Mutual Recognition Agreements

 

MRA LINKS

The Mutual Recognition Agreements

The Mutual Recognition Agreements are parallel agreements the United States of America (US) has with the European Union (formerly the European Community (EC)) and with the European Free Trade Association (EFTA) countries which are part of the European Economic Area (EEA) on the Mutual Recognition of Certificates of Conformity for Marine Equipment as allowed by Title 46 Code of Federal Regulation (CFR) subpart 159.003. 

The objectives of the two mutual recognition agreements (MRAs) are to facilitate US - EU and US – EEA EFTA trade in marine equipment and to promote bilateral cooperation on international marine equipment regulations.  The two agreements allow a manufacturer to reach both the US and European (EU and EEA EFTA member states) markets on the basis of demonstrating compliance with one set of regulatory requirements.  This can directly lead to a reduction of costs for manufacturers in terms of testing and certification. 

The two agreements are commonly referred to as the “MRA on marine equipment” and are simply referred to as the “MRAs” in this Navigation and Vessel Inspection Circular.  The mutual recognition agreement between the US and the EC was signed on February 27, 2004 and became effective on July 1, 2004.  The mutual recognition agreement between the US and Norway, Iceland and Liechtenstein, which represent the EEA EFTA member states was signed on October 17, 2005, and became effective on March 1, 2006.  The European regulations governing marine equipment were updated in 2014, and as a result, these agreements were updated.  The updated agreements became effective on February 18, 2019, and February 22, 2019, respectively.  The updated agreements with the EC, signed by the European Union (EU), and EFTA also expanded the types of equipment covered under the MRA. 

The current product scope of the MRAs includes 69 products in three main categories: lifesaving equipment; fire protection equipment and navigational equipment.  The MRAs allow a manufacturer to reach multiple markets on the basis of compliance with one set of regulatory requirements.  This can directly lead to a reduction of costs for manufacturers for testing and certification, and provide ship owners, builders, and operators with a wider selection of equipment providing more flexibility when designing, building, and operating their vessels

The MRAs do not change the requirements of vessel owners and operators to use USCG approved equipment where required on US flag vessels.  However, they do allow vessel owners and operators to purchase and install equipment that has been approved (issued a wheelmark and a USCG Approval number) under the requirements of the MRAs by an EU or EEA EFTA Notified Body.  OCMIs and ROs acting on behalf of the Coast Guard will continue to require USCG approval where required by the applicable regulations.

SUMMARY

  • The MRAs (Annex II) specifically identifies which items are covered.
  • The US – EC MRA went into effective July 1st, 2004 and was amended February 18th, 2019.
  • The US – EEA EFTA MRA is effective March 1st, 2006  and was amended February 22nd, 2019.
  • The USCG will not accept the MED mark of conformity in lieu of USCG approval numbers on U.S. flag ships.  Instead, the MRA provides a means to obtain USCG approval for eligible products from EC or EEA EFTA notified bodies.
  • Equipment that receives a USCG approval number from a European Notified Body under the MRA can be installed onboard a US flag vessel where applicable.
  • Equipment that receives the mark of conformity from the USCG under the MRA can be installed where applicable onboard a European flag vessel of a country that is a member of the EC or the EEA EFTA.
  • A manufacturer having the MED mark of conformity will make application for USCG approval to the notified body that issued the MED certificates authorizing the mark of conformity or they can apply to the USCG and receive a certificate under the MRA.

 For further questions click here to contact the CG-ENG-4 Staff.

Equipment Eligible for Mutual Approval Under the MRAs

Product item identification

USCG Approval Category

MED Number and item designation

Primary decks covering

164.106

MED/3.1

‘A’ & ‘B’ Class divisions fire integrity

 

(a) ‘A’ class divisions,

164.105 (deck assembly)*

164.107 (structural insulation) *

MED/3.11 (a)

‘A’ & ‘B’ Class divisions fire integrity

 

(b) ‘B’ class divisions.

 

Note: Restricted ‘B’ Class divisions are not covered by this agreement.

164.108 (bulkhead panels) *

164.110 (structural ceiling) *

MED/3.11 (b)

Non- combustible materials

164.109

MED/3.13

Fire doors

 

Limited to fire doors without windows or with total window area no more than 645 cm2 in each door leaf.

Approval limited to maximum door size tested.

Doors must be used with a fire tested frame design.

 

Note: Restricted ‘B’ Class doors are not covered by this agreement.

                                                               

164.136

MED/3.16

Fire door control systems components.

 

Note: When the term “system components” is used in column 1 it may be that a single component, a group of components or a whole system needs to be tested to ensure that the international requirements are fulfilled.

164.146

MED/3.17

Surface materials and floor coverings with low flame- spread characteristics

  1. decorative veneers.

164.112

MED/3.18 (a)

Surface materials and floor coverings with low flame- spread characteristics

  1. paint systems.

164.112

MED/3.18 (b)

Surface materials and floor coverings with low flame- spread characteristics

  1. floor coverings.

164.117

MED/3.18 (c)

Surface materials and floor coverings with low flame- spread characteristics

  1. combustible ducts.

164.112

MED/3.18 (f)

Draperies, curtains and other suspended textile materials and films

164.111

MED/3.19

Upholstered furniture

164.144

MED/3.20

Bedding components

164.142

MED/3.21

Fire dampers

164.139

MED/3.22

Penetrations through ‘A’ class

  1. electric cable transits.

164.138

MED/3.26 (a)

Penetrations through ‘A’ class

  1. pipe, duct, trunk, etc penetrations

164.138

MED/3.26 (b)

Fire restricting materials (except furniture) for high speed craft

 

(New item)

164.201

MED/3.32

Fire restricting materials for furniture for high speed craft

 

(New item)

164.201

MED/3.33

Fire resisting divisions for high speed craft

 

(New item)

164.207

MED/3.34

 
 

* Does not include “A” or “B” class windows.

Product item identification

USCG Approval Category

MED Number and item designation

Position- indicating lights for life- saving appliances:

  1. for survival craft and rescue boats

(New Item)

161.101

 

MED/1.2a

Position- indicating lights for life- saving appliances:

  1. for lifebuoys

(New Item)

161.110

MED/1.2b

Position- indicating lights for life- saving appliances:

  1. for lifejackets

(New Item)

161.112

 

MED/1.2c

Lifebuoy self- activating smoke signals

 

Note: Expiration date not to exceed 48 months after month of manufacture.

160.157

 

MED/1.3

Rocket parachute flares (pyrotechnics)

 

Note: Expiration date not to exceed 48 months after month of manufacture.

160.136

MED/1.8

Hand flares (pyrotechnics)

 

Note: Expiration date not to exceed 48 months after month of manufacture.

160.121

MED/1.9

Buoyant smoke signals (pyrotechnics)

 

Note: Expiration date not to exceed 48 months after month of manufacture.

160.122

 

MED/1.10

Line- throwing appliances

 

Note: Expiration date not to exceed 48 months after month of manufacture.

160.040

MED/1.11

Rigid liferafts

 

Note: The emergency pack is not covered by the Agreement

160.118

 

MED/1.13

Automatically self- righting liferafts (rigid liferafts only/inflatable liferafts not covered)

 

Note: The emergency pack is not covered by the Agreement

160.118

MED/1.14

Canopied reversible liferafts (rigid liferafts only/inflatable liferafts not covered)

 

Note: The emergency pack is not covered by the Agreement

160.118

 

MED/1.15

Float- free arrangements for liferafts (hydrostatic release units)

160.162

MED/1.16

Release mechanism for:

(a) Lifeboats and rescue boats

(launched by a fall or falls)

 

Limited to Davit- launched liferaft automatic release hook

160.170

MED/1.26 (a)

Release mechanism for :

(b) Liferafts

(launched by a fall or falls)

 

Limited to Davit- launched liferaft automatic release hook

160.170

MED/1.26 (b)

Marine evacuation systems

160.175

MED/1.27

Embarkation Ladders (New Item)

160.117

MED/1.29

Retro- reflective materials (New Item)

164.018

MED/1.30

 

Product item identification

USCG Approval Category

MED Number and item designation

Magnetic compass

Class A for ships

165.101

MED/4.1

Transmitting heading device THD (magnetic method)

 

Note: The use of ISO 11606:2000/Cor 1:2005 is required for Acceptance for USCG Approval under the MRA

165.102

MED/4.2

Gyro compass

165.103

MED/4.3

Echo - sounding equipment

165.107

MED/4.6

Speed and distance measuring equipment (SDME)

165.105

MED/4.7

Rate- of- turn- indicator

165.106

MED/4.9

GPS equipment

165.130

MED/4.14

GLONASS equipment

165.131

MED/4.15

Heading control system (HCS)

165.110

MED/4.16

Rudder Angle Indicator (New item)

165.167

MED/4.20

Propeller revolution indicator (New item)

165.168

MED/4.21

Pitch Indicator (New item)

165.169

MED/4.22

Radar equipment CAT 1

 

(Radar equipment used with ARPA must have separate EU and USA certifications)

165.115

MED/4.34

Radar equipment CAT 2

 

(Radar equipment used with ATA must have separate EU and USA certifications)

165.116

MED/4.35

Radar equipment CAT 3

 

(Radar equipment used with EPA must

have separate EU and USA certifications)

165.117

MED/4.36

Voyage data recorder (VDR)

165.150

MED/4.29

Electronic chart display and information system (ECDIS) with backup, and raster chart display system (RCDS) (New item)

165.123 (ECDIS)

165.124 (ECDIS Back-up Equipment)

MED/4.30

Gyro compass for high- speed craft

165.203

MED/4.31

Universal automatic identification system equipment (AIS)

165.155

MED/4.32

Track control system

(working at ship’s speed from minimum manoeuvring speed up to 30 knots)

165.112

MED/4.33

Radar equipment for high speed craft applications (CAT 1H and CAT 2H)
(New item)

165.216 (CAT 1H)

165.217 (CAT 2H)

MED/4.37

Radar reflector passive type

165.160

MED/4.39

Heading control system for high speed craft (New Item)

165.210

MED/4.40

Transmitting heading device THD (GNSS method) (New item)

165.102

MED/4.41

Searchlight for high speed craft (New item)

165.252

MED/4.42

Night vision equipment for high speed craft
(New item)

165.251

MED/4.43

Transmitting heading device THD (Gyroscopic method) (New item)

165.102

MED/4.46

Simplified voyage data recorder (S- VDR) (New item)

165.151

MED/4.47

DGPS Equipment (New item)

165.132

MED/4.50

DGLONASS Equipment (New item)

165.133

MED/4.51

Daylight signalling lamp (New item)

165.166

MED/4.52

Bridge Navigational Watch Alarm System (BNWAS) (New item)

165.142

MED/4.57

Sound reception system (New item)

165.165

MED/4.58

 

Certificates and Product Markings

USCG Certificate of Approval

The USCG Certificate of Approval (COA) will be endorsed with a statement to indicate that a manufacturer may apply markings required for use on both EC and EFTA member state vessels.

1408/YY

The manufacturer is allowed to affix the Mark of Conformity as allowed by the “Agreement between the European Community and the United States of America on Mutual Recognition of Certificates of Conformity for Marine Equipment” signed February 2004 as amended on February 18th, 2019 and by the “Agreement between the European Free Trade Association countries which are part of the European Economic Area and the United States of America on Mutual Recognition of Certificates of Conformity for Marine Equipment” signed October 2005 as amended on February 22th, 2019.  Item complies with requirements of Item No. MED/#.##(x) of the directive.

 

Where MED/#.##(x) is the item number or EC and EEA EFTA approval category equivalent for each product covered by the MRA (See below for list of products covered).

 

Product Markings

Manufacturers obtaining authorization to apply the mark of conformity to their products from the USCG will need to ensure that the marking is in accordance with the MED.  The following are examples of the required mark of conformity:

                      

  • The mark shall be followed by the USCG notified body identification number (XXXX = 1408) and by the last two digits of the year in which the product is produced.  The year may be applied as YYYY (2019) or YY(19). 
  • Minimum size of the wheel and numbers is 5 mm (may be waived for small devices). 
  • The mark shall be affixed to the equipment or to its data plate so as to be visible, legible
    and indelible throughout the anticipated useful life of the equipment. However, where it is not possible nor warranted on account of the nature of the piece of equipment, it shall be affixed to the packaging of the product, to a label or to a leaflet.

EU/EAA EFTA Certificates

EU and EEA EFTA Notified Bodies acting under the authority of the US-EC MRA or the US-EEA EFTA MRA are permitted to issue USCG approval numbers for products covered by the MRAs.  The EC Type Examination (Module B) Certificate issued by a Notified Body should include the following paragraph:

 

“This equipment is covered by the scope of the “Agreement between the European Community and the United States of America on Mutual Recognition of Certificates of Conformity for Marine Equipment” signed February 27th, 2004 and amended by Decision No.1/2018 dated February 18th, 2019  according to U.S. Coast Guard approval category .  A U.S. Coast Guard approval number will be assigned to the equipment when the production module has been completed and will appear on the production module certificate (module D, E or F) as allowed by the MED.”

 

For cases when the same Notified Body issues both certificates, the Notified Body assigns a USCG approval number on the Module D, E & F Certificates and includes the following paragraph:  

 

“The manufacturer is allowed to affix the US Coast Guard approval number as allowed by the “Agreement between the European Community and the United States of America on Mutual Recognition of Certificates of Conformity for Marine Equipment” signed February 27th, 2004 and amended by Decision No.1/2018 dated February 18th, 2019”

 

For cases when the Notified Body conducting the approval to Module B is different than the Notified Body conducting the quality assurance under Module D, E or F, the Certificate of Conformity (Module D, E or F) should be issued by the Notified Body (NB2) with the EC-US MRA marking required and the following paragraph:

 

“The manufacturer is allowed to affix the US Coast Guard approval number as allowed by the “Agreement between the European Community and the United States of America on Mutual Recognition of Certificates of Conformity for Marine Equipment” signed February 27th, 2004 and amended by Decision No.1/2018 dated February 18th, 2019”

 

Product Markings

Manufacturers obtaining authorization to apply the USCG Approval Number to their products from a EU or EAA EFTA Notified Body will affix the US Coast Guard approval number.

For example:

 

164.109/EC0038/zzz

 

where EC0038" indicates approval by the Notified Body number with number 0038 and zzz” is the Unique Identifier for this product.

An example of an affixed US Coast Guard approval number for cases when the Notified Body conducting the approval to Module B is different than the Notified Body conducting the quality assurance under Module D, E or F, the Certificate of Conformity (Module D, E or F) is as follows:

 

164.109/EC0038/zzz/EC1121

 

where “EC0038" is the Notified Body that issued the Module B Certificate and has the notified body number “0038” and EC1121 is the Notified Body that issued Module D Certificate and has the notified body number "1121" and zzz” is the Unique Identifier for this product.

Background of the MRAs

In December 1998, the United States Trade Representative (USTR) proposed to the European Commission (EC) the negotiation of a Mutual Recognition Agreement (MRA) on marine equipment under the Transatlantic Economic Partnership. The goal of the MRA is to allow a manufacturer to reach multiple markets on the basis of compliance with one set of regulatory requirements instead of multiple ones, as would be the case without the MRA. This will directly lead to a reduction of costs for manufacturers in terms of testing and certification. Negotiations on an agreement began in late 1999. The Lifesaving & Fire Safety Standards Division (CG-ENG-4) worked in close cooperation with USTR to develop the product scope based on a detailed product-by-product review of the U.S. and EC marine equipment requirements.

Negotiations on this important mutual recognition agreement between the US and the EC were concluded in June 2003. The MRA on marine equipment is a result of a 5-year cooperative effort that recognizes the importance of facilitating US - EC trade in marine equipment and promoting bilateral cooperation on international marine equipment regulations. The final version of the US - EC MRA was signed on February 27, 2004 and it entered into force on July 1, 2004. 

Following the implementation of the US – EC MRA the USTR started negotiations with the European Free Trade Association (EFTA) countries which are part of the European Economic Area (EEA) on a MRA that is parallel to the existing US – EC MRA. This second mutual recognition agreement between the US and Norway, Iceland and Liechtenstein which represent the EEA EFTA member states continues the goal to increase the manufacturer’s ability to reach multiple markets on the basis of compliance with one set of regulatory requirements. The US – EEA EFTA MRA was signed on October 17, 2005 and became effective on March 1, 2006. 

The European regulations governing marine equipment were updated in 2014, and as a result, these agreements were updated.  The updated agreements became effective on February 18, 2019, and February 22, 2019, respectively.  The updated agreements with the EC, signed by the European Union (EU), and EFTA also expanded the types of equipment covered under the MRA.

Many of the US, EC and EEA EFTA marine equipment requirements are based on standards and testing specified by the Safety of Life At Sea Convention (SOLAS). Of all the equipment items that were considered, only products having identical or equivalent requirements in each market were included in the scope of the agreement. The two MRA’s original product scope include the same 43 products in three main categories: life saving equipment (e.g. visual distress signals, marine evacuation systems); fire protection equipment (e.g. fire doors, insulation); and navigational equipment (e.g., compasses, GPS equipment, echo-sounding equipment).  The amended agreements expanded the product scope to 69 items, adding additional navigation equipment, position indicating lights, structural fire protection for high speed craft, and other miscellaneous items.

Additionally, 46 CFR Subchapter Q was updated to codify the procedures for obtaining USCG approval under the MRAs in 46 CFR subpart 159.003.  Sections 159.003–3 and 159.003–5 of this subpart specify that the Coast Guard can accept foreign approvals under the MRAs and may issue approvals under the MRAs.