EASA Warns of Stolen Engine Parts

The European Union Aviation Safety Agency (EASA) has published an unapproved parts notice explaining that a large volume of engine parts were stolen. The stolen parts include parts from CFM56, IAE V2500, PW1100 and RB211 turbofan engines. These parts were intended to be scrapped, and were rerouted late January 2026 when they were intended to go to a contract mutilation facility. They were rerouted by a third party that impersonated the contracted mutilation provider.

The EASA alert includes detailed information on affected serial numbers, part numbers, engine types, and parts descriptions.

ASA members received an email notice about this on Friday, but we wanted to follow-up for community members who might not have received this notice.

To help you respond appropriately, ASA recommends reviewing the following possible actions:

1. Communicate the Information Internally and Externally

Ensure relevant team members—such as quality, supply chain, procurement, operations, and IT—are aware of this notice. Consider handling this as a company-wide notification for reinforcement of our shared responsibility for maintaining a safe supply chain. If applicable, consider sharing the information with trusted external partners who may be affected or may participate in related transactions.

2. Implement an Internal “Flag” for Identified Part Numbers

ASA encourages you to update your internal systems so that any transaction involving the listed part numbers triggers an alert. This flag is not intended to prohibit procurement; rather, it is intended to alert the company’s compliance professionals that additional verification steps may be necessary before the transaction proceeds.

3. Confirm Your Company Is Subscribed to Government Safety Notifications

While ASA will continue to share relevant alerts promptly, it is important that your organization is registered directly with the appropriate government agencies for official notices. Doing so helps ensure you receive real-time information on potential safety or compliance risks. You can create an EASA account and register for EASA unapproved parts notices on the EASA website. You can subscribe to FA unapproved parts notices and other FAA notices on the FAA’s website.

EASA Notification and Details

Full details about the stolen engine parts notice, including the list of affected components (with serial numbers), can be found here:
https://www.easa.europa.eu/en/domains/aircraft-products/suspected-unapproved-parts/theft-turbofan-engine-parts-mutilation

While this notice provides details regarding the stolen parts, ASA feels that even if your company is not involved in the engine parts market, you should think about how you would manage a notice that impacts your business line.

EASA Regular Update of Continuous Airworthiness Regulations; ASA Offers Comments

The European Union Aviation Safety Agency (EASA) has published its latest thoughts about how to improve the EASA continuous airworthiness provisions. These are published in an EASA comment response document and they remain open for public comment through March 31, 2026. The rule-making activity is identified as NPA 2025-12.

The Aviation Suppliers Association has posted comments on this draft document.

One comment that may be particularly important to members was a comment recommending additional text to better support disassembly of aircraft in Europe, and issue of EASA Form 1 for the parts that are removed from such aircraft.

Another ASA comment seeks to describe the state of being in “as removed” condition and to identify such parts as remaining in need of an airworthiness determination before use/installation.

EASA Emergency AD Against Engine Parts

On Saturday, EASA issued an emergency airworthiness directive identifying CFM56 parts that may have been affected by faulty maintenance and thus may be unairworthy.

The emergency AD was issued against dozens of engine models, in the CFM56-2, -3, -5 and -7 families. It is effective as of today, and applies to EASA-registered aircraft.

The AD explains that:

An occurrence has been reported in which evidence of arcing was found on Critical Parts of an engine. Subsequent investigation identified that the root cause was the usage of an induction heater during maintenance in a manner that may have resulted in unintended electrical arcing to those parts.

EASA AD No.: 2024-0067-E (11 March 2024)

The Emergency Airworthiness Directive explains that the list of affected parts described in the document were serviced using the same induction heater and may also be damaged.

The EASA AD requires that the affected parts need to be removed and replaced from engines. The affected parts include CDP seals, HPC stage 3 disks and HPT rear shafts from particular CFM56 engines. The AD prohibits the re-installation of the affected parts, without offering an inspection for airworthiness; thus distributors will want to make sure these affected parts do not enter their systems. If distributors find themselves in possession of these parts, then the parts cannot be subsequently installed on an aircraft engine. For a complete list of the parts and their serial numbers, go to the EASA Emergency AD. Please note that under the emergency AD, there is NO inspection and NO maintenance to resolve the problem. There is only a requirement to remove the parts and prevent them from re-installation.

While the EASA AD only applies to installation in European-registered aircraft, the FAA will probably issue a corollary document to apply the same affect to US-registered aircraft. This is a developing story and ASA will continue to let you know if we learn anything else.

What Does it Mean if a Component has “a Negligible Safety Effect on the Product”? And Does it Change the Documentation Requirements?

Has your aircraft or engine manufacturer designated certain parts as having “a negligible safety effect on the product.” What does this mean? And what sort of documentation should you expect on these parts?

A European rule permits manufacturers to designate certain parts that do not need production approval and do not need EASA Form 1. This is not a novel concept – we have the same rule in the United States. Under the FAA regulations, these components are called “Commercial Parts.” 14 C.F.R. §§ 21.1(b)(3), 21.50(c)

For roughly 15 years, FAA rules have permitted manufacturers to designate parts as “commercial” by demonstrating two facts:

  • The failure of the commercial part, as installed in the product, would not degrade the level of safety of the product; and
  • The part is produced only under the commercial part manufacturer’s specification and marked only with the commercial part manufacturer’s markings

After making an engineering demonstration to show these facts, the design approval holder would then publish the commercial parts in a list that was an element of the Instructions for Continued Airworthiness (ICA).

Very few design approval holders (DAHs) have chosen to take advantage of this opportunity. There are legal liability reasons for being cautious about this, but in addition to increased legal liability, this would also mean that the DAH lose quality control of the transaction. Many production approval holders (PAHs) would prefer to offer direct ship authority to suppliers (or rely on other traditional legal constructs like ‘licensed PMA’) so that the manufacturer (DAH/PAH) can continue to control the quality assurance as well as having contractual provisions limiting the DAH/PAH’s liability in the event of an issue.

I wrote about this EASA proposal in December 2019:

ASA raised a number of concerns when this was proposed.  A few of these concerns were addressed by EASA but not all of them.

The new EASA rule requires the design-approval holder to identify the parts as having “a negligible safety effect on the product.”  This is comparable to the United States’ “commercial parts” rule (14 C.F.R. §§ 21.1(b)(3), 21.50(c)).  So the first problem that we can see with this rule is that the same DAHs who did not designate parts in response to the US rule change are probably not going to designate parts now that EASA has added a comparable rule. 

Right now my biggest concern is that this rule-change will not be useful to most of the industry because of a lack of participation among the DAHs.  The fact that it may not be useful means that any safety-negatives associated with the rule are particularly bitter pills.

The rule change creates new complexity in the system, by permitting parts that previously used the EASA Form 1 to be sold under certificates of conformity, instead. The existing variety of certificates of conformity for standard parts has already created confusion in the industry. Distributors are an important link in the chain of commerce, and they play a vital role in scrutinizing documentation to detect and address problems before those problems can be passed on to an installer.

The rule change creates an opportunity for counterfeit parts to enter the system, because the exempted parts are described only in the ICAs.  Distributors typically do not have access to the ICAs.  This means that distributors will not be able to distinguish a part that is exempt under 21.307(b)(3) from one that is fraudulently claimed to be exempt; and the industry could lose the ability to easily read the new C of Cs for parts that were previously subject to EASA Form 1 but now are being moved to C of Cs.  Fraud is already difficult enough to detect, but the regulatory authorities may no longer have jurisdiction over frauds that do not rely on regulatory authority documentation (like the EASA Form 1), which will diminish some of the front-line response opportunities.

One way to help industry mitigate risks would be for the rule to require publication of the list of “negligible safety parts” (“commercial parts” in the FAA system) to anyone in the industry. This would permit distributors to be able to see who is eligible to produce such parts. When they receive a questionable certificate of conformity for a “negligible safety” part, they would be able to review the list of qualified producers to identify whether that producer was authorized to produce “negligible safety” parts.

The new EASA rule is a manufacturing rule; so how does it intersect with repair station obligations? As we all know, EASA 145.A.42 requires the repair station to obtain an EASA Form 1 or equivalent with each received part. The repair station rules were updated to include an exception for parts that are on one of these “negligible safety” parts lists. Commission Implementing Regulation 2021/700 (EU), Annex II (26 March 2021). Such parts will NOT need an EASA Form 1 or equivalent under the published exception.

Distributors should be especially careful with parts from Europe that are alleged to be subject to the “negligible safety parts” standard. Where possible, reach out to the DAH/PAH and obtain a copy of its “negligible safety parts” list so you can confirm that the European supplier is permitted to produce parts without a Production Organization Approval (POA) and without issuing an EASA Form One.

Also, distributors will want to carefully watch the bilateral agreements to assess when these sorts of parts will be permitted. The current version of the US-EU Technical Implementation Agreement is the April 2019 version, and that version requires EASA form 1 for all parts accepted into the United States. There is an exception for standard parts but there is not yet an exception for “negligible safety parts.” Because these parts woudl not have EASA FOrm 1 (and would appear to be ineligible for such a tag) they would not be eligible for import into the United States under the US-EU agreements. In summary, this means that such parts could be eligible for installation under EASA rules but they would not be eligible for import and installation under FAA rules (e.g. on FAA-registered aircraft) unless the DAH also compiled a commercial parts list under FAA rules.

UK CAA FAQ: UK CAA Documentation Requirements for Parts

QUESTION:

UK CAA accepts 8130-3 tags but not EASA Form 1.  Is it possible for an EU based Part 145 organization who has both EASA and FAA approval to provide only a FAA single release certificate and only present this certificate to the UK based organizations as long as the UK based organizations are accepting of a single release certification for a part.  

SHORT ANSWER:

No.  If you ask an EU-based repair station that has both US and EU repair station credentials to maintain an aircraft part and to issue an 8130-3 to document the work it performed, and then subsequently proffer that 8130-3 as the basis for airworthiness determinations prior to installation on a UK-registered aircraft, then the work may be rejected by the UK on the grounds that it does not meet current UK regulatory requirements.

LONGER ANSWER:

Under the new UK CAA standards that go into effect April 1, 2022, the UK CAA will accept maintenance approved on an 8130-3 tag but will no longer accept maintenance released on an EASA Form 1 when issued after April 1.  The questioner offers a clever approach to the impending UK CAA limits.  Unfortunately, this approach puts form over substance.  The root issue is the governmental oversight of the work – not the way that the work is documented.  Therefore, using a clever approach to change the documentation will not be an acceptable way to circumvent UK CAA maintenance controls. 

There are several inherent problems with this clever approach.  First, it undermines the intent of the regulations.  The current intent of UK CAA is that they will no longer accept maintenance performed by EU repair stations.  Second, because the UK CAA intent is to reject maintenance performed by EU repair stations (except when they obtain UK CAA certification), the UK CAA’s established protocols will not permit the UK to rely on maintenance performed by EU-based repair stations (no matter what documentation they use) [NOTE: EU-based repair stations may apply for UK 145 certification, and then their work becomes acceptable under the UK system].  Third, even if it was not undermining UK CAA intent, it is not currently an available process under the existing bilateral agreements because it does not meet their plain language.

To understand why the clever approach does not work, it is important to understand the basis of aviation maintenance regulation.  Under ICAO standards, the country of registry for an aircraft is responsible for the applicable maintenance standards.  This means that the UK CAA is responsible for the continued airworthiness of aircraft on the UK registry.  The UK CAA issues repair station certificates and provides ongoing oversight to those facilities in order to help manage the continued airworthiness processes.

Under normal bilateral airworthiness relationships, one country may agree to accept maintenance performed by repair stations located in the other.  This can be accomplished through “reciprocal acceptance” or through “dual-certification.”

Under a reciprocal acceptance paradigm, the accepting country (which will be the country of registry with the applicable airworthiness responsibilities) would treat maintenance performed by the maintaining country (which will be the country that issued the repair station certificate) as if it had been performed by a repair station subject to the accepting country’s certificates.  Typically, under a reciprocal acceptance paradigm, the repair station only needs one certificate (from its home government) and that certificate is acceptable for work performed for operators from both jurisdictions.  An example of this can be found in the Canada-US relationship, where each country’s operators are permitted to rely on maintenance performed by the repair stations in the other.  A reciprocal acceptance relationship seems easy, but it requires a tremendous level of trust between the aviation safety authorities.  As a consequence, it is more common to see dual-certification relationships described in bilateral aviation safety agreements.

Under dual-certification relationship, the foreign nation issues foreign repair station certificates in collaboration with the home government.  For example, the EU-US agreements have recognized that the repair station oversight systems of both FAA and EASA are very similar and achieve substantially similar goals.  They have also identified a small number of critical differences between the two repair station certification schemes (these differences are known as “Special Conditions”).  Repair stations in the United States that want to get EASA 145 credentials need to create a manual and a system that addresses those Special Conditions.  An FAA Flight Standards maintenance inspector will inspect the EASA-145 applicant who is locate in the United States to confirm that (1) the repair station meets all of the FAA regulations and (2) the repair station complies with the EASA Special Conditions.  If the repair station meets all of the requirements, then the FAA will recommend to EASA that it issue an EASA 145 certificate and EASA may issue such a certificate.

The FAA and EASA maintain a dual-certification relationship with respect to aviation maintenance.  Repair stations must follow the requirements under that relationship to maintain their repair station credentials.  Under the EU-US bilateral agreement, an EU-based repair station that has both sets of repair station credentials must issue an EASA Form 1 as a release document for maintenance.  It does not have an option to issue an 8130-3 tag.  In the event it must release work that is acceptable in the US but not in the EU, the repair station must release the work on an EASA Form 1 that is annotated with the phrase:

The work identified in Block 11 and described herein has been accomplished in accordance with 14 C.F.R. part 43 and in respect to that work, the items are approved for return to service under certificate no.________.

This product/article meets 145.A.50 requirements, except for the following items, and therefore is “not” eligible to be installed on an EU-registered aircraft:

[** LIST THE DIVERGENCES **]

US-EU Maintenance Annex Guidance, Section C: Appendix 1, para. 7.5 (March 19, 2021).

So the first problem with the clever solution is that an EU-based dual certificated repair station is required to issue an EASA Form 1 under the FAA-EASA Maintenance Annex Guidance.

There is an additional technical impediment.  The US-UK Maintenance Implementation Procedures (MIP) do not blindly rely on the 8130-3 tag.  Under that US-UK MIP agreement, the UK CAA accepts approvals “for return to service by an AMO located in the United States under the FAA’s oversight.”  The US-UK MIP does not accept work performed in the EU.  So there is no legal basis for acceptance in the UK of an 8130-3 that documents work performed in the EU.

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 1YESRules Will Change on April 1, 2022
UK Form 1YESYES
FAA Form 8130-3YESYES, when issued as a dual FAA-EASA certificate
TCCA Form OneYESYES
ANAC Form F-100-01YESYES, 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 OrgAcceptabilityComments
Application made to CAAAcceptableDetails provided on CAA website or application receipt
No Application made to
CAA
Not AcceptableNo application has been made and therefore outside
exemption requirements
CAA Approval Granted to
EU/EASA Org
Not AcceptablePost issuance of CAA UK approval therefore org needs
to issue CAA Form 1.

European SMS Requirements for Repair Stations; Could Indirectly Affect Distributors

According to EASA sources, Safety Management Systems (SMS) requirements should be published as a part of the EASA repair station regulations before the end of the year. The part 145 SMS requirements will likely be published by the European Commission this calendar year, with associated AMCs and GMs coming from EASA. 

The EASA SMS rule for repair stations is expected to be applicable 20 days after the publication date (that’s when compliance is permitted).  Compliance with the EASA SMS rule is expected to be required one year later (385 days after the publication date).  The initial one-year period will be for initial implementing of SMS programs.

After initial implementation, the applicable authorities will audit and provide feedback to help get repair stations into full compliance. Each EASA Part 145 organization will have a two-year period for implementing missing elements with the help of the authorities (e.g. for implementing corrective action in response to authority findings). 

This is a new program so we expect that there will be findings issued against the implementers by the authorities.  The two-year transition period is meant to be a period during which all of the authority findings should be closed.

This should not have an immediate effect on US-based EASA 145 organizations because of the way that the US-EU maintenance agreement (and guidance) is structured; but the essence of that agreement is that both regulatory systems are substantially similar, so the addition of SMS to the EU system opens the door to further negotiations. This is somewhat mitigated by the fact that the United States plans to issue an SMS Notice of Proposed Rulemaking (NPRM) for repair station SMS in September 2022.

By the end of 2024, the European Community expects that all EASA Part 145 organizations should be in full compliance with SMS.

SMS requires communications with business partners, so distributors, and others, who do business with European repair stations should not be surprised if they start seeing communications seeking hazard data, and asking about mitigation strategies for known (or recently discovered) hazards. ASA has already provided SMS training for the community, and will be providing more. ASA plans to provide more SMS-related resources for its members to support their smooth coordination with customers’ SMS programs.

EASA Warns of Stolen Bell Parts

EASA has posted two Suspected Unapproved Parts (SUP) notices. Both SUP Notices are for serialized Bell strap assemblies:

  • Product: BELL AB206 / B206
  • Part name STRAP ASSY
  • Part Number 206-310-004-101

The first SUPs Notice is for Serial Number LPFS8480. The second SUPs Notice is for Serial Number LPFS7659.

The two parts appear to have been reported from Sweden, on or about September 23, 2021.

In each case, EASA states the following:

“EASA has become aware that a Strap Assy with P/N 206-310-004-101 and S/N [see serial numbers, above] and its associated log card have disappeared from a maintenance facility. The part and log card are suspected stolen. The part is considered not-airworthy and not eligible for installation on an aircraft.”

Recommendation: If this part is found in stock or installed on an aircraft, it should be quarantined until a determination can be made regarding its eligibility for installation.”

UK and EU Ink Aviation Manufacturing Deal, Formalizing Acceptance of New Parts

Today, the UK CAA and EU’s EASA signed a Technical Implementation Procedure (TIP).

The purpose of the TIP is to establish the rules for UK and EU acceptance of articles and products produced under the production authority of the other authority. There are correlative agreements regarding design approvals issued by each authority, and the acceptance of each by the other.

This TIP will be important because it affects parts transactions involving third parties. For example, if a US-based distributor has Airbus parts in its US inventory, and those parts were produced under (and tagged under) the authority of EASA, then the sale of those parts for installation on a UK-registered aircraft will be subject to the UK-EASA TIP.

Under the Agreement, the importing authority will expect the following documentation to accompany aircraft parts:

  • For import into the EASA system: an Authorized Release Certificate (CAA Form 1) issued by an authorized UK CAA production organization approval holder [in other words, a UK CAA Form 1 properly signed on the left side]
  • For import into the UK CAA system: an Authorized Release Certificate (EASA Form 1) issued by (a) a production organization approval holder authorized to engage in such activity by an EASA Member State, or (b) a production organization approval holder authorized to engage in such activity by EASA [in other words, an EASA Form 1 properly signed on the left side]

One interesting point is a requirement that instructions for continued airworthiness and other maintenance manuals must be provided for articles to be acceptable for import into each authority. The language specifically states:

“The following documentation will be provided as a condition of acceptance of the civil aeronautical product being imported … ICA and maintenance manuals which include airworthiness limitation sections”

Technical Implementation Procedures for Airworthiness and Environmental Certification Between The Civil Aviation Authority of the United Kingdom And The European Union Aviation Safety Agency, section 6.5.1 (May 17, 2021)

The TIP does not address maintained parts. The authorities are expected to conclude a separate set of procedures for acceptance of maintenance.

EU To Accept UK Production Releases Under EU-UK Trade Agreement

We’ve examined the Trade Agreement between the UK and EU and it provides some useful guidance on aviation safety matters. The Agreement includes an Annex that details the scope of cooperation between the UK and EU in this subject area.

UK CAA Form 1 authorized release certificates signed on the left side by the approved production organization will be accepted in the EU

Trade and Cooperation Agreement between the EU and the UK, Annex AvSaf-1 Art. 21 (31 Dec 2020).

Under the Trade Agreement, the UK and EU each agree:

  • To accept certain approvals without validation (AvSaf 3-4; Annex AvSaf-1 Art. 13):
    • Non-significant supplemental type certificates, non-significant major changes and technical standard order authorizations issued by the EU
    • Minor change / minor repair approvals issued by the UK or EU;
  • To accept through a validation process (AvSaf 3-4; Annex AvSaf-1 Art. 10):
    • EU and UK type certificates;
    • EU significant supplemental type certificates and approvals for significant major changes;
    • UK supplemental type certificates, approvals for major changes, major repairs and technical standard order authorizations
  • To accept the production approval systems of the other (AvSaf 3-4; Annex AvSaf-1 Arts. 21-23);
    • This is limited to the categories of civil aeronautical products that were already subject to that system on 31 December 2020 – later-approved categories must be subject to negotiation;
    • Within these limits, UK CAA Form 1 authorized release certificates signed on the left side by the approved production organization will be accepted in the EU;
  • To limit fees and charges to those “commensurate with the services provided” (AvSaf 13);
  • To exchange accident/incident information (AvSaf 9);
  • When one of them takes immediate measure in response to a safety threat (such as through issue of an airworthiness directive) it will inform the other within 15 days (Article AvSaf 6).

One type of approval that is noticeably absent from this list is maintenance approvals. To address this, EASA issued third-country maintenance approvals to repair stations located in the UK that had previously applied. So maintenance releases from UK-based repair stations will need to be signed under EASA authority to be acceptable in the EU.

We should expect an EU-UK implementation agreement that further explains the mechanisms for acceptance and validation between the two jurisdictions.

There are some remaining issues, especially with respect to multi-country transactions. For example, nations outside of the EU, Canada, Japan and the US will need to decide whether to accept UK approvals. This could make things tricky when dealing with other jurisdictions: China comes to mind as a significant market for which a decision about acceptance of UK releases will need to be made.