Brexit

Yes. All the management personnel included in the exposition previously approved by the UK CAA, which was submitted to EASA as part of the early application process, are to be considered as approved by EASA for the same position within the organisation once EASA issues the approval.

EASA expects to receive an MOE/MTOE/CAME, as applicable, upgraded to the new approval of your organisation as an EASA Part-145/Part-147/CAMO and reflecting the fact that EASA is the competent authority. In addition, all associated procedures/lists should be also provided to EASA, where those procedures or lists are referred to in the relevant exposition or manual and intended to be integral part of the EASA approval. 

Every organisation subject to early application process was provided a separate communication by EASA indicating the specific amendments expected in expositions and manuals and related timeframes for their submission to EASA.

Further guidance is available under EASA website.

Yes, it is possible. A CRS is to be issued under your UK CAA Part-145 approval for all the activity performed until December 31, 2020, according to 145.A.50(c) and (e). Based on those provisions, it is possible to release the maintenance performed, as long as the incomplete maintenance is properly identified. All the remaining activity from January 1, 2021, will be performed under your new EASA Part-145 approval, including the possibility to issue the final CRS, provided all EASA Part-145 requirements have been met during the maintenance.  The same principle is also applicable for any maintenance under Cx/D1/Bx ratings.  

No, it is not possible. A  training cannot be initiated under a UK Part-147 approval, which loses its recognition in the EASA Member States on January 1, 2021 and then completed under a Part-147 approval issued by EASA.

The Approval Certificate issued by EASA on the January 1, 2021 corresponds to the Approval Certificate issued by the UK CAA which was submitted to EASA as part of the early application process. This means that the reference of the Exposition in the EASA Approval Certificate is the same as the reference to the Exposition  in the corresponding Approval Certificate issued by the UK CAA. However the Exposition referenced in the EASA Approval Certificate may, in some cases, not be the latest approved Exposition, as some changes might have been approved to that Exposition between the date of issuance of the UK CAA Approval Certificate and the date of issuance of the EASA Approval Certificate. 

In line with the EASA certification procedures, EASA confirms that the exposition to be used by the organisation under the EASA Approval Certificate is the latest version of the Exposition approved (either directly by the CAA or if applicable, indirectly by the organisation itself under its approval privileges) before the January 1, 2021.

Please note that the organisation concerned should provide to EASA an updated version of its Exposition in the proper EASA MOE format at the latest by June 30, 2021.

Please send your documents or queries to the following functional mailboxes, as applicable to the domain:

• Part-145 approvals: MOC_UK [at] easa.europa.eu
• Part-147 approvals: MOC_147 [at] easa.europa.eu 
• Part-MG/CAMO approvals: MOC_CAMO [at] easa.europa.eu

Yes, the BASA includes provisions that ensure that design certificates and approvals issued under the EASA system until December 31, 2020 are transferred into the new system and remain effective after January 1, 2021.

The BASA contains provisions on how design certificates and approvals issued by the UK CAA will be validated by EASA. Under these provisions, an EASA DOA/ADOA will no longer be needed to obtain a validation by EASA of a design approval issued by the UK CAA. Therefore, while EASA DOAs became invalid on January 1, 2021, said UK-based design organisations cannot exercise any longer privileges of their former EASA Part 21 DOA certificate. All future design work of UK-based design organisations should be performed under the UK CAA oversight.

From January 1, 2021, EASA will no longer be acting as competent authority for the UK as State of design – this role will be taken over by the UK CAA. EASA and UK CAA are working together to ensure a smooth transfer of ongoing files. In case you want to continue the project, please contact the UK CAA for further information.

The existing bilateral agreements between the EU and third country partners will no longer apply to the UK after BREXIT. If you are a UK organisation, you will need to contact the UK CAA for any future validations of your design approvals in foreign states.

The existing bilateral aviation safety agreements between the EU and third country partners will no longer apply to the UK after December 31, 2020. Therefore, if you are a design organisation located in the UK you will need to contact the UK CAA for the continued validity of your design approvals in foreign states.

The Trade and Cooperation Agreement between UK and EU states that minor changes and minor repairs approved by UK CAA or a UK CAA approved design organisation are accepted by EASA and vice versa without a need for issuance of an additional certificate. 
Further details can be found in ANNEX 30 AIRWORTHINESS AND ENVIRONMENT CERTIFICATION, Article 13.

The Trade and Cooperation Agreement between UK and EU states that non-significant supplemental type certificates, approvals of non-significant major changes, repairs and technical standard order authorisations issued by EASA or an EASA approved design organisation are  accepted by the UK CAA without a need for issuance of an additional certificate.  Further clarification on classification will be provided in the UK CAA/EASA TIP. 
Further details can be found in ANNEX 30 AIRWORTHINESS AND ENVIRONMENT CERTIFICATION, Article 13.

The Trade and Cooperation Agreement between UK and EU states that type certificates, supplemental type certificates, approvals for major changes, major repairs and technical standard order authorisations issued by the UK CAA or by a UK CAA approved design organisation will not be directly accepted by EASA and will be subject to technical validation by EASA. In some cases, when agreed by UK CAA and EASA, a streamlined validation may be performed.  
Further details can be found in ANNEX 30 AIRWORTHINESS AND ENVIRONMENT CERTIFICATION, Article 10.

The Trade and Cooperation Agreement between UK and EU states that type certificates, significant supplemental type certificates and approvals for significant major changes will be subject to either technical validation or streamlined validation by the UK CAA.  Further clarification on classification and corresponding validation path will be provided in the UK CAA/EASA TIP.

Article 4 of Regulation (EU) No 748/2012 - Continued validity of supplemental type-certificates

With regard to supplemental type-certificates issued by a Member State under JAA procedures or applicable national procedures and with regard to changes to products proposed by persons other than the type-certificate holder of the product, which were approved by a Member State under applicable national procedures, if the supplemental type-certificate, or change, was valid on 28 September 2003, the supplemental type-certificate, or change shall be deemed to have been issued under this Regulation.

These STCs/changes being deemed to have been issued under this Regulation were EASA valid certificates at the date of 31.12.2020 (irrespective of their origins and like any other certificate issued in accordance with Reg. 748/2012) and are therefore covered by Article 15 of ANNEX AVSAF-1.

As per Article 3 and 6 of Regulation (EU) No 748/2012 - Continued validity of type-certificates and related certificates of airworthiness and parts and appliances certificates, the same applies in analogy to Type Certificates and European Technical Standard Orders.

As of January 1, 2021, Part-145 certification privileges can be granted based on Aircraft Maintenance licenses issued by the UK CAA, subject to compliance with the provisions of EASA Part-145 Appendix IV and the geographical limitations defined in Point 145.A.30(j)(1)/(2) of Regulation (EU) No 1321/2012 (i.e. where maintenance is performed at organisation facilities located outside the EU territory or where line maintenance carried out at a line station of an organisation which is located outside the EU territory).

Yes, it will be possible. Under the provisions of Part-M and Part-CAMO, a continuing airworthiness management organisation can arrange to carry out limited continuing airworthiness tasks with any contracted organisation working under its quality system, as listed on the approval certificate. This sub-contracting cannot concern however airworthiness review tasks.

No, it cannot. The privileges to conduct an airworthiness review of aircraft registered in an EASA Member State and to issue a corresponding ARC or a recommendation for issuance of an ARC are granted under Annex I (Part-M) and Annex Vc (Part-CAMO) of Regulation (EU) No 1321/2014 only to CAMOs located in EASA Member States.

A maintenance organisation approved by an EASA Member State or EASA cannot perform any maintenance on UK-registered aircraft in accordance with point 145.A.50 of Annex II (Part-145) of Regulation (EU) No 1321/2014. However EU law does not prevent UK from adopting national regulations permitting maintenance release of UK-registered aircraft by a Part-145 organisation approved by EASA or an EASA Member State. For more information on the different possibilities please refer to the following link:

• Rulemaking interpretation on 'Maintenance release of aircraft not covered by the Basic Regulation.

Such 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.

It is recalled that 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.

After 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.

When the Part-145 aircraft maintenance organisation has the capability to control the airworthiness status of components, then §2.6.2 of AMC2 145.A.50(d) is applicable in such cases. In accordance with those provisions it is possible for a Part-145 approved aircraft maintenance organisation to remove a component from a UK registered aircraft provided that such a component is removed under a procedure concerning issuance of an ‘EASA Form1’ for components removed ‘serviceable’ from a non-EU registered aircraft, which is approved in the MOE of the organisation conducting the removal. Otherwise, the component must first undergo workshop maintenance by a Part-145 component maintenance organisation in accordance with the procedure described in §2.8 of AMC2 145.A.50(d) before receiving an ‘EASA Form 1’. 

Yes, such an ARC will continue to be valid in the EASA Member States until its normal expiry date, provided that the aircraft was transferred to a registry of an EASA Member State before January 1, 2021.

An aircraft registered in the UK is to be considered as a third country aircraft as from January 01, 2021, while the Part M obligations and the organisation approvals granted in accordance with Regulation (EU) 1321/2014 have their applicability limited to:

1. aircraft registered in an Member State, unless their regulatory safety oversight has been delegated to a third country and they are not used by an EU operator; 
2. aircraft registered in a third country and used by an EU operator, where their regulatory safety oversight has been delegated to a Member State;

In addition, aircraft registered in a third country, including the UK, for which their regulatory safety oversight has not been delegated to a Member State and that are dry leased-in by an air carrier licensed in accordance with Regulation (EC) No 1008/2008, shall be managed by an approved continuing airworthiness management organisation complaint with Part M Subpart G (or Part-CAMO) and Part T Subpart G (refer to T.A.701). These aircraft however are issued with a Certificate of Airworthiness by the third country of registry and are not subject to EU requirements concerning ARC (or its extension) laid down in Part-M, but instead should comply with the continuing airworthiness rules of the State where they are registered.
 
The EU-UK Trade and Cooperation Agreement does not currently address activities covered by Regulation (EU) No 1321/2014.

EASA approved maintenance organisation can use design data approved under UK regulations in cases where these design data are directly accepted, or when validated by EASA.

As explained in the following FAQ items https://www.easa.europa.eu/faq/124095 and https://www.easa.europa.eu/faq/124097 , minor design changes and repairs approved by the UK CAA or by an approved organisation under laws and regulations of the United Kingdom (UK DOA)are directly accepted without the need for EASA to issue a certificate. Other design approvals (TC, STC, Major Change, Major Repair, ETSOA) require a validation by EASA.

When directly accepted (or once validated by EASA when applicable), the design data can be used by EASA approved maintenance organisations to release component or EU-registered aircraft, regardless of the location of the approved maintenance organisations.

In accordance with Regulation (EU) No 1321/2014, on the job training (OJT) for first type endorsement must be conducted at and under the control of an appropriately approved maintenance organisation. The maintenance organisation located in the UK where the OJT takes place must therefore hold an EASA Part 145 approval. 

In addition, also in accordance with Regulation (EU) No 1321/2014, on the job training (OJT) for first type endorsement must be approved by the competent authority of an EASA Member State which will issue the Part-66 licence. The applicant will therefore need to contact directly the relevant EASA Member State that will issue the Part 66 Licence to verify whether it will take credit of this OJT towards the type endorsement.

Finally, as regards the approval by EASA of the maintenance organisations located in the UK the MOE 3.15 procedures for the On the Job Training (first type endorsement) will not be approved by EASA when such a maintenance organisation transfers to an EASA Third Country Part 145 approval. These MOE 3.15 and 3.16 paragraphs are not applicable to EASA Part-145 Third Country approvals.
 

No.  As of January 1, 2021 Part-66 licences previously issued by UK authorities will no longer be valid and recognised in EU. Accordingly, any such a license cannot be transferred to an EASA Member State after December 31, 2020.

Yes, EASA Member States may continue to accept such CoR for the purpose of issuing a Part-66 licence/rating endorsement also after the expiry of the transitional period under the EU-UK withdrawal Agreement, provided that the CoR was correctly issued and the application for the Part-66 licence/rating endorsement to an EASA Member State was done within the time periods provided for in Annex III (Part-66) to Regulation 1321/2012 (within 10 years in case of application for an aircraft maintenance licence or the addition of a category or subcategory to such a licence; or within 3 years in case of an application for a rating endorsement).

From January 01, 2021, your UK-issued ATPL is no longer valid to operate an aircraft registered in an EASA Member State. Unless you were able to transfer that license to an EASA Member State before that date, you will need to convert it into an EU license in accordance with Commission Delegated Regulation (EU) 2020/723. You can apply for that conversion to any of the EASA Member State’s competent authorities.

Your UK-issued pilot licence and medical certificate are considered as a third-country licence and certificate as of January 01, 2021 and thus they are no longer recognised for flying an aircraft registered in an EASA Member State as of that date. In this case, you may consider temporarily validating your UK license or converting it into an EU Part-FCL license according to Commission Delegated Regulation (EU) 2020/723. 

Unless you were able to transfer your UK-issued license and medical certificates to an EASA Member State before January 01, 2021, those UK licenses and certificates became invalid in the EU as of that date and are now considered as third-country certificates. In such case, as a student pilot enrolled in an ATP integrated course, you will need a Part-MED medical certificate issued by an EASA Member State competent authority before your first solo flight (Point MED.A.030 (a) of Annex IV (Part-MED) to Regulation (EU) No 1178/2011).

Under the EU Aircrew Regulation (EU) No 1178/2011, a student may be admitted to integrated ATP training either as an ab-initio entrant or as a holder of a PPL(A) or PPL(H) issued in accordance with Annex 1 to the Chicago Convention. In the case of a entrant already holding a PPL(A) or PPL(H), 50% of the hours flown prior to the course can be credited, up to a maximum of 40 hours flying experience, or 45 hours if an aeroplane night rating has been obtained, of which up to 20 hours may count towards the requirement for dual instruction flight time. Therefore, you may benefit of credits up to the abovementioned limits. As student pilot enrolled in an ATP integrated course, you will also need a Part-MED medical certificate issued by an EASA Member State’s competent authority before your first solo flight (point MED.A.030(a) of Annex IV (Part-MED) to Regulation (EU) No 1178/2011).

After December 31, 2020, training for the issuance of a Part-FCL license must be conducted in a training organisation under oversight of an EASA Member State or EASA. Accordingly, after that date, training for the issuance of such a license in a UK-approved ATO is no longer possible. 

Students who started their courses in a UK-approved ATO before January 01, 2021 had a possibility, before that date, to transfer their training to a training organisation under oversight of an EASA Member State or EASA.  In such a case, the student wishing to transfer the training must have applied to the competent licensing authority of an EASA Member State for a formal assessment of the further hours of training required.

As of January 01, 2021, licenses and certificates issued by the UK are no longer valid in EASA Member States and are treated as a third-country licences and certificates. Accordingly, as of that date, a UK-issued ATPL cannot be used to operate aircraft of commercial operators under oversight of EASA Member States. 

As of January 01, 2021, in order to obtain a Part-FCL licence from an EASA Member State, UK licence holders must follow a conversion process as per Commission Delegated Regulation (EU) 2020/723.

Source: UK CAA

For the time being, there is no plan to develop a simplified application and validation procedure. Accordingly, any validation or conversion of a UK issued license should be done in accordance with Commission Delegated Regulation (EU) No 2020/723

As of January 01, 2021, licenses and certificates issued by the UK are no longer valid in EASA Member States and are treated as a third-country licences and certificates. As of that date, the holder of a UK-issued PPL may apply for its conversion in accordance with Commission Delegated Regulation (EU) 2020/723. LAPLs can however not be converted in accordance with that Regulation.  

After December 31, 2020, the UK Part-FCL licences (both PPL and LAPL), issued by the UK CAA in accordance with Regulation (EU) No 1178/2011, are no longer recognised as Part-FCL licences for the purpose of flying on aircraft registered in an EASA Member State. 

In order to continue to exercise the privileges associated with those UK issued licences they should have been transferred to an EASA Member State before January 01, 2021. Alternatively, as of January 1, 2021, UK-issued PPLs may be temporarily validated or converted into Part-FCL PPLs upon application submitted to an EASA Member State under Commission Delegated Regulation (EU) 2020/723. However, the LAPL is not an ICAO-compliant licence and can therefore not be validated or converted following the above-mentioned provisions.

After December 31, 2020, holders of Part-FCL licence previously issued by the UK CAA cannot be longer considered holders of a Part-FCL licence issued in accordance with Regulation (EU) No 1178/2011 subject to mutual recognition within the EASA Member States. Such licenses are considered as third-country licences in the EU after that date. 

If a pilot was not able to transfer his/her license to an EASA Member State before January 01, 2021, the pilot still has an option to convert a UK-issued license into a Part-FCL licence in accordance with Commission Delegated Regulation (EU) 2020/723 laying down detailed rules regarding the acceptance of third-country certification of pilots.

In accordance with that Delegated Regulation, an EASA Member State may issue Part-FCL licences to applicants who already hold an equivalent licence, rating, privilege or certificate issued in accordance with Annex 1 to the Chicago Convention by a third country, provided that those applicants comply with certain additional requirements and taking account of any credit based on a recommendation from an approved training organisation or a declared training organisation under oversight of an EASA Member State or EASA.

EASA Member State competent authorities may continue to accept such valid theoretical knowledge examination completion certificates for the purpose of issuing Part-FCL licenses and ratings in accordance with either Regulation (EU) 1178/2011 or Delegated Regulation (EU) 2020/723, provided that those examination completion certificates are still within their validity period in accordance with point FCL.025(c) of Annex 1 (Part-FCL) to Regulation (EU) No 1178/2011 and provided that they were issued by the UK CAA before January 01, 2021 in full compliance with Annex 1 (Part-FCL) to Regulation (EU) 1178/2011. In particular, in accordance with point FCL.025(a)(1) of Annex 1 (Part-FCL) to Regulation (EU) 1178/2011, the entire set of theoretical knowledge examinations for a specific licence or rating must have been taken under the responsibility of the UK CAA.

Please note that this does not mean that the student file can be transferred to an EASA Member State’s training organisation, but only that EASA Member State’s competent authorities may continue to accept theoretical knowledge examination completion certificates which were issued before January 01, 2021 by the UK CAA for the purpose of issuing their own licenses or ratings.

After January 01, 2021, in order to continue relying on that ATPL theoretical knowledge examination issued by the UK CAA for the purpose of obtaining a Part-FCL license or rating, the student should undergo flight training at a training organisation under oversight of EASA or an EASA Member State and apply for the issue of the license or rating to one of the EASA Member States competent authorities within the period of validity of the theoretical knowledge examination certificate concerned. 

In case the student transferred to an ATO approved by an EU27 competent authority or EASA before January 01, 2021, the student should also have applied to the competent licensing authority of an EASA Member State by that date for a formal assessment of the further hours of training required. The new EU competent authority will be the one to whom the student will apply for the licence issue.

From January 01, 2021, cabin crew attestation issued by the UK are no longer valid and mutually recognized for use on an aircraft operated by a commercial air transport operator certified by an EASA Member State. Until that date, holders of cabin crew attestation issued by the UK CAA or by UK approved organisations had an option of transferring that attestation to an EASA Member State.

Valid theoretical knowledge examination completion certificates and skill tests can be accepted by EASA Member States also after the January 01, 2021 for the purpose of issuing Part-FCL licenses and ratings in accordance with either Regulation (EU) 1178/2011 (for the issue of a Part FCL licence after completion of the flight training and testing under the responsibility of a an EASA Member State competent authority) or Delegated Regulation (EU) 2020/723 (in case of conversion of the UK licence into a Part-FCL licence), provided that those examination completion certificates or skill tests are still within their validity period in accordance with point FCL.015(f) and point FCL.025(c) of Annex 1 (Part-FCL) to Regulation (EU) 1178/2011 and provided that they were issued by the UK CAA before January 01, 2021 in full compliance with Annex 1 (Part-FCL) to Regulation (EU) 1178/2011. In particular, in accordance with point FCL.025(a)(1) in Annex 1 (Part-FCL) to Regulation (EU) 1178/2011, the entire set of theoretical knowledge examinations for a specific licence or rating must have been taken under the responsibility of the UK CAA.

As of January 1, 2021 UK registered aircraft will be considered by the EU as aircraft registered in a third country and any CAT operator certified by an EASA Member State wishing to operate such aircraft under its AOC will need to comply with the provisions of EU law concerning dry lease-in of 3rd country registered aircraft. This includes obligation for the EU operator to obtain a prior approval from its competent authority upon demonstration of compliance with safety requirements and of an operational need that cannot be satisfied by leasing aircraft registered in the EASA Member States. The duration of such dry lease-in cannot exceed 7 months in any 12 consecutive month period.

As of January 1, 2021 any CAT operator certified by an EASA Member State wishing to wet lease-in an aircraft operated by a UK operator will need to comply with the provisions of EU law concerning wet-lease in of 3rd country operated aircraft. This includes obligation for the EU operator to obtain a prior approval from its competent authority responsible for safety and from its competent licensing authority. This will require demonstration, in particular, that the safety standards of the UK operator are equivalent to the applicable requirements established by EU law and that the leasing is of a limited duration and is justified by exceptional or seasonal capacity needs or other operational difficulties as provided in relevant EU legislation. The UK operator wet leasing out to an EASA operator should also hold a TCO Authorisation, should the aircraft be operated on routes to/from/within EASA Member States (please refer to the questions under Section EASA TCO Authorisations).

As of January 1, 2021 an SPO operator certified by an EASA Member State wishing to wet lease-in or dry lease-in an aircraft operated by a UK operator or registered in the UK will need to comply with the provisions of EU law concerning the lease-in of 3rd country operated or third country registered aircraft, as applicable. These provisions are contained in point ORO.SPO.100(c) of Annex III to Commission Regulation (EU) No 965/2012.

No, Specific Airworthiness Specifications issued by EASA before January 1, 2021 with respect to UK-registered aircraft are no longer valid. EASA issues Specific Airworthiness Specifications only as regards aircraft registered in EU Member States or other European States participating in the work of EASA. As of January 1, 2021, UK is no longer part of the EASA system and the EU aviation safety legislation, including Regulation (EU) 2018/1139, no longer applies to the UK. Owners of aircraft registered in the UK which do not have a valid certificate of airworthiness should contact UK CAA for further advice.

No, approvals of flight conditions (EASA Form 18B ‘Approval of Flight Conditions for a Permit to Fly’) issued by EASA before January 1, 2021 with respect to UK-registered aircraft are no longer valid. EASA issues approval of flight conditions only as regards aircraft registered in EU Member States or other European States participating in the work of EASA. As of January 1, 2021, UK is no longer part of the EASA system and the EU aviation safety legislation, including Regulation (EU) 2018/1139, no longer applies to the UK. Owners of aircraft registered in the UK which do not have a valid certificate of airworthiness should contact UK CAA for further advice.

Annex AVSAF-1 (Airworthiness and Environment Certification) to the EU UK Trade and Cooperation Agreement does not cover Flight Conditions (FC) (FC are not design certificates)
Consequently, 

• in accordance with UK Part 21, UK CAA or UK 21J approved design organisations can approve FC only for UK-registered aircraft
• in accordance with EU Part 21, EASA (for safety of design-related FC) or State of Registry NAA (for non-safety of design related FC) or EASA 21J design approved organisations can approve FC only for EU Member State-registered aircraft

The United Kingdom (UK) withdrew from the European Union Aviation Safety Agency (EASA) system as of January 01, 2021. As of that date the EU law does not apply anymore in the UK which is considered as a third country. 

This means that, in accordance with Article 41 of Commission Regulation (EU) 2019/945, Unmanned Aircraft System (UAS) operators that have their principal place of business, are established, or reside in the UK shall comply with Commission Regulation (EU) 2019/947 for the purpose of operations within in the single European sky airspace. The competent authority for such a third country UAS operator wishing to operate in the EU is the competent authority of the first Member State where the UAS operator intends to operate.  

As a derogation to the above provisions, in accordance with Article 41 of Commission Regulation (EU) 2019/945 a certificate of the remote pilot competency or the UAS operator’s certificate issued by a third country may be recognised by the competent authority of the EU Member State provided that all of the following conditions are met:  

• the third country asked for such recognition,
• the certificate of the remote pilot competency or the UAS operator`s certificate are valid documents of the State of issue; and
• the Commission, after consultation of EASA, has ensure that the requirements on the basis of which such certificates have been issued provide the same level of safety as the Regulation (EU) 2019/945 does;

The UK has not yet initiated the above recognition process, so as things stand the UK certificates cannot be recognised yet for the purpose of UAS operations within in the single European sky airspace.

As of January 1, 2021 the UK certified CAT operators will be considered as Third Country Operators (TCO) and required to hold a valid EASA TCO authorisation in order to be able to conduct commercial air transport operations into, within or out of the territory to which the EU Treaties apply (or to territories of non-EU EASA Member States). TCO authorisations will be issued also under the EASA early applications process.

A list of operators that will be issued a TCO Authorisation on December 31, 2020 is available on the EASA website.

The dedicated TCO web-interface provides information on all aircraft that are included under an EASA issued TCO authorisation. That information is available to the TCO concerned and to all EASA Member States. EASA also provides to EUROCONTROL real time information on aircraft that are authorised to operate to/from/within the EASA Member States under an EASA TCO authorisation.

EASA Member States issue operating permits for commercial air transport operations in accordance with their national regulations. The TCO authorisation issued by EASA is a pre-requisite to apply for such operating permits.

As per the Trade and Cooperation Agreement between UK and EU, in particular Art 21 and Art 24 of Annex 30, the EU recognizes the POA issued by the UK CAA, as well as the UK CAA Form 1 for the export of parts.

Therefore, there is no need for UK-based organisation to hold an EASA Third Country Production Organisation Approval. Consequently, EASA has not issued any Third Country POA for UK organisations and as such, there is not any valid EASA.UK.21G.XXXX approval.

Parts manufactured by UK organisations should be exported to the EU with a UK CAA Form 1 referring to the UK CAA POA approval. Please note that UK CAA Form 1 is only an airworthiness export certificate, which does not alleviate from any other custom/administrative export requirements to the EU.

As per the Trade and Cooperation Agreement between the UK and the EU, in particular Section E of Annex 30, the EU recognises the POAs issued by the UK CAA.

Therefore, there is no need for UK-based organisation to hold an EASA Third Country Production Organisation Approval. Consequently, EASA has not issued any Third Country POA for UK organisations and as such, there is not any valid EASA.UK.21G.XXXX approval.

Since January 01, 2021, the Union law ceased to apply in the UK.  As per the Trade and Cooperation Agreement between the UK and the EU , in particular Section E of Annex 30, the EU recognises the POAs issued by the UK CAA. Hence UK-based organisations holding a UK CAA POA do not need to, nor are allowed to release parts or appliances with an EASA Form 1 since that date. Any potential EASA Form 1 issued by a UK CAA POA holder on or after January 01, 2021 would have no legal value (“null and void”) as an authorized release certificate.

As per the Trade and Cooperation Agreement between the UK and the EU , in particular Section F of Annex 30, the EU recognises the export certificates issued by a UK CAA POA holder or the UK CAA itself for the civil aeronautical products detailed below.

For aircraft and products intended to be exported from UK to EU the following forms (certificates) are to be used, referring to the UK CAA POA if applicable:

• For new aircraft: UK CAA Form 52;
• For used aircraft: UK export certificate of airworthiness;
• Other new products and parts: UK CAA Form 1.

Please note that these forms (certificates) are only used as airworthiness export certificates, which do not alleviate from any other custom/administrative export requirements applicable to the export of goods into the EU.

Further details are provided in the Technical Implementation Procedures, which can be found in the “downloads” section of the following page: https://www.easa.europa.eu/document-library/bilateral-agreements/eu-uk-….

Any potential EASA Form 1 issued by a UK CAA POA holder on or after January 01, 2021 would have no legal value (“null and void”) as an authorized release certificate. Refer to question: As a UK-based production organisation holding a UK CAA POA, can I release parts with an EASA Form-1 on or after January 01, 2021?

In case the design is approved under an EASA DOA, the UK-based POA can issue a UK CAA Form 1 for “NEW” under the UK CAA POA approval. Additional clarification can be entered in block 12.

As per 21.A.804, the “EPA” marking should be used for parts or appliances produced in accordance with approved design data not belonging to the type-certificate holder of the related product, except for ETSO articles.

Part/appliance manufactured by a UK-based production organisation in accordance with EASA design data (approved either through an EASA-issued certificate or through an approval by an EASA DOA, including approval prior to January 01, 2021 from a now UK DOA working under the regime of an EASA DOA at that time) not belonging to the type-certificate holder of the related product should be marked as “EPA” and released with a UK CAA Form 1.

EU/EASA POA should mark products, parts and appliances according to the design data.

As per 21.A.804, the “EPA” marking should be used for parts or appliances produced in accordance with approved design data not belonging to the type-certificate holder of the related product, except for ETSO articles.

Part/appliance manufactured by an EU/EASA POA holder in accordance with UK CAA design data (approved either through an UK CAA-issued certificate or through an approval by an UK CAA DOA) not belonging to the type-certificate holder of the related product, should be marked with “UKPA” in a manner identified by the applicable design data and released with an EASA Form 1.

As per the Trade and Cooperation Agreement between the UK and the EU, in particular Sections E and F of Annex 30, the UK recognises the POAs issued by the EU competent authorities (EASA or National Aviation Authorities - NAA), as well as the export certificates issued by these organisations or by the Competent Authorities for the civil aeronautical products detailed below.

For civil aeronautical products intended to be exported from EU to UK the following forms (certificates) are to be used, referring to the EU competent authority POA if applicable:

• For new aircraft: EASA Form 52;
• For used aircraft: export certificate of airworthiness (issued by the competent authority of the State of Registry for the aircraft from which the aircraft is exported);
• Other new products and parts: EASA Form 1.

Please note that these forms (certificates) are only used as airworthiness export certificates, which do not alleviate from any other custom/administrative export requirements applicable to the export of goods into the UK.

Further details are provided in the Technical Implementation Procedures, which can be found in the “downloads” section of the following page: https://www.easa.europa.eu/document-library/bilateral-agreements/eu-uk-trade-and-cooperation-agreement

As per the Trade and Cooperation Agreement between UK and EU, in particular Art 21 of Annex 30, the production of all categories of civil aeronautical products that were produced on December 31, 2020 in the EU and the UK, respectively, are mutually accepted. 

Annex 30 further determines that these categories are to be defined in the related Technical Implementation Procedures.

Please refer to the Technical Implementation Procedures Appendix 1, which can be found in the “downloads” section of the following page: https://www.easa.europa.eu/document-library/bilateral-agreements/eu-uk-trade-and-cooperation-agreement

As provided in the hereunder FAQ item, EASA DOAs in the UK became invalid on January 01, 2021.

As a consequence, any DO/PO arrangement between a UK-based EASA DOA and an EU/EASA POA holder existing before January 01, 2021 is not valid anymore.
A new DO/PO arrangement (or an update of the existing DO/PO arrangement) needs to be signed referring to the new UK CAA DOA.

Parts and appliances manufactured against a design approved by EASA or EASA DOA before January 01, 2021 can continue to be released by the EU/EASA POA holder, provided that such parts and appliances are covered by an updated/new DO/PO arrangement with the new UK CAA DOA .

Parts and appliances manufactured against a design approved under the UK regulatory system on or after January 01, 2021 can only be released by the EU/EASA POA holder if:

1. Such parts and appliances are covered by an updated/new DO/PO arrangement with the new UK CAA DOA; and
2. The design is accepted by EASA (minor changes/repairs) or validated by EASA (TSO, Major changes/repairs, STC, TC) as detailed in the Trade and Cooperation Agreement between UK and EU and the Technical Implementation Procedures between UK CAA and EASA.