Sofema Aviation Services (SAS) considers issues related to EASA / UK Certification.
Introduction: EASA Form 1 and UK CAA Form 1
The European Union Trade and Cooperation Agreement (EU-UK) states; “The importing Party shall recognize the production certification and production oversight system of the exporting Party since the system is considered sufficiently equivalent to the system of the importing Party” (source: Article 21 of Annex 30 of the Trade and Cooperation Agreement).
From the UK Perspective
All EASA certificates, approvals, and licenses in effect on the Withdrawal Date of December 31, 2020, for use in the UK aviation system and on UK-registered aircraft will be recognised by the CAA for up to two years.
Previously, EASA Form 1s were issued by UK organisations to confirm that a product, part, or component was manufactured in accordance with approved design data. Following the Withdrawal Date (December 31, 2020), UK CAA-approved organisations will now issue a UK CAA Form 1 in place of an EASA Form 1.
A CAA Form 1 is nearly identical in content and layout to the EASA Form 1 and is to be completed in accordance with the existing instructions – the Acceptable Means of Compliance and Guidance Material – used for EASA Form 1s. The CAA adopted the latter as its policy with regard to compliance with the relevant UK law from January 1, 2021. The only difference is the authority information in the header has changed and the form reference itself is now a CAA Form 1.
From 1 April 2022, UK owners/operators cannot accept EASA Form 1s dated after that point as acceptable documents for the certification of maintenance on engines and/or components from EU/EASA organisation that have not applied to the CAA for approval by 31 March 2022.
EASA Form 1s issued by an 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.
From EASA Perspective
The UK-EU Trade and Cooperation Agreement recognizes the CAA Form 1 for the export of new parts, appliances, engines, and propellers and CAA Form 52 for the export of new complete aircraft.
Therefore, there is no need for UK-based organisations to hold an EASA Third Country Production Organisation Approval. Consequently, EASA has not issued any Third Country POA to organizations in the UK and as such, there are no EASA.UK.21G.XXXX approvals. (Source: CAA and EASA)
As regards design and production organisations located in the UK they are governed by the trade and cooperation Agreement between the EU and the UK. For production, the agreement provides for mutual recognition of the production certifications and production oversight systems.
For Design, whilst the agreement does not provide for mutual recognition of any certificates, it does allow for certain amount of simplification in the acceptance or validation of such certificates.
For Maintenance Release
Individually identifiable components for which a UK certified maintenance organisation issued an ‘EASA Form 1’ and placed them on the market before January 1, 2021 can continue to be used and fitted on an aircraft registered in an EASA Member State also after that date, unless the part or other component has been damaged or not stored in accordance with the EU aviation safety requirements.
This is foreseen by Article 41 of the EU-UK Withdrawal Agreement.
Note An ‘EASA Form 1’ is only a statement of airworthiness at the time of its issue, and, as stated in Appendix II to Part-M of Regulation (EU) No 1321/2014, ‘EASA Form 1’ “does not constitute approval to install the item on a particular aircraft, engine, or propeller but helps the end user determine its airworthiness approval status”. It is therefore the ultimate responsibility of the user or installer to make this installation decision.
Effective December 31, 2020, the UK based maintenance organisation must hold an EASA Part 145 approval in order to be able to continue issuing ‘EASA Form 1’ for components which are to be fitted on an aircraft registered in an EASA Member State.
Next Steps
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aviation, Aviation Training, EASA, EASA Part 145, Part 145, Certification, SAS blogs, EASA Member State Authorities, EASA Form 1, UK CAA, UK CAA Form 1
