We are a maintenance organisation approved for component maintenance (B/C-rated Part-145 organisation, or Part-CAO with class “component”). Can we issue an EASA Form 1 in accordance with point 145.A.50(d) after maintenance performed on an engine/component on-wing on a non-EU-registered aircraft?
Answer
Non-EU countries are sovereign to set acceptable procedures to be followed on aircraft under their register. They can establish that components maintained by organisations approved in accordance with Part-145 (or Part-CAO) of Regulation (EU) No 1321/2014 and released with an EASA Form 1 can be installed on aircraft on their register.
Since component removed from third-country aircraft may be subject (under certain conditions) to off-wing component maintenance by Part-145 (or Part-CAO) organisation (with the issue of an EASA Form 1 after maintenance), there is no objection that a B/C-rated Part-145 organisation (or a CAO with class “component”) performs a work order and issues an EASA Form 1 to certify maintenance on engines/components installed on (or temporarily removed from) a non-EU-registered aircraft while this aircraft undergoes line or base maintenance. The B/C-rated Part-145 (or CAO) organisation needs for this an approved MOE procedure to conduct maintenance away from an approved location.
Note: In accordance with Regulation (EU) No 1321/2014, an appropriately approved organisation issuing an EASA Form 1 certifies that the requested maintenance has been properly accomplished on the component; but this form does not provide permission for the installation of the component on an EU-registered aircraft. Particular care is necessary for components originating from non-EU registered aircraft and intended for installation on EU-registered aircraft (ref. point 2.8 of AMC2 145.A.50(d)).