How did you install a Commercial Off-The-Shelf (COTS) equipment without EASA form-1? How do you arrange Part-145 side actually?
Annex II (Part-145) of Regulation (EU) 1321/2014, point 145.A.42, states:
(a) Classification of components. All components shall be classified into the following categories:
(i) Components which are in a satisfactory condition, released on an EASA Form 1 or equivalent and marked in accordance with Subpart Q of the Annex I (Part-21) to Regulation (EU) No 748/2012, unless otherwise specified in Annex I (Part-21) to Regulation (EU) No 748/2012 or in this Annex II (Part-145).
(b) Components, standard parts and materials for installation
(i) The organisation shall establish procedures for the acceptance of components, standard parts and materials for installation to ensure that components, standard parts and materials are in satisfactory condition and meet the applicable requirements of point (a).
(iv) Components referred to in point 21.A.307(c) of the Annex I (Part-21) to Regulation (EU) No 748/2012 shall only be installed if considered eligible for installation by the aircraft owner on its own aircraft.
This point 145.A.42 requires that parts are accompanied with a Form 1 or equivalent, except in the very particular cases covered by 21.A.307(c), applicable to some small aircraft only. Currently, there are no alleviations for COTS equipment. The Agency is aware that mandating a Form1 for all components installed on an aircraft may put Approved Maintenance Organisations in a difficult situation, especially in the case of COTS, and rulemaking RMT.0018 is ongoing in order to improve this situation.
NPA 2017-19 was published as an initial draft proposal allowing the installation of certain parts without a Form 1. Based on the comments received during the NPA consultation, the Agency is amending the proposal which will be formalised in an Agency Opinion, to be adopted in the coming months.