If no deal is agreed between the EU and the UK, continuing airworthiness management organisations (CAMO – Part-M) might need to take action to maximise continuity and stability for the aviation sector. Actions required would depend on individual circumstances and are a matter for each business and individual to consider. This page sets what you need to consider to prepare for such an eventuality.
PART-M CONTINUING AIRWORTHINESS REQUIREMENTS (CAMO) – UK APPROVED
Would my UK Part-M approval allow me to continue manage UK-registered aircraft?
Would my UK Part-M approval allow me to continue managing non-UK registered aircraft?
Would operators require new Certificates of Airworthiness and Airworthiness Review Certificates (ARCs)?
Operators would not require new certificates immediately after exit from the EU as current certificates continue to be recognised under the Withdrawal Act (European Union (Withdrawal) Act 2018). The CAA is looking into how it would replace certificates issued under EASA rules. More information on processes and timing will be available in due course.
Who would issue noise certificates?
If my UK-registered aircraft is managed by a Continuing Airworthiness Management Organisation (CAMO) located in an EASA member state would my ARC remain valid after exit day? Do I have to move my aircraft management to a UK Part-M approved organisation?
Your ARC would remain valid until expiry. You may continue to use a CAMO located in an EASA member state or in a third country if approved by EASA for up to two years following exit day. After this point in time you would need to ensure that your aircraft is managed by a UK approved CAMO organisation.
My maintenance programme is owned/controlled by a CAMO located in an EASA member state. Would the ARC still be valid?
What form of release should be provided for components and services received from UK approved organisations once the UK leaves the EU?
What would the CAA Form 1 look like?
A sample template is available here: CAA Form 1.
As can be seen, the technical information remains unchanged. The form is to be completed in accordance with the existing instructions and AMC/GM with the exception that the Authority information in the header and the Form Reference itself (CAA Form 1 rather than EASA Form 1) will change.
Would an aircraft transferring from an EASA state to the UK need an Export Certificate of Airworthiness issued by the local NAA?
The CAA would continue to accept a valid EASA Certificate of Airworthiness and ARC as transfer documents in place of an Export Certificate of Airworthiness if issued before the UK leaves the EU. Where the ARC is dated after that date, the CAA would require an Export Certificate of Airworthiness.
If an aircraft is transferring from the UK to an EASA state it would be up to the receiving NAA to detail the transfer requirements.
*UPDATE* Will EASA Type Certificates still be recognised for UK registered aircraft?
Yes. A Type Certificate issued, validated or accepted by EASA that is valid at the time when the UK leaves the EU will continue to be valid.
An EASA Type Certificate for aircraft where the State of Design is not an EASA member state (e.g. USA or Canada), will remain valid until such time that the certificate is amended.
The CAA will publish further information regarding how Type Certificates issued by EASA and other countries will be validated once the final EU withdrawal arrangements are known.
With aircraft that currently have an EASA Type Certificate and the State of Design is the UK, responsibility for these certificates will transfer from EASA to the UK immediately upon exit from the EU. These EASA Type Certificates will continue to be valid but will be replaced with a UK certificate in due course.
Could an EU-approved Part-M CAMO manage a UK-registered aircraft and issue/extend an Airworthiness Review Certificate?
How would the UK’s exit from the EU affect the application of Airworthiness Directives for the UK-registered aircraft that I own, operate or manage?
All EU regulations applicable at the point of UK exit would be retained in UK domestic legislation in a no-deal scenario, including Regulation (EU) No 1321/2014, Part M. This means owners, operators and Continuing Airworthiness Management Organisations (CAMOs) would continue to review and apply applicable Airworthiness Directives to their respective fleets based on requirements for the aircraft and its engines, propellers and equipment as set out in CAP 747 Mandatory Requirements for Airworthiness, Airworthiness Directives issued or adopted by EASA, plus any Airworthiness Directives notified by the State of Design.
You can view CAP 747 here: http://publicapps.caa.co.uk/docs/33/CAP747_21JUL17_BM.pdf
Some of the regulation references in CAP 747 have been repealed, typically references to Regulation (EU) 216/2008 concerning EASA and non-EASA aircraft. Where can I find the latest information?
The CAA is aware that CAP 747 currently has some out-of-date references and is in the process of updating the document. Reference to superseded or amended regulations should be taken to mean the current version of the applicable regulation in force. The CAA will ensure any mandatory requirements for UK-registered aircraft are reflected within CAP 747 and also made available via the CAA website Airworthiness Directive page. For enquiries relating to ADs, please email firstname.lastname@example.org
Can an approved Part-M subpart F or Part 145 organisation continue to issue an Airworthiness Review Certificate for ELA1 aircraft?
Yes, if approved by the CAA to issue an Airworthiness Review Certificate, a Part-M subpart F or Part 145 organisation can continue to issue an ARC for UK-registered aircraft.
Organisations approved by EASA or an EASA Member State prior to exit day would be able to continue issue an ARC for UK-registered aircraft for a period of up to two years after the date the UK leaves the EU.
As a Part 66 licenced engineer, I currently have an authorisation that enables me to make recommendations to the CAA for the issue of an Airworthiness Review Certificate for ELA1 aircraft. Could I continue to make recommendations?
An engineer with a Part 66 licence issued by the UK and who is authorised to make recommendations to the CAA for the issue of an ARC could continue for G-registered aircraft only.
An engineer with a Part 66 licence not issued by the UK who is authorised by the CAA to make recommendations to the CAA for the issue of an ARC could continue for G-registered aircraft. The authorisation would only be valid for a period of up to two years after the date the UK leaves the EU.
A licenced engineer with a UK-issued Part 66 licence would no longer be able to hold an authorisation for EU-registered aircraft.