EU-Exit - Savings Provisions – EASA Form 1

Nov 2021

Agenda

Welcome and introductions

Background

Savings Provisions and EASA Form 1’s

EASA Form 1 – Current Requirements

EASA Form 1 – Additional Requirements from Apr 2022

EASA Form 1 – Actions Required

EASA Form 1 – Guidance

Additional Guidance

Summary

Q&A

Welcome and Introductions

Introduction

Julia Ogiehor – External Relations Manager,

CAA

Mark Panton – Airworthiness Manager

Steve Horton – Airworthiness Policy Lead

• Team Intro’s

• Logistics

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Email: Your Allocated Surveyor

Background

The European Union Withdrawal Act & The Aviation Safety (Amendment etc.) (EU Exit) Regulations 2019 Statutory Instrumentexemptions (savings provisions) that allowed for certain EU aviation certificates issued before the end of 2020 to remain valid in the UK aviation system.

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The validity of these certificates ends on 31 December 2022 in the absence of any additional annexes to the UK/EU TCA Aviation Safety Annex being agreed between the UK Government and EU Commission.

This means that non-UK based holders of Part 145, Part 147, Part CAMO and Part CAO certificates will require UK approvals from the CAA to continue providing services to, and supplying, UK industry. The majority of these UK approvals will be required from 1st January 2023.

Exemptions and EASA Form 1s

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However, the exemptions do not cover EASA Form 1s as they are issued by organisations.

Therefore the 2-year recognition period does not apply.

To prevent disruption to the industry, the DfT and the CAA agreed (via two exemptions) to allow for the continued recognition of EASA Form 1s until March 2022 to bring EU/EASA organisations into the UK system with full UK approvals before the end of the 2-year recognition period.

EASA Form 1s- Current Requirements

Two exemptions currently support the continued acceptance of EASA Form 1s within the UK system:

• ORS4 No.1515: Continued Recognition of Authorised Release Certificates issued on an EASA Form 1 on or after 1 January 2021 by Organisations and Individuals Licensed or Approved by the Federal Office of Civil Aviation of Switzerland (FOCA) (caa.co.uk) (Previously ORS4 No 1451)

• ORS4 No.1516: Continued Recognition of Authorised Release Certificates issued on an EASA Form 1 on or after 1 January 2021 (caa.co.uk) (Previously ORS4 No 1452)

Note1: without these exemptions, EU/EASA organisations would be required to hold CAA approvals from 1st January 2021.

Note2: EASA Form 1s issued by an EU/EASA approved production organisations for new engines or components can continue to be accepted without restriction in accordance with the UK/EU Trade and co-operation agreement.

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EASA Form 1s- Additional Requirements from April 2022

These exemptions will require additional requirements from 01 April 2022: an extract from the exemptions is listed below:

For these exemptions to continue to apply after 31 March 2022, the organisation issuing the EASA Form 1 must have applied to the CAA for an equivalent UK approval before that date.

Therefore EU/EASA approved maintenance organisations who wish to continue issuing EASA Form 1s that are valid in the UK system from 1 April 2022 will need to have applied for a UK approval by 31 March 2022.

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EASA Form 1s issued after 1 Jan 2021

The exemptions also allow any EASA Form 1s issued by such organisations after 1 January 2021 but before 31 March 2022 to remain acceptable within the UK system without any application to the CAA.

UK operators will therefore not be required to send back components for the reissuing of certificates.

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EASA Form 1s- Action Required (1)

All owners/operators/CAMO’s or maintenance organisations managing or certifying UK G-registered aircraft respectively are required to:

1) Inform all suppliers of engines, components and equipment where an EASA Form 1 is provided as the release documentation for maintenance that they must apply for a UK approval before 31 March 2022.

2) Inform contracted maintenance organisations that before accepting an item for fitment to an UK G-registered aircraft they must comply with the additional requirements of the exemption.

Note: Fitment of an item which does not comply with the additional requirements from the exemption will result in a non-compliance with the regulations, invalidating the Certificate of Airworthiness.

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EASA Form 1s- Action Required (2)

To support suppliers of engines, components and equipment where an EASA Form 1 is provided as the release documentation for maintenance, an online application page is available where they can apply quickly to enable them to continue to supply to the UK market, the page can be found at the following location:

Apply for a third country airworthiness approval | UK Civil Aviation Authority (caa.co.uk)

A list of organisations that have applied for UK approval will be made available online to help businesses make decisions on which items for fitment on a UK G-registered aircraft can be accepted. The list of organisation can be found on our webpage titled ‘Pending Organisations’:

List of approved organisations | UK Civil Aviation Authority (caa.co.uk)

Note: this webpage also provides the listing of ‘Approved Organisations - Part 145 (Overseas)’ who should be providing CAA Form 1s to the UK as they have full UK approvals and therefore should not be supplying EASA Form 1’s for use on UK G Registered aircraft.

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EASA Form 1- Acceptance Tables

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Certificate Issuance Date Acceptability Legislation Comments

2020 and Before Acceptable SI Saving Provisions, Schedule 3

2021/Q1 2022 (Jan to Mar) Acceptable Exemption 1515/1516 Acceptability not affected by time or exemption

additional requirements.

From Apr 2022 Partial Acceptance Exemption 1515/1516 To accept certificate, a UK Part 145 approval

application must be made to CAA by EU/EASA Org

releasing component post maintenance.

EASA Form 1 Acceptance, including Timelines:

Status of EU/EASA Org Acceptability Comments

Application made to CAA Acceptable Details provided on CAA website or application receipt

No Application made to CAA Not Acceptable No application has been made and therefore outside exemption requirements

CAA Approval Granted to EU/EASA Org Not Acceptable Post issuance of CAA UK approval therefore org needs to issue CAA Form 1.

For EASA Form 1 Acceptance from April 2022 where the certificate was issued after Apr 2022:

EASA Form 1- Guidance

We have provided additional guidance related to this subject in the following documents or webpages:

• International cooperation | UK Civil Aviation Authority (caa.co.uk) - UK component acceptability table

• CAP 2009 - Airworthiness Flow charts

Along with the Exemptions:

• ORS4 No.1515: Continued Recognition of Authorised Release Certificates issued on an EASA Form 1 on or after 1 January 2021 by Organisations and Individuals Licensed or Approved by the Federal Office of Civil Aviation of Switzerland (FOCA) (caa.co.uk)

• ORS4 No.1516: Continued Recognition of Authorised Release Certificates issued on an EASA Form 1 on or after 1 January 2021 (caa.co.uk)

• Note: EASA Form 1s issued by a EU/EASA approved Production organisation for a new Engine or Component can continue to be accepted without restriction in accordance with the UK/EU Trade and co-operation agreement.

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Additional Exemption Guidance

We have provided various exemptions to support industry and individuals you should be aware of:

• ORS4 No.1507: Holders of Part-145, Part CAO or Part M subpart F Organisation Approvals Certificates Amended by EASA Member States after 31 December 2020 (caa.co.uk)

• ORS4 No.1506: Holders of Part-147 Organisation Approval Certificates amended by EASA or EASA Member States after 31 December 2020 (caa.co.uk)

• ORS4 No.1505: Holders of Part-66 Licences; Issued by EASA Member States after 31 December 2020 (caa.co.uk)

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Summary

From 1 April 2022, UK organisations will no longer be able to accept EASA Form 1s as an acceptable certificate for the certification of maintenance on engines and/or components from an EU/EASA organisation that have not applied to the CAA by 31 March 2022.

UK owners, operators, CAMOs and maintenance organisations are encouraged to share this information with their EU/EASA approved organisations within their supply chain to ensure these organisations apply for a UK approval or alternatively find another supplier who has a UK approval or has applied for a UK approval, a list of which can be found on the CAA’s webpage.

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Thank YouQ&A