UK will Stop Accepting Some EASA Form 1s When Signed on the Right Side

We all know that UK-CAA is currently accepting EASA Form 1. Last year’s guidance on owner operator acceptance, though, is causing some confusion in the parts community.

For new parts, UK-CAA will accept EASA Form 1. But the story for maintained/overhauled parts is more complicated; these are the parts for which the EASA Form 1 is signed on the right side.

Under UK-CAA provisions, owners and operators will soon be limited in their acceptance of maintenance releases from EASA 145 repair stations (i.e., EASA Form 1). These are going to be maintenance releases for work accomplished.

From 1 April 2022, UK owners/operators can only accept an EASA Form 1 from an EU/EASA approved maintenance organisation that has applied for a UK approval by 31 March 2022.

CAA briefing – Changes to recognition of EASA Form 1, CAP2287 (UK CAA Nov 9, 2021)

The reason for this limit is that the EU-UK trade agreement does not directly permit sharing of aircraft maintenance. instead it draws reference to other agreements like the bilateral agreements. No Maintenance Agreement has yet been concluded between UK-CAA and EASA. Without a maintenance annex between UK-CAA and EASA, there is no continuing legal basis for the acceptance (in the UK) of maintenance performed under EASA 145 certificates.

NOTE: under current plans, UK-CAA expects that the EU-based repair station would issue a UK-CAA Form 1 after it is approved. This plan may change, but if it does not change then EU-based repair stations with UK-CAA Part 145 credentials would no longer issue EASA Form 1 for maintained / overhauled parts. This seems to suggest that an EASA Form 1 issued by an EU-based repair station after it was issued UK-CAA Part 145 credentials would become unacceptable in the UK. This varies from international norms so it is possible that this plan may change.

The UK-CAA’s current position is that EU-based repair stations will need to obtain UK-CAA Part 145 certificates. The deadline for beginning this process is March 31, 2022 but EU repair stations that have applied for UK credentials before April 1, 2022.

This means that distributors who want to sell EU-maintained/overhauled parts into the UK (for installation on UK-registered aircraft) will need to make sure that (1) the EASA Form One was dated March 31, 2022 or earlier OR (2) the repair station that issued the EASA Form One applied for UK-CAA Part 145 credentials by March 31, 2022 (but did not yet obtain that credential). If the planned UK-CAA approach does not change (and they continue to expect dual-certificated repair stations in the EU to issue UK CAA Form 1 instead of EASA Form 1) then EASA Form 1 from these same repair stations would no longer be acceptable in the UK if it that form was issued after the UK-CAA Part 145 certificate was issued.

To aid in understanding what the UK-CAA will accept, I have compiled the table, below. Each reference (except the UK-CAA’s own certificates) includes a link to the applicable document that addresses the relationship vis-a-vis that use of that document. There is a limit to the details that I can fit into a table so please be sure to click through to review any special requirements:

	What will the UK CAA Accept as Airworthiness Documentation for Aircraft Parts intended for Installation on UK-Registered Aircraft?
Properly Completed Document	New Parts (certification)	Maintained Parts (maintenance release)
EASA Form 1	YES	Rules Will Change on April 1, 2022
UK Form 1	YES	YES
FAA Form 8130-3	YES	YES, when issued as a dual FAA-EASA certificate
TCCA Form One	YES	YES
ANAC Form F-100-01	YES	YES, when issued as a dual ANAC-UK CAA certificate

This following table is taken directly from the UK-CAA guidance and it explains the details concerning acceptability of EASA Form 1 as a maintenance release, when the Form 1 was issued after March 31, 2022:

Status of EU/EASA Org	Acceptability	Comments
Application made to CAA	Acceptable	Details provided on CAA website or application receipt
No Application made to CAA	Not Acceptable	No application has been made and therefore outside exemption requirements
CAA Approval Granted to EU/EASA Org	Not Acceptable	Post issuance of CAA UK approval therefore org needs to issue CAA Form 1.