The UK-EU trade deal, announced on 24 December 2020, includes agreements on air transport and aviation safety which are due to come into effect at 23.00 GMT on 31 December 2020 when the UK ceases to take part in the EU Aviation Safety Agency (EASA) and other EU institutions.

While the agreements involve some elements of continuity, they do not constitute a replication of the UK’s regulatory arrangements as part of the EASA/EU framework and many sections of the aviation and aerospace industries will face changes after 31 December, as this microsite sets out.

We will study the detail of the new agreements and will update relevant pages of the microsite as information becomes clearer about how the new arrangements will work in practice. We will notify stakeholders of the updates through the SkyWise alert system. If you haven’t already done so, please subscribe to the EU exit category in the SkyWise system: skywise.caa.co.uk

Organisations (Part-M Subpart F) maintaining aircraft might need to take action to maximise stability for the aviation sector. Actions required would depend on individual circumstances and are a matter for each business and individual. This page sets out what you need to consider.

The Technical Implementation Procedures (TIP)

We are aware that organisations across the aerospace enterprise from design and production to maintenance organisations are currently waiting for the Technical Implementation Procedures (TIP) to complement the EU–UK Trade and Cooperation Agreement (the TCA). The TIP will set out how specific elements of the Aviation Safety Agreement Annex on design, production and oversight of the agreement will be implemented.

Colleagues at the CAA and EASA are working hard to negotiate this at present, and we expect it to be finalised within the coming months. In the meantime, we have agreed with EASA and the European Commission interim arrangements to allow for continued mutual recognition of approvals and certificates for production and the recognition of designs approved on or before 31 December 2020. This means the UK and the EU will continue to automatically accept products made on or before 31 December by organisations in product categories accepted within the EASA system. Any new category of product made for export after 1 January 2021 will be subject to a review process before being accepted for import by the other party.

The UK will also, in most cases, accept designs approved by EASA without the need for validation. The particulars of what designs need to be validated are contained within the Air Safety Agreement annex in the TCA, and the means of how they will be validated is being discussed as part of the TIP negotiations.

Until the TIP is signed, in case you have a project to be validated in the EU, please contact EASA directly.

We would like to reassure you that finalising and agreeing the TIP with EASA is our utmost priority.

PART-M SUBPART F MAINTENANCE OF AIRCRAFT – UK APPROVED

Will my organisation approval continue to be valid with the UK outside EASA?

Yes. As a UK-approved Part M Subpart F holder, your approval will remain valid with the same scope of work as previously. There is no need for a new certificate, as it was issued by the UK CAA (not EASA). The UK CAA will arrange for an updated certificate to be issued the next time you change your approval or when the normal two-yearly recommendation is made by the CAA to continue the approval. This will remove the references to EASA.

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Will my organisation continue to be able to certify UK-registered aircraft?

Yes. As a UK-approved Part M Subpart F holder, you will be able to continue to certify UK-registered aircraft as your approval will still be valid.

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Will my organisation continue to be able to certify EU-registered aircraft?

To continue to certify EU-registered aircraft you need to hold an EASA Part M Subpart F approval. Outside EASA, the UK will be considered a third country. EASA has said previously that it will accept third country applications from UK holders of Part M Subpart F approvals. Organisations will need to decide whether, in this scenario, they wish to retain both a national and an EASA approval. Further details regarding the EASA application process can be found on this link. 

A UK Part M Subpart F will be needed to continue to certify UK-registered aircraft.

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My UK-based organisation has applied for a Third Country approval from EASA. Will EASA accept UK Part 66 licences to support the approval?

Part M Subpart F does not have the same provisions as Part 145 to use non-EASA licences to support an approval issued in Third Countries. You are advised to contact EASA as soon as possible to discuss this.

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How can my organisation continue to maintain/certify non-UK registered aircraft?

Your organisation will need to apply for an EASA approval if it intends to maintain aircraft registered in the EASA member states. Other non-European states of registry may accept CAA-issued approvals.

You are advised to contact EASA or the State of Registry NAA as soon as possible to discuss the application process in this scenario.

EASA has said previously that it will accept third country applications from UK holders of Part M Subpart F approvals. Organisations will need to decide whether they wish to retain both a national and an EASA approval: https://www.easa.europa.eu/brexit

The CAA will continue to recognise EASA certificates current and valid on 31 December 2020 for an initial period of up to two years.

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If my company has an approval to maintain aircraft registered outside the EASA Member States, will it continue to be valid?

This is a decision for the National Aviation Authority of the state of registry. Please contact the specific NAA directly as soon as possible.

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Will I be able to continue to issue EASA Form 1 certificates under my UK approval?

You will no longer be able to issue EASA Form 1 certificates. The UK will issue CAA Form 1 certificates independent of the EASA system.

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) is changed.

A word version of the new UK form is available here: CAA Form 1

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What will 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.

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UPDATE: Could I fit a component released under an EASA Form 1 or equivalent to a UK-registered aircraft?

Yes, these components could continue to be fitted to a UK-registered aircraft, subject to the following limitations:

  • Components released on an EASA Form 1 before 1 January 2021 can continue to be fitted until 31 December 2022
  • Components released on an EASA Form 1 after 31 December 2020 issued by organisations located outside of the UK can continue to be fitted subject to the conditions listed in ORS4 No.1452 here

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If my company employs Part 66 certifying staff with UK-issued Part 66 licences, can they continue to certify under my UK M Subpart F approval?

Yes, they can continue to certify under a UK approval. The UK-issued Part 66 licence will remain valid, and there is currently no need for re-issue of the licence.

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If my company employs Part 66 certifying staff with non-UK issued Part 66 licences in the UK, can they continue to certify under my UK M Subpart F approval?

Yes, they can continue to certify under the UK approval, for a period of up to two years. After that, the engineer will need to obtain a licence from the CAA. The CAA will provide an application process for EU licence holders to apply for a UK licence.

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PART-M SUBPART F MAINTENANCE OF COMPONENTS & SPECIALISED SERVICES – UK APPROVED

Will my organisation approval remain valid with the UK outside EASA?

Yes. As a UK-approved Part M Subpart F holder your approval will remain valid with the same scope of work as previously. There will be no need for a new certificate as the existing one was issued by the UK CAA, not EASA. The UK CAA will arrange for an updated certificate to be issued the next time you change your approval or when the normal two-yearly recommendation is made by the CAA to continue the approval. This will remove the references to EASA.

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Will I be able to continue to issue EASA Form 1 certificates under my UK CAA approval?

You will no longer be able to issue EASA-approved Form 1 certificates. The UK will issue Form 1 certificates independent of the EASA system.

A template of the new UK CAA Form 1 is available here: CAA Form 1

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UPDATE: Will CAA Form 1 certificates issued by CAA-approved organisations be accepted by EASA for use on EU-registered aircraft?

Under the terms of the UK-EU trade and cooperation agreement, a CAA Form 1 issued by a CAA-approved Production Organisation* will be accepted. A CAA Form 1 issued by CAA approved Maintenance Organisations will not be accepted.

Note: * A CAA form 1 issued under a production approval will have Block 13 completed and Block 14 greyed out.

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UPDATE: Can I still use parts released under EASA Form 1 to complete maintenance, repairs and/or modifications to components?

Yes, these components can continue to be fitted to a component released under a CAA Form 1 subject to the following limitations:

  • Components released on an EASA Form 1 before 1 January 2021 can continue to be fitted until 31 December 2022
  • Components released on an EASA Form 1 after 31 December 2020 issued by organisations located outside of the UK can continue to be fitted subject to the conditions listed in ORS4 No.1452 here
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PART-M SUBPART F MAINTENANCE OF AIRCRAFT BY ORGANISATIONS LOCATED OUTSIDE THE UK

UPDATE: Will my organisation be able to certify UK-registered aircraft?

From the 1 January 2021 EU/EASA approved maintenance organisations must transition to using CAA Decision No. 3 or gain a UK approval to enable the release of a UK-registered aircraft.

Only an aircraft maintenance organisation that has its principal place of business outside the UK may use CAA Decision No. 3.

The CAA considers that an organisation operating in this way is acting in accordance with “Practice 3” of the EASA document dated 20 March 2013.

Please note that UK operators may insist that their maintenance providers obtain approval from the CAA as part of their commercial arrangements. This is at the discretion of the operator. For organisations wishing to apply for an approval by the CAA, please see the third country application page on the CAA website for further details.

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PART-M SUBPART F  MAINTENANCE OF COMPONENTS & SPECIALISED SERVICES BY ORGANISATIONS LOCATED OUTSIDE THE UK

Would my organisation still be able to issue an EASA Form 1 to a product or component that has either been removed from or to be fitted to a UK- registered aircraft?

Yes, as the current EASA system allows for components removed from non-EU aircraft to be maintained and released with an EASA Form 1 providing the component conforms to EASA maintenance/design data.

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AIRWORTHINESS DIRECTIVES

How does the UK leaving EASA affect the application of Airworthiness Directives for the UK-registered aircraft that I own, operate or manage?

All EU regulations current and valid on 31 December 2020 are retained in UK domestic legislation, including Regulation (EU) No 1321/2014, Part M. This means owners, operators and Continuing Airworthiness Management Organisations (CAMOs) must 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. 

Issue 4 of CAP 747 has been updated to reflect the new UK-EU framework. 

Section 1, Part 1 provides new flowcharts to assist in identifying the applicable mandatory requirements for airworthiness relating to your product. The revision history in CAP 747 provides more details on the changes to the CAP.

You can view CAP 747 here: www.caa.co.uk/CAP747 

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With the UK outside EASA, has the classification of aircraft in CAP 747 changed?

Issue 4 of CAP 747 has been published to reflect the new UK-EU regulatory arrangements.

Each aircraft type is categorised as either:

  • a “Part 21 aircraft”; an aircraft that is included in the scope of Regulation (EU) 2018/1139 (as retained by The European Union (Withdrawal) Act 2018); or
  • a “non-Part 21 aircraft”; an aircraft that is subject to the Air Navigation Order.

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 ad.unit@caa.co.uk

 

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