How do I inform EASA about minor changes?
Generally, if changes are classified minor and do not require a change to the certificate, any method to inform EASA is accepted. This notification should be sent to etsoa [at] easa [dot] europa [dot] eu. It is required to regularly inform EASA about minor changes (at least once per year). The notification can be performed by either providing a summary of changes or the full descriptions of changes.
However, even if no changes had been performed on the ETSO article(s) EASA shall be notified at least once per year that no changes had been performed.
When changes involve a modification to the ETSO authorization, then it is necessary to submit an application through EASA Form 34. The minor change shall be entered in section 3.1 of Form 34.
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 doesn’t 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.
NB_1: Any change has to be substantiated regardless if the change is classified minor or major; the responsibility is on the ETSOA Holder.
NB_2: 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 EASA Form 34 and are considered as a new application.
My company name has changed. Do I have to apply for a re-issuance of the ETSO certificates?
It is up to the ETSOA holders to decide whether they require reissued approvals to reflect the transfer of ownership on the certificates. In case they decide to have the certificates reissued they must file an application through EASA Form 34. The task is charged by the working hours needed. In case the ETSOA holder decides to only inform EASA on the transfer of ownership, EASA will not reissue old certificates, but change the name of the approval holder for new authorizations, and in the list of ETSO authorizations published on its website.
Change of Ownership of a Part of an Organisation holding a ETSO Authorisation
The only way for an ETSO Authorisation to change owner is according to Part21.A.621 a change of ownership of the holder of the ETSO Authorisation. A change of ownership can affect either the entire organisation or only a part thereof. If only a part of the organisation changes owner, both parts have to show that they comply individually with Part 21 requirements for the ETSO Authorisations that will be held by the individual parts of the former united organisation, before the ETSO Authorisations can reflect the new ownership.
Change of Ownership of the Design Data of an ETSO Authorisation
When no change of ownership of the holder of ETSO Authorisation is involved and only the ETSO Authorisation design data are changing owner, the original ETSO Authorisation holder should surrender its certificate(s) and the new owner of the design data may apply for new ETSO Authorisation(s), partially using the original compliance data, if available. This application requires that the organisation of the new owner complies with Part 21 requirements for design and production organisation.