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

Continuing airworthiness management organisations (CAMO – Part-M) 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.

Update - The UK CAA has developed a flowchart pack to aid Airworthiness organisations in understanding what certification can be accepted once UK participation in EASA and EU institutions ends on 31 December 2020.

PART-M CONTINUING AIRWORTHINESS REQUIREMENTS (CAMO) – UK APPROVED

Will my UK Part-M approval allow me to continue managing non-UK registered aircraft?

You will only be able to manage non-UK-registered aircraft if you are approved by the state of registry or EASA for aircraft registered in the EASA Member states.

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UPDATE: Will operators require new Certificates of Airworthiness and Airworthiness Review Certificates (ARCs)?

Operators will not require new certificates immediately as current certificates will continue to be recognised under the European Union (Withdrawal) Act 2018.

Replacement CoAs will be issued during 2021. ARCs will be updated at the next issue of the certificate.

To minimise the risk of disruption, we are making a letter available to all operators confirming the validity of these documents for carriage on UK aircraft. This letter should be carried onboard the aircraft at all times. We have also communicated to all National Aviation Authorities the legal basis for this decision. The letter (CAP2019) is available on the 'Downloads' tab of this microsite.

CAP2080 has been published to provide guidance for Continued Airworthiness Management Organisations (CAMO) with an EASA Part M approval which have their Principal Place of Business located outside of the UK to manage UK-registered aircraft and to issue or extend the validity of their Airworthiness Review Certificate. This is available from the CAA publications website.

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Who will issue noise certificates?

These will be issued by the UK CAA.

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If my UK-registered aircraft is managed by a Continuing Airworthiness Management Organisation (CAMO) located in an EASA member state will my ARC remain valid? Do I have to move my aircraft management to a UK Part-M approved organisation?

Your ARC will remain valid until expiry.

An EU organisation with an EASA MG or Pt CAMO approval will only be able to manage a G- registered aircraft if their approval (and the applicable aircraft type) was in place prior to 1 January 2021, and only for the recognition period. If not, or following the recognition period, the organisation will need to obtain a UK Pt CAMO approval to manage a UK-registered aircraft.

Note: when an organisation transitions to a Part CAMO after 31 December 2020 this constitutes a new approval, at which point an EASA approved organisation can no longer issue/extend an ARC or manage a UK aircraft.

 

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My maintenance programme is owned/controlled by a CAMO located in an EASA member state. Will the ARC still be valid?

Your maintenance programme approval will remain valid if it was approved prior to 1 January 2021. Any subsequent amendments will need to be approved by the CAA or by an organisation approved by the CAA.

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What form of release should be provided for components and services received from UK-approved organisations?

UK-approved production and maintenance organisations will issue UK Form 1s for both the components and services they provide. Member states will continue to issue EASA Form 1s.

Note: EASA Form 1s issued by TCOs with a principal place of business in the UK cannot be issued for parts to be installed on a UK-registered aircraft.

 

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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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Will an aircraft transferring from an EASA state to the UK need an Export Certificate of Airworthiness issued by the local NAA?

Following the UK-EU Trade agreement an aircraft being imported into the UK from a European Country will still require a valid transfer document. For European aircraft transferring into the UK, this will be an Export Certificate of Airworthiness

For UK aircraft transferring to Europe, the EU member state will regard the aircraft as an import from a third country and M.A. 904, as applied in EU law, will apply.

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Will EASA Type Certificates still be recognised for UK-registered aircraft?

A Type Certificate issued, validated or accepted by EASA that was valid at the time this scenario came into effect 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 post-transition period 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 after 31 December 2020. These EASA Type Certificates will continue to be valid but be replaced with a UK certificate in due course.

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Can an EU-approved CAMO manage a UK-registered aircraft and issue/extend an Airworthiness Review Certificate?

A CAMO approved by EASA or an EASA Member State prior to 1 January 2021 will be able to manage UK-registered aircraft and issue/extend ARCs for up to two years as long as the applicable aircraft type was on the organisation's approval prior to that date. 

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How will the UK’s exit from 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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Can an approved Part-M subpart F or Part 145 organisation continue to issue an Airworthiness Review Certificate for Part ML 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 this scenario coming into effect will be able to continue issue an ARC for UK-registered aircraft for a period of up to two years.

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Who can I sub-contract continuing airworthiness tasks to?

Nothing will change. Organisations carrying out sub-contracted Part M tasks may continue to perform these tasks as the work is being carried out under the approval/quality system of the CAMO organisation. (M.A.711).

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What will happen with the BCAR approval system for those holding both Part 145 and A8-23 or Part M and A8-25?

Nothing will change, Organisations that currently hold a Part 145 and A8-23 and/or Part M and A8-25 approvals will continue to exercise those approvals on UK- registered aircraft while they remain valid.

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After 31 December 2020, how will EASA's NPAs be implemented?

EU legislation that is in force and in effect on 31 December 2020 will form part of UK domestic law from 1 January 2021.

From 1 January 2021, the UK will be responsible for the development of its aviation safety policy and regulation. There will be an annual, published programme of change derived from a prioritisation of the various demands that exist.

Any future changes to the EASA Regulations will not be automatically taken, any proposed changes may be considered on their merit.

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UPDATE: As a CAMO managing UK registered aircraft, what do I need to consider from my Part 145 organisation/s?

You will need to consider whether the Part 145’s support certifying staff hold an appropriate licence.

You will need to confirm whether the Part 145 had the applicable type on their scope of approval prior to 31 December 2020.

For EASA-approved Part 145 organisations who have their Principle Place of Business (PPOB) outside the United Kingdom, Practice 3 methodology (EASA Reference 2013 (D) 51397) can be used, upon agreement with the NAA for the EASA approved Part 145 organisation. This allows an EASA approved Part 145 organisation to use their approval number to release the aircraft in accordance with state of registry regulations and legislation. Approvals issued by EASA to Part 145 organisations with a principal place of business in the UK cannot release a UK-registered aircraft using Practice 3. Approval by the CAA is required.

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 PPOB 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.

For further details see CAA decision 3 ORS9 - CAA Decision No 3: Decision enabling an approved maintenance organisation located outside the UK to perform the release to service of an aircraft registered in the UK, after Exit day

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Do I need to make changes to the CRS in the technical log?

No changes are required to the technical log. However, organisations using EASA approved Part 145 organisations may wish to update the CRS statement to recognise the use of Practice 3.

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What changes do I need to make to my CAME?

For organisations with Subpart I privilege, Form 15b or 15c will need to be updated to be a UK Form 15b or 15c.

Review the work being carried out by your organisation to understand the processes and procedures affected by the end of the transition period. Examples of changes to CAME documentation that will be required include:

  1. acceptability of data for modifications and repairs (TCs/STCs etc);
  2. process for identifying applicable ADs;
  3. acceptability of components for fitment to UK registered aircraft (Form 1s etc);
  4. a review of MROs, considering their control procedure for support and certifying staff, the impact of using an EU approved MRO.
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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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