8130-3 Tags and CM Project Number

January 16, 2026 by Leave a comment

Late in 2025, the FAA issued a significant revision to Order 8130.21 (the instructions for completing 81303 tags). After it was released, ASA pointed out that one of the changes was requirement to list the CM project number on the 8130-3.

The problem with this requirement is that the CM project number is not published on an available database (like DRS.FAA.GOV); nor is it readily available for most projects. For most aircraft parts the CM project number is also different from the production approval number. When a manufacturer has multiple production sites, each site may have a different CM project number. ASA members and their DARs have complained that they are unable to reliably find the CM Project Number for most aircraft parts.

ASA has been in discussions with the FAA about this issue. The FAA recognized the difficulties in finding the CM project number, and yesterday FAA signed a deviation memo that removes this “CM Project Number” requirement as it applies to 8130-3 tags signed at a distributor or other non-PAH location.

The deviation memo is identified as AIR-600-DM46.

The deviation memo is not yet publicly available, but is expected to be made available soon on the FAA’s Dynamic Regulatory System (DRS): https://drs.faa.gov.

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ASA Files Comments on 8130.21J

June 7, 2025 by Leave a comment

On Friday June 6, ASA filed comments in response to the FAA’s draft update to Order 8130.21. This FAA order provides instructions for completing the FAA Form 8130-3 with a left-side signature.

The new revision will be numbered Order 8130.21J. The title of the guidance in “Completion of FAA Form 8130-3 under Part 21.”

ASA announced that the draft was open for comment, but the original comment period was quite short, so ASA asked for an extension (which the FAA granted, through June 6).

This is a major rewrite of the guidance, so it is to be expected that the draft-for-comment might still need some work. Many of ASA’s comments highlighted discrepancies that were probably inadvertent (like wrong word choice, or provisions that would have violated existing law). Some others highlighted policy choices that could undermine safety, and recommended alternatives designed to achieve FAA goals without compromising safety.

The FAA Form 8130-3 has evolved into a critical tool for airworthiness assurance in the aircraft parts world. Getting the 8130-3 guidance right is an important step in the continued effort to support safety.

ASA is pleased to be able to work with the FAA to help edit this document and make it ready for eventual release to the public. Cooperation on this document is a great example of the way that the regulators and industry work together toward our common safety goals.

2025-06-06 DRAFT Order 8130.21J – Completion of FAA Form 8130-3 under Part 21 – ASA CommentsDownload

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8130.21J Comment Period Extended Through June 6

April 17, 2025 by Leave a comment

The FAA will extend the comment period for the draft revision to the instructions for completing 8130-3 tags (Order 8130.21J). This draft revision is now open for comment through June 6, 2025. The FAA website should be updated tomorrow to reflect this new date.

We appreciate the FAA’s cooperation in extending this comment period. ASA members who have opinions on this draft should share their comments with ASA at their earliest opportunity, so that ASA can incorporate your ideas into the formal Association comments. 

The FAA has asked the community to remember the regulatory purposes of the 8130-3 tag, and to consider those purposes in formulating their comments.

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8130-3 Instructions: Major Revision is Open for Public Comment

March 21, 2025 by 2 Comments

The FAA has issued a draft revision to the instructions for completing 8130-3 tags. This draft revision is open for comment through April 21, 2025. The form is known in the industry as an “Authorized Release Certificate,” “FAA Form 8130-3,” and an “Airworthiness Approval Tag.”

This is a major overhaul of the guidance, and the draft guidance 8130.21J has been reduced to only 18 pages (including appendices). The existing guidance 8130.21H (change one) is 74 pages.

There is an obvious fear that some of the language that was added to correct past problems, may have been removed from this draft. With this in mind, we are especially interested in your comments about hazards and risks associated with the 8130-3 tag, and instruction language that mitigates those risks.

ASA plans to develop comments in response to the draft. We request that ASA members who have comments submit a copy of those comments to ASA’s General Counsel by April 14, 2025 so that ASA can incorporate your comments into the final industry comments.

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