
the proposed emissions standards range between 5,75% and 67,35% of annual turnover when 
the  stricter  limits  will  be  applied.  Large  engine  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* 

Significant 

Absorb the compliance costs 

Decrease in profits, less investments 

Modify production function 

Depending on how the new 
combination of inputs affects the 
selling price 

Increase the selling price** 

Decrease in sales, shrinking market* 

Very significant 

Shift the focus of the business 

Survival as a niche player 

Cease operation 

Out of market 

* The actual effect depends on the price elasticity of demand for recreational craft engines. 

** A further increase of the selling price will only be possible if the price elasticity of demand for recreational 
craft engines is very inelastic. 

Source: ARCADIS Impact Assessment Study (2008), p. 90-93 

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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 deriving 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 companies having replied to 
the  questionnaire  and/or  being  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 customisation of SI OB engines in the EU is slightly 
over 400. The numbers of 1 600 and 400 employees will 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 indirect 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 boats, is set at -2. This means that for every 
1%  price  increase  the  quantity  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  elasticity  is  set  at  0,35.  Finally,  the 
multiplier for assessing the overall (direct and indirect) 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 PWC manufacturing chain. No job losses in the EU SI IB engine 
manufacturing chain as we assumed 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 

Option 2 

max 

4,10% 

8,20% 

2,87% 

45,9 

27,6 

73,5 

1 600 

max 

min 

max 

max 

Suboption 
3.1 

3,30% 

6,61% 

2,31% 

37,0 

22,2 

59,2 

0,27% 

0,53% 

0,19% 

3,0 

1,8 

4,8 

1,72% 

3,45% 

1,21% 

19,3 

11,6 

30,9 

3,29% 

6,57% 

2,31% 

36,8 

22,1 

58,9 

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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 

Option 2 

Suboption 
3.1 

min 

max 

min 

max 

400 

0,54% 

1,07% 

0,38% 

0,54% 

1,09% 

0,38% 

0,48% 

0,95% 

0,33% 

0,48% 

0,97% 

0,34% 

1,5 

1,5 

1,3 

1,4 

0,9 

0,9 

0,8 

0,8 

2,4 

2,4 

2,1 

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 

Option 2 

Suboption 
3.1 

min 

max 

min 

max 

300 

0,16% 

0,32% 

0,11% 

0,16% 

0,32% 

0,12% 

0,18% 

0,35% 

0,11% 

0,18% 

0,35% 

0,12% 

0,3 

0,4 

0,3 

0,4 

0,2 

0,2 

0,2 

0,2 

0,5 

0,6 

0,5 

0,6 

Source of all Tables: ARCADIS Impact Assessment Study (2008), p. 98-100 

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ANNEX XIV:  SME Test 

The SME Test  

Consultation 

(1) 
representatives 

with 

SMEs 

See section 2.2. 

Preliminary 

(2) 
businesses likely to be affected 

assessment 

of 

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 

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period  for  SMEs  placing  on  the  EU  market  the 
SI outboard engines. 

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