Sofema Aviation Services (SAS) reviews the EASA Certification Validation Process across multiple Regulatory Environments.
Introduction
To consider how the European Union Aviation Safety Agency (EASA) validates aircraft from the three major non-European States of Design: the USA (Boeing/FAA), Canada (Bombardier/TCCA), and Brazil (Embraer/ANAC).
It is critical to distinguish between the legal framework (which is highly harmonized among these four authorities) and the operational reality (which varies based on geopolitical context, risk appetite, and recent historical events like the 737 MAX grounding).
The Regulatory Framework: BASA & TIP
All three validation paths are governed by a Bilateral Aviation Safety Agreement (BASA) between the EU and the respective country. The operational details are defined in the Technical Implementation Procedures (TIP).
The Goal:
To avoid duplicating certification activities. The “Validating Authority” (VA-in this case, EASA) relies on the “Certificating Authority” (CA-FAA, TCCA, or ANAC) to the maximum extent possible.
The Certification Management Team (CMT):
These four authorities (EASA, FAA, TCCA, ANAC) form the “Big Four” and meet regularly to harmonize these TIPs. Consequently, the written procedures are nearly identical.
The Core Concept: Risk-Based Validation (LoI)
The modern validation standard across all three is Risk-Based Validation using the Level of Involvement (LoI) concept. EASA no longer re-checks everything. Instead, they filter the project through three buckets:
• Reciprocal Acceptance: No application to EASA required (e.g., TSOs, minor repairs).
• Streamlined Validation (“Basic”): EASA issues a certificate based solely on the CA’s certification, with no technical deep-dive (administrative only).
• Technical Validation (“Non-Basic”): EASA retains technical scrutiny. The scope of this scrutiny is the Level of Involvement (LoI), determined by a risk assessment.
Comparative Analysis: Execution by Authority
While the rules are similar, the execution differs due to the maturity of the relationship, the complexity of the aircraft, and historical friction points.
FAA (Boeing) \ EASA
Governing Doc: EASA-FAA TIP (e.g., Revision 6/7)
Status: Highly Formalized, “Trust but Verify” (Post-MAX).
The “MAX Effect”:
Prior to the 737 MAX accidents, EASA-FAA validation was moving toward extremely low involvement. Post-MAX, the pendulum swung back. For new Boeing programs (e.g., 777X), EASA exercises a significantly higher Level of Involvement (LoI) in critical areas (flight controls, avionics, human factors) than it might for TCCA or ANAC.
Validation Items (VIs):
EASA will raise VIs on Safety Emphasis Items (SEIs). These are specific systems where EASA standards differ slightly or where EASA perceives a higher safety risk (e.g., Crew Alerting Systems).
Conflict Resolution:
Due to the sheer size of the industries (Airbus vs. Boeing), technical disagreements can occasionally escalate to political levels. The TIP includes a robust “Issue Resolution Mechanism” to handle these impasses.
Key SME Takeaway:
For Boeing aircraft, do not expect “automatic” trust on critical systems anymore. EASA now demands independent verification of safety assessments for critical flight control laws.
TCCA (Bombardier) \EASA*
Governing Doc: EASA-TCCA TIP
Status: High Trust, Streamlined, “The Gold Standard.”
Harmonization:
TCCA and EASA regulations are historically very close. There is less friction regarding “philosophical” differences in certification (unlike the occasional FAA vs. EASA debates on pilot interaction with automation).
Efficiency:
SMEs often regard the TCCA-EASA path as the most efficient. A significant portion of STCs and even some significant major changes are processed as “Basic” (Streamlined) with minimal EASA delay.
Generic Validation Items (GVIs):
These are standard lists of items EASA always checks for Canadian products (e.g., specific cold weather operations or hydromechanical distinctives), but they are well-understood and predictable.
Key SME Takeaway:
The process is highly predictable. Unless the design is radically novel, EASA typically accepts TCCA’s compliance findings with very low LoI.
(Note: This now also applies to the Airbus A220, formerly C-Series, though as an Airbus product, the integration is even tighter).
ANAC (Embraer)\ EASA
Governing Doc: EASA-ANAC TIP (Revision 5 is the modern risk-based standard)
Status: Mature, Specialized, Rapidly Harmonizing.
Evolution:
Historically, EASA scrutinized ANAC more heavily than the FAA or TCCA. However, the latest TIP revisions (Rev 5) have officially aligned ANAC with the FAA/TCCA “Risk-Based” model.
Concentration Risk:
Unlike the US or Canada, where the CA oversees hundreds of design organizations, ANAC’s primary heavy-iron interactions with EASA are almost exclusively Embraer. This creates a very focused, expert-to-expert relationship regarding specific Embraer platforms (E-Jets, E2).
Specifics:
EASA pays close attention to Significant Standards Differences (SSD). While ANAC has adopted many US-style regulations (RBACs are close to FARs), EASA will retain LoI where European operational rules (e.g., noise, steep approach) are stricter.
Key SME Takeaway:
The “gap” between ANAC validation and FAA/TCCA validation has largely closed. EASA now treats ANAC as a peer CA, utilizing the same LoI tools to minimize redundant testing.
Step-by-Step Validation Process (Non-Basic)
For a “Non-Basic” project (e.g., a new Type Certificate like the 777X or E195-E2), the process follows these sequential gates:
1. Application
OEM submits application to their CA (FAA/TCCA/ANAC), who forwards it to EASA.
EASA will not accept applications directly from Boeing or Embraer; it must come via the CA.
2. Familiarization
EASA team meets OEM/CA to understand the design.
EASA identifies Novel or Unusual Features (e.g., folding wingtips, new composites).
3. Classification
EASA classifies as “Basic” (Streamlined) or “Non-Basic” (Technical).
New TCs are always Non-Basic.
4. Certification Basis
EASA establishes the EASA Certification Basis.
This is the list of CS (Certification Specifications) the aircraft must meet. EASA checks for SSDs (Significant Standards Differences) compared to the CA’s basis.
5. Work Plan (LoI)
CRITICAL STEP. EASA defines exactly what it will check.
EASA issues a Validation Work Plan defining the LoI. They may choose to witness 5% of tests and trust the CA for 95%.
6. Compliance
OEM demonstrates compliance to CA; CA demonstrates compliance to EASA for the items in the Work Plan.
EASA engineers review reports and may fly the aircraft (Validation Flight Test).
7. Final Statement
CA issues a “State of Design” statement.
“The aircraft meets the EASA Certification Basis.”
8. Issuance
EASA issues the Type Certificate (TC).
Summary Matrix
Primary Agreement
US-EU BASA / TIP | Canada-EU BASA / TIP | Brazil-EU BASA / TIP
Trust Level
High, but currently under “Recovering” status (Post-MAX).
Very High / Seamless.
High / Peer-Level (Aligned via TIP Rev 5).
EASA Scrutiny (LoI)
Medium/High: Focus on complex automation & safety assessments.
Low: Focus on novelties only.
Low/Medium: Focus on SSDs and environmental specs.
Friction Points
Human Factors, Flight Control Software.
Few (mostly specific cold-weather/icing specs).
Noise certification, specific operational capabilities.
Validation Speed
Slower for complex projects due to higher LoI.
Fast / Predictable.
Fast (highly specialized teams).
Next Steps
Sofema Aviation Services (SAS) and Sofema Online (SOL) Provide Classroom, Webinar & Online training please see the websites email [email protected]
Tags:
Bilateral Aviation Safety Agreement (BASA), Technical Implementation Procedures (TIP), Level of Involvement (LOI), Certification Validation Process, Regulatory Environments, Boeing/FAA, Bombardier/TCCA, Embraer/ANAC, historical friction points, Safety Emphasis Items (SEIs), Unusual Features
