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Airworthiness review of aircraft imported into the EU


M.A.904(a) Importing procedures

(a) When importing an aircraft onto a Member State register from a third country or from a regulatory system where Regulation (EU) 2018/1139 does not apply, the applicant shall:

1. apply to the competent authority of the Member State of registry for the issuance of a new airworthiness certificate in accordance with Annex I (Part-21) to Regulation (EU) No 748/2012;

AMC M.A.904(a)(1) Competent authority communication

In order to allow for possible participation of authority personnel, the applicant should inform the competent authority at least 10 working days in advance of the time and location of the airworthiness review.

2. for aircraft other than new, have an airworthiness review carried out in accordance with point M.A.901;

AMC M.A.904(a)(2) Work to be undertaken to establish airworthiness

1. When performing an airworthiness review of aircraft imported into the EU the aircraft and the relevant records should be reviewed to determine the work to be undertaken to establish the airworthiness of the aircraft.

2. In determining the work to be undertaken during the airworthiness review on the aircraft, the following should be taken into consideration:

(a) the information from third country authorities such as export certificates, primary authority information;

(b) the information on aircraft maintenance history such as continuing airworthiness records, aircraft, engine, propeller, rotor and life limited part log books or cards as appropriate, tech log/flight log/cabin log, list of deferred defects, total flight times and cycles, times and cycles since last maintenance, accident history, former maintenance schedule, former AD compliance status;

(c) the information on aircraft such as aircraft, engine and propeller type certificate datasheets, noise and emission certificate data sheets, flight manual and supplements;

(d) the aircraft continuing airworthiness status such as the aircraft and component AD status, the SB status, the maintenance status, the status of life-limited parts and time-controlled components, weight and centre of gravity schedule including equipment list;

(e) the modification and repair status of the aircraft detailing elements such as owner/operator designed modifications and repairs, STCs, and parts needing European parts approval (EPA);

(f) the aircraft cabin configuration such as emergency equipment fitted, cockpit configuration, placards, instrument limitations, cabin layout;

(g) the maintenance needed for import, such as embodiment of modifications needed to comply with the EASA type certificate, bridging check to comply with the new maintenance programme;

(h) the avionics such as, but not limited to, radio and navigation equipment, instrument flight rules (IFR) equipment, digital flight data recorder (DFDR)/cockpit voice recorder (CVR) test, emergency locator transmitter (ELT) 406 MHz code and identification;

(i) the compass compensation;

(j) special operating rules such as extended twin-engine operations (ETOPS)/long range operations (LROPS), reduced vertical separation minima (RVSM), minimum navigation performance specifications (MNPS), all weather operations (AWOPS), area navigation (RNAV);

(k) the aircraft survey including verification of conformity with the flight manual and the datasheet, presence of fire proof identification plates, conformity of markings including registration, presence and serviceability of emergency equipment, internal and external lighting systems, and

(l) maintenance check flight including check of control system/cockpit ground check/engine run up.

3. If there is no CAMO or maintenance organisation approved for the airworthiness review of the specific aircraft type available, the competent authority may carry out the airworthiness review in accordance with this paragraph and the provisions M.A.901(g) and M.B.902. In this case, the airworthiness review should be requested to the competent authority with a 30-day notice.

3. have all maintenance carried out to comply with the AMP approved in accordance with point M.A.302.

M.A.904(b) ARC recommendation

(b) When satisfied that the aircraft is in compliance with the relevant requirements, the organisation performing the airworthiness review, shall send a documented recommendation for the issuance of an airworthiness review certificate to the competent authority of the Member State of registry.

AMC M.A.904(b) Content of recommendation

The recommendation sent to the competent authority should contain at least the items described below.

(a) All the information set forth by AMC M.A 901(d)

(b) Aircraft information

— aircraft assigned registration;
— state of manufacturer;
— previous registration;
— export certificate number;
— TC and TC data sheet numbers;
— noise and emissions TC and TC data sheet numbers;
— comparison of prior maintenance programme with the proposed new maintenance programme.

(c) Documents accompanying the recommendation

— copy of the application;
— original export certificate;
— copy of the approvals of the flight manual and its supplements;
— list of ADs incorporated up to the latest published issue;
— proposed new maintenance programme;
— status of all life-limited parts and time-controlled components;
— the valid weight and centre of gravity schedule reflecting the current configuration of the aircraft, and;
— Part-21 approval reference for all modifications and repairs.

(d) Maintenance
— a copy of the work packages requested by the CAMO including details of any bridging check to ensure all the necessary maintenance has been carried out.

(e) Aircraft maintenance check flight
— a copy of the maintenance check flight report.

M.A.904(c) Competent authority access

(c) The owner of the aircraft shall allow access to the aircraft for inspection by the competent authority of the Member State of registry.

M.A.904(d) ARC issuance

(d) The competent authority of the Member State of registry shall issue an airworthiness certificate when it is satisfied that the aircraft complies with the requirements of Annex I (Part-21) to Regulation (EU) No 748/2012.

M.A.904(e) ARC validity

(e) That competent authority of the Member State shall also issue the airworthiness review certificate. The certificate shall be valid for 1 year, unless the competent authority decides to reduce the period of validity for reasons of aviation safety.

Are EASA Forms 1 required during the import in the EU of an aircraft subject to Part-M?

For the import of an aircraft in the EU under Part-M regime, the provisions of M.A.904 require the accomplishment of an airworthiness review in accordance with point M.A.901.

Note: AMC M.A.904(a)(2) defines specific elements to be considered for imported aircraft.

However, when performing the airworthiness review of an imported aircraft in accordance with point M.A.901 and its AMC, it may happen that ‘AMC M.A.901(k)’ is not fully satisfied in which certain components subject to the review may not hold an EASA Form 1 (or equivalent under a bilateral agreement) In such a case, other component releases to service or serviceable tags may be acceptable for the competent authority of the importing Member State.

Nevertheless, it is important to ensure that the information required by M.A.305(c) and (d) related to the status of ADs, life accumulated by life-limited parts and time-controlled components, modifications and repairs is available.
Updated on 23/06/2021

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