Conversion to lithium of a CE-marked boat

[bikesherpa]

I recently become aware of a recommendation for use (RFU no. 199/2023) regarding lithium batteries, published by the group of inspection and certification organizations under the EU Recreational Craft Directive.

See page 335
https://www.imci.org/site/document/d...U%20240118.pdf

Scenario/Questions:

In a watercraft, bearing a CE mark, the non-lithium battery(-ies) permanently installed for use on the craft
electrical system and/or engine starting are replaced with (a) lithium-based battery(-ies) of the same
function.
Is this a "major craft conversion" in the sense of RCD Article 3 (7)?


Recommended Solution:
Yes.
This change alters the watercraft to such an extent that it may not meet any more the applicable
essential safety and environmental requirements laid down in the RCD and/or ISO/TS 23625.

The consequence of the above recommendation is that any change of batteries from lead-acid to lithium would require a Post Construction Assessemnt (PCA) of the boat and be done by qualified technicians, which would be very expensive.
In my opinion, this would basically kill the market for LFP conversions in the EU.

[CaptainRivet]

The f... EU again, bureaucrats their only job is to burn tons of money and make our life as difficult as possible...
Again these bureaucrats should finally get that lifepo4 and li-ion are totally different batteries. Instead lithium they should explicitly specify the lithium chemistry used.
Additionally new come with an lithium option, so that's part of CE.

Nope it just means a surveyor need to check if the install is sufficent and compliant with ISO. Like I done on my boat with DIY battery