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“Installers need to confirm that the part complies with the rules established by the [BASA] agreement…”

There are special rules for acceptance in Europe of PMA parts. The rules endorse the long-standing position of the European Community that PMA parts are generally acceptable. The acceptance criteria make an important distinction between critical PMA parts and non-critical PMA parts. Because the word “critical” is used in several different ways in aviation, it is important to first focus on what this word means in the context of PMA parts imported into Europe. For this limited purpose, the term “critical” refers to a part for which there is a replacement time, inspection interval, or related procedure specified in the Airworthiness Limitations section of the Instructions for Continued Airworthiness. If there is no limit, or if there is a limit found elsewhere but not found in the Airworthiness Limitations, then the PMA part is not “critical.” This is an important distinction, because some companies have gotten confused about other limits that are not found in the Airworthiness Limitations Section (such limits, alone, do not make the part critical). Most PMA parts are not “critical.’’ If the PMA part is not “critical,” then the part is accepted into the EC without any further showing. The export 8130-3 tag for the part should state “This PMA part is not a critical component.” If the part is “critical” but it is manufactured under a licensing

agreement with a type certificate holder or STC design approval holder, then the part is accepted into the EC without any further showing. This is because the Airworthiness Limitations have already been approved in the context of the TC/STC, which is either issued, validated or accepted by EASA. The export 8130-3 tag for the part should state “Produced under licensing agreement from the holder of [INSERT TC or STC NUMBER].” If the part is “critical” and it is manufactured independently

(no license agreement), then the PMA holder should obtain EASA STC for the design. If there is already a FAA STC for the PMA design (e.g. if it reflects a major change to type design) then the STC holder can use the validation process to obtain European STC. Such validation is obtained by applying through the FAA Aircraft Certification Office (ACO), which will work with EASA to obtain the validated EASA STC. After obtaining an EASA STC, the part may be freely exported to the EC - the export 8130- 3 tag should state: “Produced by the holder of the EASA STC number [INSERT THE FULL REFERENCE OF THE EASA STC INCORPORATING THE PMA].”

Marking Requirements Some parts and products passing between the United States and the European Community must have identification markings in order to be in compliance.

 Aircraft, engines and propellers must be identified according to the importing nation’s requirements.

 Each critical component of a product must be identified with a part number and serial number.

 Each ETSO or TSO appliance must have the phrase “ETSO” or “FAA TSO,” respectively.

 PMA replacement or modification parts headed for Europe must be marked with the part number, serial number (if applicable), and a manufacturer’s name, trademark or symbol. They do not need to be marked “EPA” unless Europe was the state of design.

The US-EC Bilateral Agreement became effective May 1, 2011. AM

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