My organisation is holder of a type certificate issued by EASA and a Russian operator of my product reported an occurrence to us. Are we allowed to have an exchange with the Russian operator to investigate the reported occurrence?
Answer
The sanctions do not prohibit that technical information is received by EASA type certificate holders (or other EASA design approval holders) from organisations or operators located in Russia. Therefore, EASA type certificate holders are not prevented from receiving or requesting information from a Russian operator of their product with a view to investigating an occurrence and evaluating the related safety issues. However, the EASA type certificate holder should ensure that during those exchanges no technical data or information (including those related to the type design), instruction, advice, working knowledge or skills or consulting services, etc., are provided by that type certificate holder to the Russian operator, as that would be considered provision of technical assistance related to goods and technology which is forbidden by the sanctions.