Following the UK’s exit from the EU on 31 January, a transition period will apply until 31 December 2020. During this period, the UK and the aviation sector will continue to follow EU law and to participate in the European Aviation Safety Agency (EASA) system. As a result, businesses and individuals operating in the UK should see no change to existing conditions during the transition period, while the longer-term UK-EU relationship on aviation is determined. Please see the homepage for further details.

A fuller outline of the position as the UK enters the transition period is available here. While the respective positions outlined in the UK Government and EU negotiating mandates indicate what both sides want in terms of future agreements on air transport and aviation safety and security, the conditions that will exist after the end of the transition period are still uncertain. Given this uncertainty, the FAQ information below should not be regarded as exhaustive and will be subject to change.

As the UK-EU negotiations move forward and more information becomes available, the CAA will update these FAQs and 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

After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, 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 out 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 managing non-UK registered aircraft?

You would 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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Would operators require new Certificates of Airworthiness and Airworthiness Review Certificates (ARCs)?

After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, operators would not require new certificates immediately as current certificates would continue to be recognised under the 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.

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Who would issue noise certificates?

These would 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 would my ARC remain valid? Do I have to move my aircraft management to a UK Part-M approved organisation?

Your ARC would remain valid until expiry. After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, you may for up to two years continue to use a CAMO located in an EASA member state or in a third country if approved by EASA. After this point in time you would need to ensure that your aircraft is managed by a UK-approved CAMO organisation.

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

After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, your maintenance programme approval would remain valid if it was approved prior to this scenario coming into effect. Any subsequent amendments would 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?

After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, UK-approved production and maintenance organisations would issue UK Form 1s for both the components and services they provide. Member states would continue to issue EASA Form 1s.

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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.

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

After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, 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 this scenario came into effect. 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.

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

After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, 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 would transfer from EASA to the UK immediately this scenario came into effect. These EASA Type Certificates would continue to be valid but would be replaced with a UK certificate in due course.

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

After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, a Part-M CAMO approved by EASA or an EASA Member State prior to this scenario taking effect would be able to manage UK-registered aircraft and issue/extend ARCs for a period of up to two years.

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How would the UK’s exit from EASA affect the application of Airworthiness Directives for the UK-registered aircraft that I own, operate or manage?

After the UK’s membership of the EASA system ceases at the end of the transition period and if there is no mutual recognition of safety certificates between the UK and European systems, all EU regulations applicable at the time this scenario came into effect would be retained in UK domestic legislation, 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: www.caa.co.uk/CAP747 

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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 ad.unit@caa.co.uk

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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 would be able to continue issue an ARC for UK-registered aircraft for a period of up to two years.

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