REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to article 10.2 of Regulation (EC) N° 391/2009 on common rules and standards for ship inspection and survey organisations
Date: 2015-07-31
Institutions: Directorate-General for Mobility and Transport, European Commission
Subjects: harmonisation of standards, international standard, maritime safety, professional association, recognition of diplomas, ship's flag, spare part, vessel

EN 

   EN 

   EUROPEAN COMMISSION  Brussels, 31.7.2015  COM(2015) 382 final   REPORT FROM THE COMMISSION TO THE EUROPEAN PARLIAMENT AND THE COUNCIL pursuant to article 10.2 of Regulation (EC) N° 391/2009 on common rules and standards for ship inspection and survey organisations  
 
 
I. 

Introduction 

This report reviews the implementation by the Recognised Organisations of Article 10 (1) of 
Regulation  (EC)  N°  391/2009  (hereinafter  referred  to  as  "the  Regulation")  regarding 
harmonisation of their rules and procedures and setting up a system of mutual recognition of 
their class certificates for equipment, materials and components.  

The present report is based on an independent study, in accordance with Article 10 (2) of the 
aforementioned Regulation1.  

In  the exercise of their flag state responsibilities,  flag administrations  can delegate statutory 
responsibilities  stemming  from  international  conventions  to  ship  inspection  and  survey 
organisations ("classification societies"). Each organisation is responsible and accountable to 
the flag administration for the work that it carries out on the administration's behalf.  

Core  responsibilities  delegated  to  these  organisations  are  described  in  international 
conventions of the International Maritime Organisation or within relevant Union law. Within 
the EU, the Regulation as well as Directive 2009/15/EC2 set out common rules and standards 
for ship inspection and survey organisations and establish the legal framework for recognition 
of  ship  inspection  and  survey  organisations  and  for  the  relevant  activities  of  maritime 
administrations of the Member States who can only authorise organisations recognised under 
the Regulation (EU ROs) for the aforementioned statutory work.  

At  international  level,  the  International  Maritime  Organisation  Instrument  Implementation 
and  Recognised  Organisation  Codes  which  are  in  force  since  1st  January  2015  establish  the 
relevant legal framework. In view of ensuring compliance with Union legislation with the said 
Codes the Commission adopted the Commission Implementing Directive 2014/111/EU3 and 
the Commission Implementing Regulation (EU) N° 1355/20144.   

Recital (25)  of Commission Implementing Regulation (EU) N° 1355/2014 clarifies that the 
scheme  for  the  mutual  recognition  of  class  certificates  for  materials,  equipment  and 
components laid down by Article 10(1) of Regulation (EC) N° 391/2009 is only enforceable 
within  the  Union  in  respect  of  ships  flying  the  flag  of  a  Member  State.  As  far  as  foreign 
vessels  are  concerned,  the  acceptance  of  relevant  certificates  remains  at  the  discretion  of 
relevant non-EU flag States in the exercise of their exclusive jurisdiction, notably under the 
United Nations Convention on the Law of the Sea (UNCLOS). 

In  the conduct of their activity, classification societies oblige manufacturers to comply with 
different  sets  of  requirements  which  are  developed  by  each  society.  These  requirements  are 
important for the construction and operation of ships and play a role in reassuring the ship's 
owner and insurer, and ultimately the flag State about the safety of the vessel.  

The absence of mutual recognition of class certificates between societies results in the need 
for multiple certifications: in order to be able to operate on a global scale (and to have access 
to  a  wide  range  of  ship-owners  who  select  a  classification  society  to  supervise  the 

1 http://ec.europa.eu/transport/modes/maritime/studies/maritime_en.htm    
2  Directive  2009/15/EC  of  the  European  Parliament  and  of  the  Council  on  common  rules  and  standards  for  ship  inspection  and    survey 
organisations and for the relevant activities of maritime administrations (OJ L 131, 28.5.2009, p.47). 
3 Commission Implementing Directive 2014/111/EU of 17 December 2014 amending Directive 2009/15/EC with regard to the adoption by 
the International Maritime Organization (IMO) of certain Codes and related amendments to certain conventions and protocols. 
4 Commission Implementing Regulation (EU) No 1355/2014 of 17 December 2014 amending Regulation (EC) No 391/2009 with regard to 
the  adoption  by  the  International  Maritime  Organization  (IMO)  of  certain  Codes  and  related  amendments  to  certain  conventions  and 
protocols. 

2 

 
 
 
                                          
construction of a ship), marine equipment suppliers are required to obtain, for the same piece 
of  equipment,  a  certificate  from  different  classification  societies  certifying  the  conformity 
with often very similar requirements and sometimes based on identical tests even carried out 
at the same laboratories (which often happen to be the manufacturer's).This issue is addressed 
in article 10 (1) of Regulation (EC) N° 391/2009 as the matter of whether a product is to be 
certified by one or more classification societies is also important from an EU internal market 
perspective. 

The  Regulation  places  an  obligation  on  EU  recognised  organisations  to  harmonise  their 
classification rules and set up a system of mutual recognition of their classification certificates 
for  equipment,  materials  and  components.  In  particular,  according  to  Article  10  (1)  of  this 
Regulation, "Recognised organisations shall consult with each other periodically with a view 
to maintaining equivalence and aiming for harmonisation of their rules and procedures and 
the  implementation  thereof.  They  shall  cooperate  with  each  other  with  a  view  to  achieving 
consistent interpretation of the international conventions, without prejudice to the powers of 
the flag States.  

Recognised organisations shall, in appropriate cases, agree on the technical and procedural 
conditions  under  which  they  will  mutually  recognise  the  class  certificates  for  materials, 
equipment  and  components  based  on  equivalent  standards,  taking  the  most  demanding  and 
rigorous standards as the reference."  

This type of harmonisation has to be distinguished from the EU harmonisation for statutory 
requirements  for  marine  equipment.  The  Marine  Equipment  Directive5  (MED)  regulates 
equipment installed on board a vessel for which a "carriage requirement" under one or more 
of  the  international  conventions  exists  (e.g.  for  marine  pollution  prevention,  fire  protection, 
navigation, life-saving appliances). Member States are not allowed to prohibit the placing on 
the market or the placing on board an EU-flagged ship of marine equipment which complies 
with the MED, nor refuse to issue certificates relating hereto to the ships flying their flag. The 
respective equipment has to bear as a visible sign of conformity with the MED the so called 
'wheel  mark'.  The  Union  has  concluded  a  Mutual  Recognition  Agreement6  with  the  United 
States to facilitate trade and to avoid multiple certification of wheel marked equipment. 

However, a vast range of marine equipment (e.g. equipment not included in the international 
conventions) is not within the scope of the MED but subject to certification requirements of 
classification societies. Such equipment is targeted by Article 10 (1) of the abovementioned 
Regulation. 

II. 

Progress to date  

The  Regulation  does  not  set  specific  ways  in  which  the  mutual  recognition  should  be 
implemented.  Neither  does  it  set  specific  deadlines.  Thus  it  provided  flexibility  to  the  EU 
recognised organisations to  cooperate among themselves  as well as with other stakeholders, 
for  example  the  Ships  &  Maritime  Equipment  Association  (SEA  Europe),  and  decide  upon 
the necessary steps for its implementation.  

5 Council Directive 96/98/EC of 20 December 1996 on marine equipment (OJ L 046, 17.2.1997, p.25), as amended. 
6 http://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:JOL_2004_150_R_0042_01&from=EN  

3 

 
 
 
                                          
Regarding  the  first  requirement  (harmonisation),  the  EU  recognised  organisations  have 
implemented  a  systematic  approach  in  harmonising  the  technical  and  procedural  conditions 
for  certification  of  products  eligible  for  the  mutual  recognition  scheme.  In  doing  so,  the 
organisations  claim  they  have  used  the  most  demanding  and  rigorous  standards  as  the 
reference. In terms of the process of harmonisation of rules and procedures, a review of the 
current state of implementation has provided evidence that so far the extent this is still at its 
infancy. Although some mutual recognition Certificates have been issued under the "mutual 
recognition  scheme",  these  exist  in  the  market  together  with  the  individual  recognised 
organisation’ certificates for these specific products. In other words, the individual recognised 
organisation's certificates have not been withdrawn from the market. The above highlights the 
need for additional time to test the new mutual recognition Certificate in practice, which may 
become common practice and eventually replace the individually issued certificates. 

Regarding  the  second  requirement  (mutual  recognition),  the  EU  recognised  organisation 
considered the following scenarios:  

1.  to  accept  directly  each  other's  standards  as  equivalent,  recognising  each  other's 

certificates at face value;  

2.  to  select  and  accept  directly  rules  judged  to  be  the  most  demanding  and  rigorous 
following 
products 
(materials/equipment/components) in question  from all EU recognised organisations. 

classification 

assessment 

rules 

for 

all 

of 

3.  to  develop  afresh  common  technical  requirements  as  the  basis  for  issuing,  in 
appropriate cases, an additional certificate which they mutually recognise. Individual 
certificates issued by each EU recognised organisation continue to exist in parallel to 
the proposed (mutually recognised) Certificate. 

The organisations decided to follow the third approach to implement the obligations included 
in Article 10 (1) of the Regulation.  

A risk assessment mechanism was created to assess products across the board according to a 
6-level scale of safety criticality, as seen below (figure 1). 

4 

 
 
 
 
 
The scale of safety criticality took the shape of a hierarchical pyramid7. Certification for the 
highest  level  (6th)  of  this  pyramid  requires  knowledge  of  full  build  specification.  Moving 
lower  to  the  5th  level,  the  certification  requires  sub-certificates.  Level  4th  requires  Unit 
certification, and level 3 requires Type approval alone. For the lower levels (1st and 2nd) there 
are no class requirements or only a manufacturer's certificate is expected. The EU recognised 
organisations agreed upon a set of technical requirements for a limited number (currently 34, 
to  be  increased  to  44  as  of  1st  July  2015)  of  products,  eligible  for  "Type  Approval" 
certification,  falling  under  the  3rd  level  of  the  safety  criticality  scale  mentioned  above.  This 
specific type of certification has become known as the "mutual recognition scheme". 

The  Technical  Requirements8  for  relevant  certificates  are  agreed  among  EU  recognised 
organisations and are published in Tiers. The progressive development of these Tiers has been 
accelerated  due  to  accumulated  experience  over  the  recent  years  and  has  been  listed  (from 
initial concept to final release) in the table below:  

Number of Tier 
#1 
#2 
#3 
#4 
#5 

Initial concept 
29/6/2010 
06/09/2011 
24/09/2013 
23/04/2014 
21/04/2015 

Final release 
01/01/2013 
01/07/2013 
01/07/2014 
foreseen for 01/07/2015 
Ongoing work 

The  first  Tier  included  Technical  Requirements  for  11  products  (3rd  safety  criticality  level) 
that  entered  into  force  in  the  beginning  of  2013  and  was  followed  by  a  second  Tier  (11 
products, July 2013) and a third Tier (12 products, July 2014) always for the same (3rd) safety 
criticality  level.  A  fourth  Tier  of  Technical  Requirements  for  10  products,  again  of  the  3rd 
safety criticality level enters into force on 1st July 2015. Preparations for the fifth Tier have 
started, with the industrial sector participating in the selection of the Technical Requirements 
for  products  of  the  fifth  Tier,  based  on  a  consolidated  list  of  (3rd  safety  criticality  level) 
products, presented to them by the EU Recognised Organisations Mutual Recognition Group. 
All  Tiers  of  the  mutual  recognition  scheme  are  related  to  products  of  the  Type  Approval 
category because its criticality was shown to be low; thus, experience with the new scheme 
can  be  gained  while  limiting  the  risk  to  safety.  Upon  adoption  of  the  fourth  Tier,  the  44 
Technical Requirements of products eligible for this scheme will cover ca. 50% of the total 
type approval certification required in the classification rules of EU recognised organisations. 
The  organisations  are  of  the  opinion  that  as  the  level  of  safety  criticality  increases,  more 
complex  processes  will  have  to  be  considered;  however,  the  list  of  products  currently 
available is not considered going far enough to have added value for business because it only 
applies to a small market segment, according to the manufacturing sector.  

While  focussing  on  harmonisation  of  technical  requirements  the  organisations  could  have 
opted for a simple mutual recognition of each other's certificates, at least regarding 3rd level 
safety critical products. This may have resulted in a quicker progress which would correspond 
more to the expectations of the marine equipment manufacturers. 

7 See page 12 (The EU ROs’ approach to meeting Article 10) in: 
http://www.euromr.org/SiteAssets/Document%20Archive/EU_report_1212_L02.pdf  
8 Agreed Technical Requirements for mutual recognition: http://www.euromr.org/technical-requirements  

5 

 
 
 
 
                                          
III.  On-going issues 

Compliance with safety requirements 
The  mutual  recognition  scheme  appears  to  be  compliant  with  the  safety  considerations 
highlighted in Article 10 (1) of the Regulation. All key stakeholders have agreed that safety is 
of paramount importance.  

The  strictest  rules  apply  for  the  preparation  and  implementation  of  the  Technical 
Requirements  for  the  mutual  recognition  Certificate  and  all  EU  recognised  organisations 
follow the same rules for issuing the new mutual recognition Certificate. Moreover, any new 
mutual  recognition  Certificates  that  will  be  issued  will  have  exactly  the  same  standing 
worldwide. If however there is a non-acceptance incident of a mutual recognition Certificate 
by  a  certain  EU  recognised  organisation,  the  group  on  EU  recognised  organisations  have 
established  internal  reporting  processes  in  order  to  establish  the  reasons  why  this  was 
performed and address it accordingly, in compliance with the third subparagraph of Article 10 
(1).  

Involvement of stakeholders 
It  should  be  highlighted  that  the  marine  equipment  industry  is  involved  in  the  mutual 
recognition certification process only to a limited extent.  

in 

the  past 

through  other 

On one side, big original equipment manufacturers (OEMs) are more involved in the mutual 
recognition  process  due  to  their  own  interest  and  prior  knowledge  of  similar  certification 
processes 
international 
standardisation  activities  for  electrical  or  mechanical  products  and  equipment.  However, 
smaller  OEMs  are  not  as  well  informed  or  involved  due  to  their  inherent  market 
characteristics e.g. smaller size, constraints in terms of administrative and financial resources. 
It is this part of the marine equipment manufacturers that would appreciate more information 
regarding the mutual recognition certification scheme. Accordingly, it is this particular group 
of  stakeholders  that  could  most  benefit  from  the  Regulation  as  multiple  certificates  are  less 
often affordable for these manufacturers.  

international  collaborations  e.g. 

A range of stakeholders share the view that there is lack of or limited information available9. 
This can be attributed to the limited time that the mutual recognition scheme has been up and 
running and showcased in the market (all existing mutual recognition Certificates have been 
issued over the last 18 months). 

All EU recognised organisations have developed internal processes for the mutual recognition 
certification  in  order  to  increase  awareness  within  their  organisation.  The  latter  has  been 
applied both within the EU and worldwide (i.e. EU recognised organisations headquarters and 
site  offices  worldwide),  very  much related to  the  global  operations  of  each  organisation.  At 
the  time  of  the  preparation  of  this  report,  a  total  of  14  mutual  recognition  Certificates  have 
been published10. It is important to note that manufacturers which acquired those certificates 
do not only have their head offices in EU countries but also in USA, Taiwan and South Korea. 
This  further  highlights  the  global  nature  of  the  industry  and  the  importance  of  as  wide  as 
possible acceptance of the issued mutual recognition Certificates. 

9 http://www.easy-content.be/Documents/Open.aspx?guid={0CF8BB9B-3D56-4E4F-ABCF-B3F8991A6A81} 
  http://ec.europa.eu/transport/modes/maritime/studies/maritime_en.htm      
10  See  Appendix  V 
referred 
the 
http://ec.europa.eu/transport/modes/maritime/studies/maritime_en.htm    

independent 

article 

study 

10.2 

of 

to 

in 

of  Regulation 

(EC) 

391/2009: 

6 

 
 
 
                                          
Cost and administrative burden related issues 
At  present  there  is  also  a  lack  of  transparency  concerning  the  cost  of  acquiring  a  mutual 
recognition Certificate.  

It  is  difficult  to  obtain  a  full  picture  of  the  overall  cost,  as  the  cost  for  a  new  mutual 
recognition Certificate varies according to the item that it will be issued for. To this extent, for 
simple  mass  produced  items  (e.g.  valves,  electrical  components,  etc.),  the  cost  for  the  new 
Certificate can vary from similar up to twice the price of one for the same product for which 
individual  RO  Type  Approval  certificates  were  previously  required.  However,  for  another 
category  of  specific  products  (e.g.  one-off  non-mass  produced  items)  the  cost  of  the  new 
mutual recognition Certificate could potentially be significantly higher than for an individual 
recognised organisation Type Approval certificate. On the other hand, renewal fees seem to 
be  similar  to  those  for  Type  Approval  certificates.  A  5-year  term  of  mutual  recognition 
Certificates’  renewal  is  a  general  practice  among  EU  recognised  organisations  relating  not 
only  to  Certificates  issued  under  the  mutual  recognition  scheme,  but  also  to  those  of 
individual RO Type Approval (for the latter see also IMO Circular MSC.1/Circ.122111). The 
fact  that  witness  testing  is  required  for  some  of  the  new  mutual  recognition  Certificates,  in 
combination  with  the  necessity  to  meet  more  rigorous  standards,  has  potentially  led  to  an 
increase in cost in certain cases.  

The preliminary data from the independent study demonstrate that the amount of time needed 
to  acquire  a  mutual  recognition  Certificate  varies  a  lot  (from  6  months  up  to  2  years) 
depending  on  the  product  in  question  and  the  complexity  of  the  overall  process  (i.e. 
administrative burden). Such fluctuations can partly be attributed also to the fact that there is 
only  a  limited  number  of  mutual  recognition  Certificates  already  issued,  thus  making  it 
challenging  to  draw  general  conclusions  on  aspects  related  to  length  of  time  needed.  It  has 
been  reported12  that,  for  a  specific  product,  the  mutual  recognition  Certificate  and  the 
individual  EU  recognised  organisation's  Type  Approval  certificate  were  both  issued 
simultaneously.  It  is  though  important  to  acknowledge  that  as  more  mutual  recognition 
Certificates are issued and the overall process becomes more standardised, the time necessary 
to acquire a new mutual recognition Certificate may be significantly reduced. 

IV.  Way forward 

Safety criticality assessment mechanism  
In terms of number of products eligible for the mutual recognition Certificate, the progress so 
far has been achieved only with regards to the 3rd safety criticality level. The EU recognised 
organisations have sought to include the marine equipment industry in the process as can be 
also observed through a long list13 of meetings and initiatives taking place since 2009. At this 
stage it is important to address the concerns in the area of safety impact. This can be done by 
following  the  same  risk  based  approach  process  used  by  the  EU  recognised  organisations 
including  the  strictest  Technical  Requirements  for  all  products14  belonging  to  the  3rd  safety 
criticality  level  that  are  included  within  existing  Tiers  (1,  2  and  3)  as  well  as  for  the 
forthcoming  two  Tiers  (4  and  5)  of  products  to  be  published  in  the  future  (1/7/2015  and 

11 http://www.iho.int/mtg_docs/industry/ECDIS_workshop_12/MSC_Circ1221.pdf  
12 http://ec.europa.eu/transport/modes/maritime/studies/maritime_en.htm  
13  See  Appendix 
referred 
the 
http://ec.europa.eu/transport/modes/maritime/studies/maritime_en.htm    
14  See  Appendix 
referred 
the 
http://ec.europa.eu/transport/modes/maritime/studies/maritime_en.htm    

independent 

independent 

study 

study 

of 

of 

to 

in 

to 

in 

II 

I 

article 

10.2 

of  Regulation 

(EC) 

391/2009: 

article 

10.2 

of  Regulation 

(EC) 

391/2009: 

7 

 
 
 
                                          
summer  2016  respectively),  and  the  need  for  witnessed  testing,  when  necessary  for  the 
acquisition  of  a  mutual  recognition  Certificate.  In  this  way  the  approach  of  the  mutual 
recognition scheme can gain momentum over time and further address safety concerns.  

The  development  of  a  more  advanced  and  comprehensive  risk  model  for  the  selection  of 
products belonging to the next (4th) safety criticality level would require the involvement of 
various  stakeholder  organisations,  including  insurers.  The EU  recognised  organisations  plan 
to conduct a 6 month pilot study to ensure that safety is maintained at the higher (4th) level.  

End-user involvement 

Industry stakeholders within the EU appear to be more active in terms of participation in the 
EU  recognised  organisations  consultation  process  while  global  industry  could  appreciate 
higher  involvement  in  the  future.  An  indication  of  the  above  is  the  fact  that  out  of  7 
manufacturers  already  using  the  new  mutual  recognition  Certificate  for  some  of  their 
products,  3  have  their  headquarters  outside  EU  (i.e.  USA,  Taiwan  and  South  Korea).  This 
could  enhance  the  global  acceptance  of  the  mutual  recognition  Certificates.  Additional 
involvement by small OEMs would be also encouraged as they form the group which is less 
often involved in the current mutual recognition scheme implementation through associations, 
information  workshops  and  other  similar  events.  In  this  case  the  mutual  recognition 
Certificates  could  increase  the  market  access  for  Small  and  Medium  sized  Enterprises 
(SMEs).  In  practice  though,  due  to  the  current  ambiguity  of  voluntary  mutual  recognition 
Certificate  acceptance  by  administrations  worldwide,  this  may  only  be  applicable  for  EU 
based  SMEs  supplying  to  ships  flying  the  flag  of  a  Member  State.  However,  while  global 
voluntary acceptance should be further promoted, the time to market as well as administrative 
costs, would be reduced for those companies targeting a wider audience.  

Additional considerations 

It is not clear at this juncture whether EU recognised organisations will manage to elaborate 
requirements  for  mutual  recognition  certifications  for  more  complex  products  in  the  near 
future.  Equipment  manufacturers  are  eager  to  propose  a  list  of  possible  new  products  with 
higher safety criticality. To this end, further steps have been suggested by SEA Europe and 
EU recognised organisations including planned meetings among major international industry 
stakeholders in order to discuss and receive feedback and recommendations for incorporating 
additional products in the scheme.  

With  regards  to  the  currently  existing  products,  as  illustrated  by  the  independent  study,  a 
significant  proportion  of  stakeholders  (such  as  manufacturers,  ship-operators,  insurers, 
shipyards,  shipbuilders,  ship  repairers)  had  no  information  with  regard  to  the  use  and 
acceptance  of  the  mutual  recognition  Certificate  nor  knew  whether  mutual  recognition 
Certificates were currently accepted by all EU recognised organisations.  

Therefore  dissemination  events  (e.g.  workshops,  seminars,  etc.)  in  combination with  wider 
distribution of existing information on the technical requirements of the eligible products for 
the mutual recognition scheme to a larger proportion of stakeholders with different industry 
interests  could  be  envisaged  to  enlarge  the  outreach  of  the  mutual  recognition  scheme  to  a 
wider  audience.  To  this  end,  the  two  workshops  organised  by  EU  recognised  organisations 
and SEA Europe so far have been perceived as an effective step in this direction and should 
be continued.  

8 

 
 
 
 
Providing  for  time  to  process  recommendations  and  receipt  of  feedback  on  the  scheme 
through  available  channels  of  communication15  can  enhance  awareness  and  thus  promote 
additional  involvement  by  a  larger  group  of  interested  stakeholders.  Products/units  that  are 
already subject to common rules among EU recognised organisations could be a good starting 
point  for  the  expansion  of  the  scheme  to  the  next  (4th)  level  of  safety  criticality.  Informing 
shipowners, shipbuilders and local surveyors of the mutual recognition scheme could further 
enhance  its  acceptance.  Other  measures  that  can  promote  the  mutual  recognition  scheme 
would  be  to  increase  the  transparency  related  to  the  cost  for  obtaining  mutual  recognition 
Certificates. 

V.  Conclusions 

The mutual recognition scheme developed by EU recognised organisations is compliant with 
the  EU  Regulation  although  manufacturers  criticise  the  application  process  for  mutual 
recognition Certificates as not yet completely streamlined. Existing experience, which is very 
limited, shows that component suppliers still apply for individual certificates and additionally 
the mutual recognition Certificate. When witnessed testing is required for the latter, the cost is 
often  considered  overwhelming  (especially  for  SMEs).  Whilst  there  is  a  general  lack  of 
information  outside  the  immediately  affected  stakeholders,  additional  information  and 
dissemination  events  could  improve  awareness  and  participation  in  the  mutual  recognition 
certification  scheme.  Voluntary  international  acceptance  is  the  most  important  obstacle  to 
overcome  and  dialogue  between  industry  representatives  as  well  as  between  relevant  public 
authorities may increase understanding and acceptance of the mutual recognition certification 
scheme outside the EU. Through the application of the risk based approach for the selection 
of items included in all Tiers of technical requirements for products of the 3rd safety criticality 
level,  and  the  adherence  to  the  strictest  rules,  safety  is  fully  promoted  through  the  mutual 
recognition scheme. Still there is room for expansion of the mutual recognition certification 
scheme to cover a broader range of marine equipment products (e.g. more complex products 
or materials) under different safety criticality levels. 

Overall, at this juncture, the following can be concluded: 

  The  mutual  recognition  scheme  developed  by  EU  recognised  organisations  is 
compliant  with  the  EU  Regulation  although  its  scope  is  still  limited  and  should  be 
further developed.  

  At  present  mutual  recognition  Certificates  co-exist  with  individual  Type  Approval 
certificates  for  the  same  products.  Recognised  organisations  should  consider 
simplifying the procedures for mutual recognition Certificates in appropriate cases so 
that  their  costs  become  more  competitive  and  individual  certificates  can  be  phased 
out. 

15 Requesting Changes or Clarification of MR Technical Requirements (TRs) and Related Documentation: http://www.euromr.org/technical-
requirements  

9