New FAA SUPs Reporting Form

The FAA has published an updated version of the Form 8120-11. This is the form for reporting suspected unapproved parts (SUPs).

One obvious change is the Privacy Act statement, which is bolder and moved to a separate front page (the substance remains similar). The information in the form, though, remains substantially unchanged.

This is not the first update to the form. The 2016 version of the form placed the instructions on the first page so that people could read them before getting to the form (the 2009 version placed the instructions after the form and before the continuation sheet, which caused some confusion).

The FAA estimates that it receives about 150 of these completed forms per year. They also believe that the form takes about 30 minutes to complete. Most importantly, the FAA uses these forms as the first step in assessing whether an unapproved parts investigation is warranted.

If you encounter a Suspected Unapproved Parts, or SUP, then reporting is typically voluntary under the regulations; however many aviation companies have imposed mandatory SUPs reporting requirements on themselves (as a commercial obligation) through their quality manuals or operations manuals.  Be sure to follow your own internal guidance when considering whether to report a SUP!

Suspected Unapproved Parts (SUPs) Reporting on Form 8120-11

The FAA has republished the Form 8120-11. This is the form for reporting suspected unapproved parts (SUPs).

The new version of the form was approved by the White House in 2016.  One new feature is that the completion instructions are on the first page of the standard PDF – before the actual form.  This means that people will typically see the instructions before they start to complete the form.

The 2009 version of the form put the instructions on the second page, between the primary form and the continuation sheet.  It is natural for people to .  ASA has received many questions from members about how to complete the 8120-11 form, and many of those questions were answered in the instructions (found on the second page of the PDF).  This is because it is natural for people to start at the top of page one and work their way through completing the form, without skipping ahead to examine the later parts of the form.  Moving the instructions to page one will hopefully answer many of the questions that arise in completing the form.

If you encounter a Suspected Unapproved Parts, or SUP, then reporting is typically voluntary under the regulations; however many aviation companies have imposed mandatory SUPs reporting requirements on themselves through their quality manuals or operations manuals.  Be sure to follow your own internal guidance when considering whether to report a SUP!

FAA Updates SUPs Guidance

The FAA has updated the guidance on detecting and reporting suspected unapproved parts (SUPs), which is known as Detecting and Reporting Suspected Unapproved Parts, FAA AC 21-29C CHG 2 (August 17, 2011).

The advisory circular’s update provides new references to various sections in Part 21 , to coincide with the October 16, 2009 changes in Part 21.  It also makes reference to the new commercial parts definition (part of the 2009 rule change), and clarifies that commercial parts are approved parts.

References to “fabrication inspection systems” are removed from the guidance (the concept of “fabrication inspection systems” was removed from the regulations in favor of unified standard production quality system regulations for all production approval holders).

Finally, the guidance is updated to reflect changed addresses and telephone contact numbers.

The newest guidance can be found online here: