How do I know whether my proposed change is minor?
The ETSOA holder can perform minor changes. However, he has to inform EASA about minor changes. Major changes lead to a new ETSO authorization. As a general criterion, a change could be classified as “minor” if it does not require a complete re-investigation for assessing the compliance to the applicable requirements.
For minor changes to ETSO articles, per Regulation Commission Regulation (EU) No 748/2012 article 21.A.611(a), the root part of the part number is unchanged and the minor change is identified via “open brackets”. Per 21.A.603(b), an open bracket system should be proposed to accommodate a series of minor changes to an ETSO article.
Any change has to be substantiated regardless if the change is classified minor or major; the responsibility is on the ETSOA Holder.
Substantiation by test does not automatically mean that the change is major.
Examples for minor changes are:
- Part numbers to be added to the list of approved ones (for example to add open brackets)
- Merging of companies and new entity (= change of ownership)
An example for a major change would be the use of a revised ETSO standard. Major changes are submitted through the EASA applicant portal by creating a new application and selecting ETSOA – Initial Approval. Use of Form 34 is not recommended, with the exceptions specified in the FAQ “How do I apply for an ETSO authorisation?”.