Correct SD, says so on the PCI web site.
They modify they door sill (raised to 11 inches), mod the toe rail, put in three bilge
pumps (2 elect, one manual from the cockpit) enlarge the cockpit drains to 2 inches each and of course wire it for the EU.
There is no reasonable way to modify a non-European modified Gemini to meet CE standards.
All the hype I spout about my Gemini being open ocean category A rated by the CE is just that, hype. The design is capable, it's components are not. Last I heard a new Gemini going to the UK starts at about 170 EU, or 200k as opposed to my 149.5k