September 19, 2025

Steven Bentley

GCAA Logistics plays a central role in understanding the regulatory contrasts between EASA Part-145 and UAE CAR-145. This article highlights key differences in areas such as Form 1 acceptance, PMA parts, and supplier control, with a focus on requirements for stores and materials management.

Form 1 – GCAA is more explicit and broader: CAR-145 lists an expanded set of “AW Form 1 or equivalent” documents it will accept, including UK CAA Form 1, legacy JAA Form One, FAA 8130-3, TCCA Form One, TC-holder certificates, plus “any other equivalent” acceptable to GCAA.

  • EASA does not enumerate that list inside Part-145; instead, it requires organisations to verify accompanying documentation is acceptable under 145.A.42(a) and to perform incoming inspections—it’s principle-based rather than a named list of foreign forms within 145.A.42 AMC/GM.

FAA PMA parts – GCAA explicitly allows PMA parts subject to conditions (8130-3 issued, non-critical status, and/or inclusion in TC holder IPC/maintenance data or an STC approved by GCAA; CAMO must authorise their use). This creates a defined route for PMA usage by UAE operators and their AMOs.

EASA’s Part-145 AMC/GM set does not provide a general “blanket” PMA acceptance clause for receiving; acceptance flows from design approval/eligibility checks under 145.A.42 However, reference should be made to FAA-EASA Maintenance Annex Guidance (MAG).

Commercial parts (COTS) policy –GCAA recognises “commercial parts” explicitly and allows installation when the CAMO has defined acceptance/fitment procedures under CAR-M.501(a)(1); AMOs then mirror those CAMO-approved terms in their expositions. This is expressly spelled out for UAE operators.

  • EASA Part-145 AMC/GM focuses on standard parts and materials; there’s no parallel, explicit “commercial parts” privilege inside 145 AMC/GM for AMOs (the organisation must ensure the part is specified/eligible in the applicable maintenance data).

Component classification categories used by stores

GCAA adds UAE-specific categories in its CAR 145.42(a):
– “Restored UAE complete engine” released on an AW Form 1 by an appropriately rated GCAA AMO (store must segregate accordingly).
– Components authorised under CAR-MOA and released on AW Form 299.

EASA’s 145.A.42 uses the generic taxonomy (serviceable, unserviceable, unsalvageable, standard parts, materials) and defines “unsalvageable” in detail (useful for quarantine/scrap streams), but it does not have the UAE-specific categories above.

Supplier evaluation and audit depth (stores’ vendor control)

EASA provides a very prescriptive supplier-evaluation playbook in GM3 145.A.42(b)(i) (training/competence, shelf-life control, ESD handling, traceability, incoming inspection, calibration control, storage/packing/transport, SUP detection/reporting, recall control, etc.), and even cites recognised distributor standards (AS/EN9120, ASA-100, FAA AC 00-56). This drives how Part-145 stores qualify and monitor vendors.

  • GCAA’s CAR-145 ties acceptance of standard/raw/consumable materials to CAR-M AMCs and sets acceptance rules, but does not include an EASA-style, long checklist inside CAR-145 GM for supplier system elements (it relies more on cross-references and the receiving/eligibility checks).

Receipt Documentation

GCAA AMC 145.42(b) highlights the importance of Block 12 “Remarks” on release docs (e.g., configuration/limitations, life-limited items, AD status, CDCCL), directing the receiving organisation to verify eligibility against approved data (IPC/SB, etc.). It’s explicit about this step in the receiving workflow.

  • EASA AMC/GM likewise requires a documentation review and eligibility check before installation; emphasis is similar but expressed in EASA’s generic acceptance framework under AMC1 145.A.42(b)(i) and associated GMs.

Fabrication of parts by the AMO (internal manufacture for use)

Both frameworks allow limited in-house fabrication for own use, but GCAA AMC 145.42(c) adds very explicit boundaries for UAE AMOs: the parts are for the AMO’s own work, no AW Form 1 may be issued, and bulk transfer of locally fabricated parts is prohibited (must be segregated from deliverable stock).

  • EASA also treats fabricated parts as not eligible for EASA Form 1 and frames the practice under AMC to 145.A.42 (fabrication for installation), but the UAE text is more explicit about segregation and “no external supply.”

Store Supervision / Competence Requirements

GCAA calls out “Store Supervisors’ competence” explicitly in the GM2 145.30(e) competence assessment table—i.e., stores/logistics leadership is a named competence area to be assessed.

  • EASA Part-145 requires competence for personnel performing receiving/acceptance and related tasks, but does not name “Store Supervisor” as a distinct role in the AMC/GM competency matrices.

Information security & supply-chain risk (new EASA layer)

EASA introduces an Information Security Management System (ISMS) obligation in 145.A.200A, with applicability from 22 Feb 2026, which has downstream effects on supplier and data-flow controls in stores and purchasing (e.g., protection of maintenance data, vulnerability handling with vendors).

  • GCAA CAR-145 Issue 09 has no equivalent ISMS clause in the maintenance regulation, so this layer is currently an EASA-only delta for stores/supply-chain governance.

Next Steps

Sofema Aviation Services (SAS) provides EASA & UAE GCAA Regulatory Training, including the following Logistics Course. Please see our online website, Sofema Online (SOL), or email [email protected].

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non-critical status, Competence Requirements, Store Supervision, Receipt Documentation, ESD handling, stores’ vendor control, GCAA AMO, Commercial parts (COTS) policy, TC holder, CAMO, Supply Chain Comparison, GCAA Logistics Stores, FAA PMA Parts, SAS blogs, UAE, GCAA, EASA