European Aviation Safety Agency
Notice of Proposed Amendment 2017-20
Embodiment of level of involvement acceptable means of
compliance and guidance material to Part-21
RMT.0262 (MDM.060)
EXECUTIVE SUMMARY
The objective of this NPA is to support the embodiment of level of involvement (LoI) and other changes into Part 21 as
proposed by European Aviation Safety Agency (EASA) Opinion No 07/2016 (Phase I). The NPA (Phase II) proposes to
amend the related Acceptable Means of Compliance (AMC)/Guidance Material (GM) to Annex I (Part-21) to Regulation
(EU) No 748/2012.
EASA Opinion No 07/2016 proposed to introduce in the product certification process the safety management principles
contained in International Civil Aviation Organization (ICAO) Annex 19. With said Opinion, the first step for the
embodiment of LoI into Part-21 has been completed. As a second step, this NPA proposes to reflect in the related
AMC/GM the amendments proposed by the Opinion. Additionally, new AMC/GM have been created and included in this
NPA to cover the new elements introduced by the Opinion.
This NPA proposes AMC to support an applicant’s proposal for EASA’s LoI in certification projects, as well as EASA’s
determination of its LoI. Furthermore, GM is proposed not only on the application of a risk-based approach for
determining EASA’s LoI, but also on the process used. Furthermore, the GM proposed in the NPA provides guidance on
the application of the new privileges for certain major changes, major repairs, and supplemental type certificates (STCs).
Finally, the NPA includes new or amended AMC/GM based on the amendments to Part-21; in particular, it proposes to
also relocate the guidance on those Part-21 requirements that have been moved from Section A to Section B.
The proposed changes are expected to support the implementation of the amendments to Part-21 proposed by Opinion
No 07/2016. This will improve the effectiveness, efficiency, transparency, and predictability of the certification process,
allowing for a better planning of the process with fewer delays as well as for a better allocation of both EASA’s and the
applicant’s certification staff resources. In addition, compliance with ICAO Annex 19 will be achieved through the
introduction of safety management system (SMS) elements into the certification process.
Action area: Safety management
Affected rules: AMC/GM to Part-21
Affected stakeholders: Design approval holders (DAHs), EASA
Driver: Safety Rulemaking group: No
Impact assessment: Light (ref. NPA 2015-03) Rulemaking Procedure: Standard
27.8.2013 15.12.2017 2018/Q3
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Table of contents
Table of contents
1. About this NPA ..................................................................................................................................... 3
1.1. How this NPA was developed ...................................................................................................................3
1.2. How to comment on this NPA...................................................................................................................3
1.3. The next steps ...........................................................................................................................................3
2. In summary — why and what ............................................................................................................... 4
2.1. Why we need to change the rules — issue/rationale...............................................................................4
2.2. What we want to achieve — objectives ...................................................................................................5
2.3. How we want to achieve it — overview of the proposals ........................................................................5
2.4. What are the expected benefits and drawbacks of the proposals .........................................................18
3. Proposed amendments and rationale in detail .................................................................................... 20
3.1. Draft acceptable means of compliance and guidance material (Draft EASA decision) ..........................20
4. Impact assessment (IA) ....................................................................................................................... 99
5. Proposed actions to support implementation.................................................................................... 100
6. References ....................................................................................................................................... 101
6.1. Related regulations ...............................................................................................................................101
6.2. Affected decisions .................................................................................................................................101
6.3. Other reference documents .................................................................................................................101
7. Appendix — Correlation table between Part 21 and the proposed amendments thereto .................... 102
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1. About this NPA
1. About this NPA
1.1. How this NPA was developed
The European Aviation Safety Agency (EASA) developed this notice of proposed amendment (NPA) in
line with Regulation (EC) No 216/20081 (hereinafter referred to as the ‘Basic Regulation’) and the
Rulemaking Procedure2. This rulemaking activity is included in the EASA 5-year Rulemaking
Programme3 under rulemaking task RMT.0262 (MDM.060) (Phase II). The text of this NPA has been
developed by EASA. It is hereby submitted to all interested parties4 for consultation.
1.2. How to comment on this NPA
Please submit your comments using the automated Comment-Response Tool (CRT) available at
http://hub.easa.europa.eu/crt/5.
The deadline for submission of comments is 15 March 2018.
1.3. The next steps
Following the closing of the public commenting period, EASA will review all comments.
Based on the comments received, EASA will develop a decision amending the Acceptable Means of
Compliance (AMC)/Guidance Material (GM) to Annex I (Part-21) to Regulation (EU) No 748/20126.
The comments received and the EASA responses will be reflected in a comment-response document
(CRD). The CRD will be annexed to the decision, the publication of which is subject to the adoption of
the related European Union (EU) regulation.
1
Regulation (EC) No 216/2008 of the European Parliament and of the Council of 20 February 2008 on common rules in the field of
civil aviation and establishing a European Aviation Safety Agency, and repealing Council Directive 91/670/EEC, Regulation (EC)
No 1592/2002 and Directive 2004/36/EC (OJ L 79, 19.3.2008, p. 1) (http://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1467719701894&uri=CELEX:32008R0216).
2
EASA is bound to follow a structured rulemaking process as required by Article 52(1) of Regulation (EC) No 216/2008. Such a
process has been adopted by the EASA Management Board (MB) and is referred to as the ‘Rulemaking Procedure’. See MB Decision
No 18-2015 of 15 December 2015 replacing Decision 01/2012 concerning the procedure to be applied by EASA for the issuing of
opinions, certification specifications and guidance material (http://www.easa.europa.eu/the-agency/management-
board/decisions/easa-mb-decision-18-2015-rulemaking-procedure).
3
http://easa.europa.eu/rulemaking/annual-programme-and-planning.php
4
In accordance with Article 52 of Regulation (EC) No 216/2008 and Articles 6(3) and 7 of the Rulemaking Procedure.
5
In case of technical problems, please contact the CRT webmaster (
[email protected]).
6
Commission Regulation (EU) No 748/2012 of 3 August 2012 laying down implementing rules for the airworthiness and
environmental certification of aircraft and related products, parts and appliances, as well as for the certification of design and
production organisations (OJ L 224, 21.8.2012, p. 1) (http://eur-lex.europa.eu/legal-
content/EN/TXT/?qid=1511176429493&uri=CELEX:02012R0748-20160126)
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2. In summary — why and what
2. In summary — why and what
2.1. Why we need to change the rules — issue/rationale
On 23 May 2016, EASA published Opinion No 07/2016 ‘Embodiment of level of involvement
requirements into Part-21’7 under RMT.0262 (MDM.060) (Phase I) — see also the related
NPA/CRD 2015-038.
The Opinion addressed the following topics:
A risk-based approach in determining EASA’s level of involvement (LoI) in certification projects
The Opinion proposed to introduce safety management principles into the process of airworthiness
and environmental certification of aircraft and related products, parts and appliances, as well as of
changes and repairs thereto in accordance with Part-21.
The risk-based LoI concept is in line with the safety risk management standards of International Civil
Aviation Organization (ICAO) Annex 19, and will enable EASA to better identify the areas of product
certification that are more prone than others to risk with regard to safety and environmental
protection.
Privilege for certain major changes, major repairs and supplemental type certificates (STCs)
The Opinion also proposed to introduce the possibility for design organisation approval (DOA) holders
to obtain a privilege to approve certain major changes to type certificates (TCs), STCs, and/or major
repair designs.
Relocation of Part-21 requirements
Certain Part-21 requirements have been relocated and sometimes adjusted in order to improve
consistency. In particular, EASA has focused its attention on ensuring that Section A contains
requirements governing the rights and obligations of the applicants for, and holders of, Part-21
certificates and approvals (see 21.A.1), whereas requirements applicable to competent authorities
(CAs), including EASA, are located in Section B.
Alignment with the Basic Regulation regarding the type certification basis (TC basis)
Some inconsistencies between the Basic Regulation and Part-21 have been corrected, in particular with
reference to an equivalent level of safety, deviations, and notification of the TC basis.
Improvements, streamlining, corrections, and consistency issues
Part-21 needs to be periodically reviewed to ensure that changes in certification activities and evolving
technology are properly reflected. For this reason, some of the proposed amendments focus on
updating Part-21 to ensure that it remains a state-of-the-art procedural rule.
Those amendments to Part-21 needed to be reflected in the related AMC/GM, by either reviewing the
existing ones or creating new items.
7
https://www.easa.europa.eu/document-library/opinions/opinion-072016
8
https://www.easa.europa.eu/document-library/notices-of-proposed-amendment/npa-2015-03
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2. In summary — why and what
2.2. What we want to achieve — objectives
The overall objectives of the EASA system are defined in Article 2 of the Basic Regulation. This proposal
will contribute to the achievement of the overall objectives by addressing the issues outlined in
Section 2.1 above.
The specific objective of this proposal is to facilitate the implementation of the embodiment of LoI and
other changes into Part-21 as proposed by Opinion No 07/2016.
2.3. How we want to achieve it — overview of the proposals
EASA reviewed the existing set of AMC/GM to Part-21 and identified those items that needed to be
amended or deleted in order to reflect the changes proposed by Opinion No 07/2016. Additionally,
where needed, new AMC/GM have been developed to support the implementation of the new
elements proposed by the Opinion.
In total, approximately 60 AMC/GM are affected by this proposal. In the majority of the cases, the
AMC/GM have been amended to better reflect the amended Part-21 requirements. In some cases,
new AMC/GM have been created to clarify the intent of some new requirements. In a few cases, the
existing AMC/GM have been deleted as they became obsolete.
Where Part-21 requirements have been relocated from Section A to Section B, the related GM have
been also relocated accordingly.
The following Table 1 summarises the AMC/GM included in this NPA:
Table 1
AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
Some references have
been amended and the
wording introduced by
AMC/GM to Part-21 —
Issue 2, Amendment 6 has
Alternative
21.A.14(b) AMC A been reflected. In
procedures
particular, some
occurrences of ‘change to
type design’ have been
replaced by ‘change(s) to
type certificate’.
This new AMC provides
detailed instructions on
21.A.15(a) AMC N Form and manner
how to download and fill
in the application form.
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2. In summary — why and what
AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
This new AMC provides
detailed information
Content of the about the contents of the
21.A.15(b) AMC N certification certification programme,
programme and has been developed
on the basis of the
existing AMC 21.A.20(b).
This new Appendix A lists
the means of compliance
AMC codes and the associated
Means of compliance
21.A.15(b) (Appendix N compliance documents. It
codes
A) is based on the deleted
Appendix to
AMC 21.A.20(b).
Breakdown of the
This new AMC clarifies the
certification
definition of a CDI as well
21.A.15(b)(5) and programme into
AMC N as the certification
21.B.100(a) compliance
programme breakdown
demonstration items
into meaningful CDIs.
(CDIs)
This new GM provides
detailed information on
updating the contents of
Updates to the
the certification
21.A.15(c) GM N certification
programme. It has been
programme
developed on the basis of
the existing
AMC 21.A.20(b).
Clarification of the
The title and the content
applicability of
have been slightly
21.A.15(d) GM No 1 A operational suitability
amended to improve
data (OSD)
readability.
constituents
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2. In summary — why and what
AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
This new AMC provides
Effectivity dates for
detailed guidance on the
the application for a
extension of the original
21.A.15(e) and (f) GM N type certificate TC or
application date and
restricted type
calculation of the new
certificate (RTC)
effectivity date.
This new GM describes
Compliance
how 21.A.20 should be
21.A.20 GM N demonstration
applied by different
process
applicants.
This new GM provides
Reporting on the
detailed information
compliance
21.A.20(b) GM N about the reporting on
demonstration
the compliance
process
demonstration process.
This AMC has been slightly
Compliance amended to improve its
21.A.20(c) AMC A
documentation wording and include
appropriate references.
This AMC has been
amended to improve its
wording and include
appropriate references.
21.A.20(d) GM A Final statement
Additionally the meaning
and purpose of the final
statement have been
further clarified.
This new GM has been
Clarification of the introduced to clarify the
21.A.21(a)(3)(i) GM N
term ‘determined’. meaning of the term
‘determined’.
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AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
21.A.21(b)
21.A.95(c)
21.A.97(c) This GM has been
Approval of
amended to improve its
21.A.115(c) GM No 1 A operational suitability
wording and correct some
21.B.103(b) data (OSD)
references.
21.B.107(b)
21.B.110(b)
GM 21.A.33 has been
amended to reflect the
deletion of 21.A.33(a) and
to improve its wording.
21.A.33(d) GM A Inspections and tests
The general content of
this GM has been
maintained and linked to
the new 21.A.33(d).
This AMC provides
additional details on
21.A.33 AMC N Inspections and tests ‘inspection and tests’. The
applicability of 21.A.33
has been clarified.
This GM has been slightly
reworded to reflect the
21.A.90A GM A Scope
changes introduced into
21.A.90A.
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AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
This GM has been
substantially amended to
incorporate the
classification part of the
deleted
GM 21.A.263(c)(4).
Additionally, EASA
decided to reintroduce
the one criterion
triggering a ‘major’
classification which was
Classification of
deleted through Decision
21.A.91 GM A changes to a type
2016/007/R related to
certificate (TC)
OSD. Following one
comment received during
the NPA 2015-12
consultation, EASA
decided to delete
‘changes altering
Airworthiness Limitations
or Operating Limitations’,
but this change was later
on widely considered to
be erroneous.
The flow chart of
Appendix A to GM 21.A.91
GM has been amended to
Examples of major
21.A.91 (Appendix A improve terminology,
changes per discipline
A) correct certain references,
and incorporate OSD
considerations.
This new AMC clarifies the
acceptable form and manner
21.A.93(a) AMC N Form and manner
of an application for changes
to TCs.
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AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
This amendment of
GM 21.A.93(b) provides
further clarifications of
Certification the certification
programme for a programme for a change
21.A.93(b) AMC A
change to a TC or an to a TC or an STC.
STC Additionally, the text has
been amended to reflect
the changes introduced
into 21.A.93(b).
Interaction of changes
to the type design and The references of GM No
21.A.93(b)(1)(iii) GM No 1 A changes to 1 to 21.A.93(c) have been
operational suitability updated.
data (OSD)
Interaction of changes
to the type design and The references of GM No
21.A.93(b)(1)(iii) GM No 2 A changes to master 2 to 21.A.93(c) have been
minimum equipment updated.
list (MMEL)
This new GM explains
Requirements for the
further how the new LoI
21.A.95 AMC N approval of a minor
concept is applied to
change
minor changes.
The wording has been
improved, the application
Requirements for the of the LoI concept
21.A.97 AMC A approval of a major clarified, references
change corrected, and the
meaning of ‘specific
configurations’ explained.
Establishment of the
operational suitability This AMC has been slightly
data (OSD) amended to improve the
21.A.101(g) GM1 A
certification basis for wording and include new
changes to type references.
certificates (TCs)
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AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
This new AMC clarifies the
acceptable form and
21.A.113(a) AMC N Form and manner
manner of an application
for STCs.
This new AMC provides
further clarification of the
Requirements for the
requirements for the
issuance of a
21.A.115 AMC N issuance of an STC. Its
supplemental type
contents are partially
certificate (STC)
derived from the deleted
AMC 21.A.114.
GM No 1 21.A.239(a) has
been updated,
subparagraph 3.1.5
Design assurance ‘Maintenance and
21.A.239(a) GM No 1 A
system Operating Instructions’
improved, and the new
obligations introduced by
21.A.265(h) reflected.
Procedure for the
classification of
changes to a type AMC No 1 to
certificate (TC) or to a 21.A.263(c)(1) has been
21.A.263(c)(1) AMC No 1 A
supplemental type amended to improve
certificate (STC) and language and clarity.
repair designs as
‘minor’ or ‘major’
Privileges —
Organisations
designing minor
changes to a type AMC No 2 to
certificate (TC) or a 21.A.263(c)(1) has been
21.A.263(c)(1) AMC No 2 A
supplemental type amended to improve
certificate (STC) and language and clarity.
minor repairs to
products: classification
procedure
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2. In summary — why and what
AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
Procedure for the
approval of minor AMC No 1 to
changes to a type 21.A.263(c)(2) has been
21.A.263(c)(2) AMC No 1 A certificate (TC) or amended to improve
supplemental type language, and include
certificate (SCT) and changes to STCs.
minor repairs
Privileges —
Organisations
designing minor
AMC No 2 to
changes to a type
21.A.263(c)(2) has been
certificate (TC) or a
21.A.263(c)(2) AMC No 2 A amended to improve
supplemental type
language, and include
certificate (STC) and
changes to STCs.
minor repairs to
products: procedure
for approval
This new AMC provides
Procedure for the
further clarification on the
approval of minor
approval of minor
changes to a type
21.A.263(c)(2) AMC No 3 N changes to an aircraft
certificate (TC) which
flight manual (AFM), and
affect the aircraft
is based on the deleted
flight manual (AFM)
GM 21.A.263(c)(4).
AMC 21.A.263(c)(6) has
Procedure for the
been amended to partially
approval of the
21.A.263(c)(6) AMC A incorporate the content of
conditions for issuing
the deleted
a permit to fly
AMC 21.A.263(b)(1).
This new AMC further
explains the scope of the
new design organisation
21.A.263(c)(5)(8)(9) AMC No 1 N Scope and criteria
approval (DOA) privilege,
with particular focus on
the meaning of ‘certain’.
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2. In summary — why and what
AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
Procedure for the
approval of a major
repair, a major change to This new AMC provides
a type certificate (TC), or further clarification to TC
21.A.263(c)(5)(8)(9) AMC No 2 N a supplemental type holders on the approval of
certificate (STC) by a a major change under the
design organisation new privilege.
approval (DOA) holder
under their privileges
This new AMC establishes
a single numbering system
Numbering system for
for the STCs, major
supplemental type
changes, and major
certificates (STCs),
repairs approved using
major changes and
the new privilege. After
21.A.263(c)(5)(8)(9) AMC No 3 N major repairs issued
the approval of STCs, the
by design organisation
DOA holder should submit
approval (DOA)
to EASA the information
holders, and
needed to keep the EASA
information to EASA
STC list updated on the
EASA website.
Designation of data
and information This new GM partially
issued under the incorporates the content
21.A.265(h) GM N
authority of a design of the deleted
organisation approval GM 21.A.263(c)(3).
(DOA) holder
The flow chart for
21.A.431A GM A Scope approval of repairs has
been amended.
Repairs to European
technical standard The title of this GM has
order (ETSO) articles been amended to
21.A.431A(e) GM A
other than to an introduce the correct
auxiliary power unit reference to Part-21.
(APU)
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AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
This new AMC describes
the acceptable form and
21.A.432C(a) AMC N Form and manner manner of an application
for a major repair/major
change to a TC.
This new AMC provides
Certification further clarification to
21.A.432C(b) AMC N programme for a applicants on the content
repair design approval of the certification
programme.
The existing
AMC 21.A.433(a) and
AMC 21.A.447 have been
21.A.433(b) and Repair design and
AMC A amended to reflect the
21.A.447 record keeping
new extended text of
21.A.433 and to update
the references.
This new GM 21.A.435(b)
is based on the existing
21.A.435(b) GM N Repair design approval
GM 21.A.437 and
GM 21.A.437(a).
This new AMC provides
additional clarification on
Certification the newly introduced
21.A.605(a)(1) AMC N
programme requirement for
establishing a certification
programme.
Reporting from the
compliance This new GM provides
demonstration additional guidance on
21.A.605(b) GM N
process and updates difficulties and events to
to the certification be reported to EASA.
programme
This new AMC clarifies the
21.A.606(d) AMC N Declaration declaration required by
21.A.606(d).
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2. In summary — why and what
AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
This new GM provides
additional guidance on
the special conditions
21.B.75 GM N Special conditions introduced into 21.B.75. It
has been partially derived
from the deleted
GM 21.A.16B.
Type-certification This new GM provides
basis for a type additional guidance on
21.B.80 GM N certificate (TC) or ‘elect to comply’,
restricted type equivalent safety findings,
certificate (RTC) and deviations.
Level of involvement This new AMC provides
(LoI) in a certification further clarification on
project for a type how to determine EASA’s
21.B.100(a) and certificate (TC), a LoI considering the new
AMC N
21.A.15(b)(6) major change to a TC, risk-based approach. The
a supplemental type wording stems largely
certificate (STC) or a from the Certification
major repair design Memorandum on LoI9.
This new AMC provides
further clarification on
Level of involvement
how to determine EASA’s
(LoI) in projects for
21.B.100(b) AMC N LoI in certification projects
minor changes and
for minor changes and
minor repairs
repair designs to products
with non-DOA applicants.
Level of involvement This new AMC provides
(LoI) in European further clarification on
21.B.100(b) AMC N technical standard how to determine EASA’s
order authorisation LoI in certification projects
(ETSOA) projects for ETSO articles.
9
http://www.easa.europa.eu/documents/public-consultations/proposed-cm-21a21b-001
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2. In summary — why and what
AMC/GM title
Reference to Part- Amended
AMC/GM (as proposed in this Rationale
21 requirement (*) /new
NPA)
GM No 1 21.A.103,
Operational suitability 21.A.115 and 21.B.70 has
data (OSD) been amended to improve
21.B.107 and
GM A considerations for the wording and update
21.B.110
approval of changes to the links, based on the
type certificates (TCs) changes proposed by
Opinion No 07/2016.
(*) as per Opinion No 07/2016
Note: please refer also to Chapter 7 of this NPA for a comparison between the current AMC/GM to Part-21 and
the future version.
Table 2 below lists the existing AMC/GM that are proposed to be deleted in this NPA:
Table 2
Reference number AMC or GM
AMC/GM title (*) Remarks
(*) (*)
21.A.16B GM Special Conditions Opinion No 07/2016 proposed
to delete 21.A.16B.
21.A.17B(a)(1) GM Reference date for Opinion No 07/2016 proposed
operational suitability to delete 21.A.17B and move its
certification basis contents to 21.B.82; therefore,
this GM is proposed to be
deleted.
21.A.20(b) AMC Certification programme This AMC is proposed to be
deleted and replaced by
GM 21.A.15(c) and
GM 21.A.20(b).
21.A.20(b) GM Update to the This GM is proposed to be
Certification Programme deleted and replaced by
GM 21.A.15(c).
21.A.114 AMC Compliance Opinion No 07/2016 proposed
demonstration process to delete 21.A.114, and partially
for Supplemental Type- include its contents in 21.A.114;
Certificate therefore, this GM is proposed
to be deleted.
21.A.263(b) GM DOA privilege related to Opinion No 2016/07 proposed to
compliance documents delete 21.A.263(b). The content of
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Reference number AMC or GM
AMC/GM title (*) Remarks
(*) (*)
GM 21.A.263(b) has been
superseded by the new LoI concept
explained in AMC 21.B.100(a) and
AMC 21.A.15(b)(6); therefore, this
GM is proposed to be deleted.
21.A.263(b)(1) AMC Compliance documents Opinion No 07/2016 proposed to
with conditions related to delete 21.A.263(b).
engine or propeller AMC 21.A.263(b)(1) is therefore
proposed to be deleted and its
without a type-certificate
contents partially moved to the new
or with unapproved
proposed AMC 21.A.263(c)(6).
changes and fitted on
aircraft for which a
permit to fly is requested
21.A.263(c)(3) GM Issue of information or Opinion No 07/2016 proposed to
instructions delete 21.A.263(c)(3).
GM 21.A.263(c)(3) is therefore
proposed to be deleted and its
contents partially moved to the new
proposed GM 21.A.265(h).
21.A.263(c)(4) GM Procedure for the Opinion No 07/2016 proposed to
approval of minor delete 21.A.263(c)(4).
revisions to the aircraft GM 21.A.263(c)(4) is therefore
proposed to be deleted and its
flight manual
contents partially moved to the
amended GM 21.A.91 and
AMC No 3 to 21.A.263(c)(2).
GM Opinion No 07/2016 proposed to
Issue of repair design
21.A.437 delete 21.A.437, therefore this GM
approval
is proposed to be deleted.
GM Opinion No 07/2016 proposed
Issue of repair design to delete 21.A.437, therefore
21.A.437(a)
approval this GM is proposed to be
deleted.
AMC Opinion No 07/2016 proposed
Issue of repair design to delete 21.A.437, therefore
21.A.437(b)
approval this GM is proposed to be
deleted.
(*) current Part-21 and/or AMC/GM to Part-21.
Note: please refer also to Chapter 7 of this NPA for a comparison between the current AMC/GM to Part-21 and
the future version.
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2. In summary — why and what
It is to be noted that at the time of publication of this NPA, Opinion No 07/2016 is still under review by
the European Commission. It is therefore not possible at this stage to provide a comprehensive list of
AMC/GM for all the proposed amendments to Part-21. Certain AMC/GM, the text of which can only be
proposed after the adoption of the EU regulation amending Regulation (EU) No 748/2012, have been
highlighted in the current NPA as ‘to be developed’. Based on the amending regulation, EASA will
develop the remaining AMC/GM and review the AMC/GM proposed in this NPA.
Additionally, EASA may further develop AMC/GM on the basis of the comments received by
stakeholders during the public consultation of this NPA.
2.4. What are the expected benefits and drawbacks of the proposals
The overall expected benefits and drawbacks of the proposed amendment to AMC/GM to Part-21 are
summarised as follows:
(a) Risk-based approach in determining EASA’s LoI in certification projects
The proposed AMC/GM are expected to ensure an easier implementation of the new risk-based
approach in determining EASA’s LoI by:
(1) supporting applicants in preparing the certification programmes, including a proposal for
EASA’s LoI;
(2) providing interpretative material and guidance on the application of the Part-21
principles; and
(3) explaining how EASA’s LoI will be determined.
(b) Privileges for certain major changes, major repairs, and STCs
This NPA contains three new AMC which are intended to clarify the eligibility of the new
privilege. Additionally, practical guidance is proposed to TC and STC holders for obtaining the
new privilege and approving major changes under this new privilege. These AMC are therefore
expected to facilitate the exercise of the new privilege.
(c) Relocation of Part-21 requirements
This NPA contains the proposed amendments to the existing AMC/GM affected by the relocation
of various Part-21 requirements.
In some cases, the existing AMC/GM have been deleted and new AMC/GM have been developed
on the basis of the existing material.
(d) Alignment with the Basic Regulation regarding the TC basis
This NPA contains new GM introduced to provide additional guidance on ‘elect to comply’,
equivalent safety findings, and deviations.
Furthermore, language inconsistencies between the Basic Regulation and AMC/GM to Part-21
have been corrected, where necessary.
(e) Improvements, streamlining, corrections, consistency issues
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2. In summary — why and what
Language corrections and changes for alignment with Opinion No 07/2016 have been proposed
throughout the AMC/GM contained in this NPA. This is expected to facilitate the applicants in
their demonstration of compliance with Part-21 requirements.
For additional details on the impact assessment (IA) of this NPA, please refer to Chapter 4 below,
NPA 2015-03, and Opinion No 07/2016.
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3. Proposed amendments and rationale in detail
3. Proposed amendments and rationale in detail
The text of the amendment is arranged to show deleted text, new or amended text as shown below:
— deleted text is struck through;
— new or amended text is highlighted in grey;
— an ellipsis ‘[…]’ indicates that the rest of the text is unchanged.
3.1. Draft acceptable means of compliance and guidance material (Draft EASA decision)
3.1.1. Annex I (Part-21) to Regulation (EU) No 748/2012
1. AMC 21.A.14(b) is amended as follows:
AMC 21.A.14(b) Alternative Pprocedures
Alternative procedures are an acceptable means to demonstrate design capability in the cases
described in 21.A.14(b), 21.A.112B(b) or 21.A.432B(b). This concept is the implementation, in the
context of specific projects, of procedures required in Subpart J DOA, to ensure that the applicant will
perform the relevant activities as expected by the AgencyEASA, but without the requirements on the
organisation itself that can be found in Subpart J. The establishment of these alternatives to DOA
procedures may be seen as a starting phase for a Subpart J DOA, allowing at a later stage, at the
discretion of the applicant, the applicant to move towards a full Subpart J DOA by the addition of the
missing elements.
1. Scope
1.1 As an alternative to DOA, a manual of procedures must should be provided that sets out
specific design practices, resources and sequence of activities relevant for the specific
projects, taking account of Part -21 requirements into account.
1.2 These procedures mustshould be concise and limited to the information needed for
quality and proper control of activities by the applicant/holder, and by the AgencyEASA.
2. Management of the (supplemental) type-certification process
2.1 Certification programme: See AMC 21.A.2015(b) for type-certification and
AMC 21.A.11493(b) for supplemental type-certification.
2.2 Compliance demonstration: see GM 21.A.20.
2.3 Reporting: see AMC 21.A.20(b).
2.24 Compliance documentation: see AMC 21.A.20(c).
2.5 Declaration of compliance: see GM 21.A.20(d).
3. Management of design changes, repair designs and production deviations
3.1 ApprovalManagement of changes to a type designcertificate or supplemental type
certificate (hereinafter referred to as ‘changes’), repairs designs and production deviations
from the approved design data.
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3. Proposed amendments and rationale in detail
The TC or STC applicant mustshould provide procedures acceptable to the AgencyEASA for
classification and approval of changes to type design (see paragraphs 3.2 and 3.3), and
repairs designs and production deviations from the approved design data (see paragraph
3.4).
3.2 Classification
3.2.1 Content
The procedure mustshould address the following points:
- identification of the product configuration(s) to which the change is to be made
- identification of changes to type designareas of the product that are changed
or affected by the change
- identification of any reinvestigations necessary (see point 21.A.93(b)(2)),
including identification of applicable certification specifications or
environmental protection requirements and methods of compliance
- airworthiness classification of the whole change and its individual components
(if it consists of more components, see GM 21.A.91, Section 3.2)
- changes to type design initiated by sub-contractors
- documents to justify the classification
- authorised signatories
- the Ccriteria used for classification must be in compliance with 21.A.91 and
corresponding interpretations.
3.2.2 Identification of changes to type design
The procedure mustshould indicate how the following are identified:
- major changes to type design
- those minor changes to type design where additional work is necessary to
demonstrate compliance with the certification specifications
- other minor changes to type design that requireing no further demonstrating
of compliance.
3.2.3 Airworthiness cClassification
The procedure mustshould show how the effects on airworthiness, operational
suitability or environmental protection are analysed, from the very beginning, by
reference to the applicable certification specifications.
If no specific certification specifications are applicable to the change, the above
review mustshould be carried out at the level of the part or system where the change
is integrated and where specific certification specifications are applicable.
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3. Proposed amendments and rationale in detail
3.2.4 Control of changes to type design initiated by sub-contractors
The procedure mustshould indicate, directly or by cross- reference to written
procedures, how changes to type design initiated by sub-contractors are controlled.
3.2.5 Documents to justify the classification
All decisions of classification of changes to type design mustshould be documented
and approved by the AgencyEASA. ItThe documentation may be in the format of
meeting notes or a register.
3.2.6 Authorised signatories
The procedure should identify the persons authorised to sign the proposed
classification before release to the AgencyEASA for approval.
3.3 Approval of changes to type design
3.3.1 Content
The procedure mustshould address the following points:
- compliance documentation
- the internal approval process
- authorised signatories
3.3.2 Compliance documentation
For major changes and those minor changes to type design where additional work to
demonstrate compliance with the applicable certification specifications type
certification basis, operational suitability data certification basis, and environmental
protection requirements (hereinafter referred to as ‘certification basis’) is
necessary, compliance documentation mustshould be established in accordance with
AMC 21.A.20(c).
3.3.3 Approval process
A) For the approval of major changes to type design, a certification programme as
defined in AMC 21.A.973(b) must be established.
B) For major changes and those minor changes to type design where additional
work to showdemonstrate compliance with the applicable certification
basisspecifications is necessary, the procedure should define a document to
support the approval process.
This document mustshould include at least :
- identification and a brief description of the change and its classification
- references to the applicable certification basisspecifications
- reference to the compliance documents
- effects, if any, on limitations and on the approved design
datadocumentation
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3. Proposed amendments and rationale in detail
- the name of the authorised signatory
C) For the other minor changes, the procedure mustshould define a means:
- to identify the change
- to present the change to the AgencyEASA for approval.
3.3.4 Authorised signatories
The procedure mustshould identify the persons authorised to sign the change before
release to the AgencyEASA for approval.
3.4 Repairs designs and production deviations from the approved design data
A procedure following the principles of paragraphs 3.2 and 3.3 mustshould be established
for the classification and approval of repairs designs and unintentional deviations from the
approved design data occurring in production (concessions or non-conformances). For
repairs designs, the procedure mustshould be established in accordance with Part-21,
Section A, Subpart M and the associated acceptable means of compliance (AMC) or
guidance material (GM).
4. Issue of design data and information and(including instructions) to owners, operators or others
required to use the data and information
4.1 General
Design data and Iinformation and instructions include the operational suitability data.
4.2 Data related to changes
The design data and information or(including instructions) issued by the holder of a design
approval (a TC, STC, approval of a changes to type design, approval of a repair design) holder
are intended to provide the owners of a product with all the necessary design data and
information to implementembody a change or a repair on the product, or a repair, or to
inspect it.
The design data and information or(including instructions) may be issued in a format of a
Sservice Bbulletin as defined in ATA 100 system, or in Sstructural Rrepair Mmanuals,
Mmaintenance Mmanuals, Eengine and Ppropeller Mmanuals, etc.
The preparation of this data involves design, production and inspection. The three aspects
should be properly addressed and a procedure should exist.
4.3 Procedure
The procedure should address the following points:
- preparation
- verification of technical consistency with corresponding approved change(s), repair(s)
design(s) or approved data, including effectivity, description, effects on airworthiness
or operational suitability, especially when limitations are changed.
- verification of the feasibility in practical applications.
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3. Proposed amendments and rationale in detail
The persons authorised to sign before release of design data and information and
instructions to the AgencyEASA for approval should be identified in the procedure.
The procedure should include the information or(including instructions) prepared by
sub-contractors or vendors, and declared applicable to its products by the holder of
the TC, STC, approval of changes to type design or approval of repair designs holders.
4.4 Statement
The design data and information and(including instructions) should contain a statement
showing AgencyEASA’s approval.
5. Obligations addressed in 21.A.44 (TC holder), 21.A.118A (STC holder) or 21.A.451 (major repair
design approval holder)
The applicant for alternative procedures to DOA should establish the necessary procedures to
show to the AgencyEASA how it will fulfil the obligations required under 21.A.44, 21.A.118A or
21.A.451, as appropriate.
6. Control of design sub-contractors
The applicant for alternative procedures to DOA should establish the necessary procedures to
show to the AgencyEASA how it will control design sub-contractors and ensure acceptability of the
parts or appliances designed or the design tasks performed.
2. New AMC 21.A.15(a) is inserted as follows:
AMC 21.A.15(a) Form and manner
The applicant should file an application using the web-based ‘EASA Applicant Portal’10 or the
application form for a type certificate or restricted type certificate (FO.CERT.00030)11 which may be
downloaded from the EASA website.
The form should be completed in accordance with the completion instructions embedded at the
bottom of the application form, and sent to EASA by fax, email or regular mail following the
information provided on the EASA website12.
3. New AMC 21.A.15(b) is inserted as follows:
AMC 21.A.15(b) Content of the certification programme
The certification programme is a document that allows the applicant and EASA to manage and control
the evolving product type design, as well as the process of compliance demonstration by the applicant
and its verification by EASA.
The certification programme may be based on modules that may be updated independently.
10
https://ap.easa.europa.eu (changes to the link provided may not be reflected in this document).
11
http://www.easa.europa.eu/document-library/application-forms/focert00030 (changes to the link provided may not be reflected
in this document).
12
https://www.easa.europa.eu/document-library/application-forms/certificates-and-approvals (changes to the link provided may not
be reflected in this document).
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3. Proposed amendments and rationale in detail
The level of detail in the certification programme depends on the complexity of the product and its
intended use.
In particular, the following information should typically be expected:
General
— Identification of the relevant personnel who make decisions affecting airworthiness, operational
suitability and environmental protection and who will interface with EASA, unless otherwise
identified to EASA.
— A project schedule including major milestones.
— Subcontracting arrangements for design and/or production as well as design organisation
approval (DOA) responsibility sharing.
21.A.15(b)(1) ‘a detailed description of the type design, including all the configurations to be certified’
Overview of:
— architecture, functions, systems;
— dimensions, design weights, payloads, design speeds;
— engines and power/thrust rating;
— materials and technologies;
— maximum passenger seating capacity, minimum flight and cabin crew;
— cabin configuration aspects;
— options (e.g. weight variants, power/thrust rating variants, optional avionics equipment items,
auxiliary power unit (APU) choices, brake options, tire options, floats, skids); and
— noise/emissions level.
21.A.15(b)(2) ‘proposed operating characteristics and limitations’
— Operating speed limitations.
— Service ceiling, maximum airfield elevation.
— Cabin pressure.
— Limit load factors.
— Number of passengers, minimum crew, payload, range.
— Weight and centre of gravity (CG) envelope and fuel loading.
— Performance.
— Environmental envelope.
— Runway surface conditions.
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21.A.15(b)(3) ‘the intended use of the product and the kind of operations for which certification is
requested’
— Category A or B (relevant for CS-27 and CS-29), ditching, take-off and landing on water,
emergency floatation equipment.
— Extended overwater operation, high-altitude operation (above 41 000 ft).
— High-airfield operation, steep approach, short take-off and landing, extended-range twin-engine
operations (ETOPS), all-weather operations (AWO), visual flight rules (VFR)/instrument flight
rules (IFR), reduced vertical separation minimum (RVSM), required navigation performance
(RNP) type, increased bank angles, single-pilot operation, flight into known icing conditions.
— Flight in ice crystal icing.
— Engine operations in ice-forming conditions, helicopter hoist operations, operation on unpaved
runway, operation on narrow runway.
— Take-off and landing in tailwind.
— Volcanic-ash operation (limitation or operation as per CS 25.1593 and CS-E 1050).
— Design service goal (DSG)/limit of validity targets.
— Fatigue missions (general description of assumptions for flight durations, main phases, and
parameters, as appropriate).
21.A.15(b)(4) ‘a proposal for the initial type-certification basis, operational suitability data certification
basis, where applicable, and environmental protection requirements, considering the requirements
and options specified in 21.B.80, 21.B.82 and 21.B.85’
The proposed certification basis should include applicable certification specifications, proposed special
conditions, proposed equivalent safety findings, as well as a proposed ‘elect to comply’ and proposed
deviations, as applicable.
21.A.15(b)(5) ‘a proposal for a breakdown of the certification programme into compliance
demonstration items, including references to their proposed means of compliance and related
compliance documents’
See AMC21.A.15(b)(5) and 21.B.100(a) for compliance demonstration item (CDI) determination.
21.A.15(b)(6) on information relevant for the determination of the level of involvement (LoI)
The applicant should provide sufficient detailed information about the novelty, complexity, and
severity aspects of each proposed CDI.
It is recommended to provide this information at the level of each EASA panel or discipline affected by
a proposed CDI. Further interpretative material on the necessary level of details is provided in
AMC 21.B.100(a) and 21.A.15(b)(6).
The applicant should provide sufficient detailed information about the proposed means of compliance
with the applicable requirements identified under 21.A.15(b)(4), to enable EASA to determine its
(initial) LoI. This should include the following, as far as this information is available at the time of
submission to EASA:
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3. Proposed amendments and rationale in detail
— a compliance checklist addressing each requirement, the proposed means of compliance (see
Appendix A to AMC 21.A.15(b) below for the relevant codes), and the related compliance
document(s);
— identification of industry standards (Society of Automotive Engineers (SAE), American Society for
Testing and Materials (ASTM), European Organisation for Civil Aviation Equipment (EUROCAE),
etc.), methodology documents, handbooks, technical procedures, certification memoranda,
policy statements, guidance material, etc., that should be followed in the demonstration of
compliance;
— when the compliance demonstration involves testing, a description of the ground and flight test
article(s), test method(s), test location(s), test schedule, test house(s), test conditions (e.g. limit
load, ultimate load), as well as of the intent/objective(s) of the testing; and
— when the compliance demonstration involves analysis/calculations, a description/identification
of the tools (e.g. name and version/release of the software programmes) and methods used, the
associated assumptions, limitations and/or conditions, as well as of the intended use and
purpose; furthermore, the validation and verification of such tools and methods should be
addressed.
For every aspect mentioned above, the applicant should clearly identify whether the demonstration of
compliance involves any novel or unusual method (analysis or test), either for the applicant or for
industry in general. This should include any deviations from published AMC/GM.
4. New Appendix A to AMC 21.A.15(b) is inserted as follows:
Appendix A to AMC 21.A.15(b) Means of compliance codes
Type of compliance Means of compliance Associated compliance documents
MC0: (a) Design data
(a) compliance statement (b) Recorded statements
(b) reference to design data
(c) election of methods, factors, etc.
Engineering evaluation (d) definitions
(c) Descriptions
MC1: design review
(d) Drawings
MC2: calculation/analysis (e) Substantiation reports
MC3: safety assessment (f) Safety analysis
MC4: laboratory tests
MC5: ground tests on related (g) Test programmes
Tests product(s) (h) Test reports
MC6: flight tests (i) Test interpretations
MC8: simulation
Inspection MC7: design inspection/audit (j) Inspection or audit reports
Equipment qualification MC9: equipment qualification Note: equipment qualification is a
process that may include all previous
means of compliance at equipment
level.
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5. New AMC 21.A.15(b)(5) and 21.B.100(a) is inserted as follows:
AMC 21.A.15(b)(5) and 21.B.100(a) Breakdown of the certification programme into compliance
demonstration items (CDIs)
1. What is a CDI?
A CDI is a meaningful group of compliance demonstration activities and data identified in the
certification programme which can be considered in isolation for the purpose of performing the
risk assessment that allows EASA to determine its level of involvement (LoI) using a risk-based
approach.
The possibility to create this grouping of compliance demonstration activities and data is
intended to facilitate the risk assessment. However, there may be cases in which the risk
assessment may also be performed at the level of the compliance demonstration activity or
data, or at the level of the whole certification project.
The chosen breakdown into CDIs may affect the resulting risk classes (please refer to
AMC 21.B.100(a) and 21.A.15(b)(6)), but should not have any effect on the compliance
demonstration itself or on EASA’s overall LoI.
2. The grouping of compliance demonstration activities and data
The compliance demonstration activities and data grouped in a CDI may demonstrate
compliance with a requirement, a group of requirements, or even a part of a requirement. In this
context, ‘requirement’ means any element of the type certification basis or operational
suitability data (OSD) certification basis as specified in 21.B.80 and 21.B.82, or environmental
protection requirement as specified in 21.B.85.
A CDI may comprise any of the means of compliance listed in Appendix A to AMC 21.A.15(b).
CDIs may be tailored to the scope and size of the project. On simple projects, a CDI may address
all compliance demonstration activities within a given technical area (e.g. avionics, flight,
structures, hydromechanical systems, OSD-cabin crew data (CCD), etc.) or of the whole project.
A CDI should not be too large, combining completely unrelated compliance demonstration
activities or data, that it becomes meaningless, but it should not be too small either so that it
may not be considered in isolation from some other related compliance demonstration activities
or data.
A way of meaningful grouping, for example, is to select some activities and data and group them
into a single CDI as the certification programme must already contain the applicable
requirements, the proposed means of compliance for each requirement, as well as the
associated compliance documents for each means of compliance.
Another way to make a meaningful grouping is to group data at the level of the technically
related compliance demonstration activities and data. This may ease the assessment of those
activities and data against the novelty, complexity, and criticality criteria (see AMC 21.B.100(a)
and 21.A.15(b)(6)). The resultant CDI may encompass various means of compliance.
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3. Description of CDIs
Each CDI should be sufficiently described in the certification programme and should detail the
following:
— the scope of the CDI; and
— information on the novelty, complexity, and criticality of the item being certified.
However, in obvious cases, no detailed justification is necessary to explain the rationale used by
the applicants to assess the novelty, complexity, and criticality of the CDI.
Additionally, it is recommended to identify the EASA panel(s)/discipline(s) affected by each CDI
as this will support the determination of novelty, complexity, design organisation approval (DOA)
performance, and criticality.
6. New GM 21.A.15(c) is inserted as follows:
GM 21.A.15(c) Updates to the certification programme
Point 21.A.15(b) recognises that the initial submission of the certification programme may not be fully
complete, e.g. due to schedule constraints of the design, analysis and testing activities.
Furthermore, even if the initial submission of the certification programme is complete, it may be
necessary to amend it throughout the duration of the project.
The certification programme should be updated and resubmitted to EASA. In particular, updates to the
following elements should be provided:
— any complementary information that was not included in the initial submission of the
certification programme;
— any change in the intended use or kind of operations of the product itself, or of the aircraft on
which the product is installed;
— any change in the key characteristics of the product such as, but not limited to, any declared
limits as intended to be recorded in the type certificate data sheet (TCDS);
— any change in the product design or characteristics that may affect the criteria used to assess the
likelihood of an unidentified non-compliance with the type certification basis, operational
suitability data (OSD) certification basis or the environmental protection requirements, including
the potential impact of that non-compliance on product safety or environmental protection, as
defined in 21.A.15(b)(6) and 21.B.100(a)(1)-(4);
— any change to the initial type certification basis, OSD certification basis or environmental
protection requirements, as applicable to the product, whether that change is initiated by EASA
or by the applicant;
— any change in the breakdown of the certification programme into compliance demonstration
items (CDIs) or in the content of those CDIs;
— any change in the proposed means of compliance, including its/their methodology;
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— any change in the structure of compliance documents that may affect the determination of
EASA’s level of involvement (LoI), as defined in 21.B.100;
— any relevant change to the design organisation approval (DOA) holder’s personnel (and design
organisation (DO) suppliers) involved in the project; and
— relevant changes to the schedule.
Following each update to the certification programme as submitted by the applicant, EASA may update
the determination of its LoI in accordance with 21.B.100(c).
7. GM No 1 to 21.A.15(d) is amended as follows:
GM No 1 to 21.A.15(d) Clarification of the term ‘as applicable’applicability of operational suitability
data (OSD) constituents
The term ‘as applicable’ indicates that not all OSD constituents as listed in 21.A.15(d)(1) through (5) are
not always part of the OSD.
[…]
8. New GM to 21.A.15(e) and (f) is inserted as follows:
GM 21.A.15(e) and (f) Effectivity dates for the application for a type certificate (TC) or restricted
type certificate (RTC)
Point 21.A.15(e) establishes a maximum effectivity period for an application for a TC or an RTC. During
this period, the type certification basis, operational suitability data (OSD) certification basis, and the
environmental protection requirements (hereinafter referred to as ‘certification basis’), established
and notified by EASA in accordance with points 21.B.80, 21.B.82, and 21.B.85, remain effective.
However, the effectivity of the certification basis is limited so that the standards notified as part of the
certification basis at the time of application do not become outdated.
For various reasons (e.g. development, business, commercial, etc.), the applicant may not be able to
complete the certification within the established time limit. In this case, the applicant has the following
two options (see 21.A.15(f)(1) and (2)):
1. Submit a new application
In this case, EASA establishes and notifies a new certification basis in accordance with points
21.B.80, 21.B.82, and 21.B.85, considering the standards available at the date of the new
application.
In accordance with point 21.A.15(e), the new application has a maximum effectivity period equal
to the first one, corresponding to the product category. Beyond this effectivity period, the
applicant may need to choose again between the two options of either submitting a new
application or applying for an extension of this application.
2. Apply for an extension of the original application
In this case, the applicant proposes to EASA a ‘new target date’ for the issuance of the certificate
and selects a date that becomes the reference date for the establishment of the certification
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basis by EASA. For the purposes of this GM, the selected reference date is referred to as ‘new
effectivity date’ of the initial application.
The ‘new effectivity date’ of the initial application may be any date in the past between the
following limits:
— the ‘new target date’ for a TC proposed by the applicant minus the time limit used under
21.A.15(e) (e.g. 5 years for large aeroplanes and large rotorcraft, 3 years for the other
products); and
— the date at which the applicant applies for the extension of the application.
This calculation is visualised in Figure 1 below:
Range of
acceptable ‘new
effectivity dates’
Original Application for an Original TC New TC
application date extension date target date target date
Time line
21.A.15(e)
21.A.15(e)
Figure 1
This ensures that the standards used to establish the certification basis are never older than the
ones available at the start of the effectivity period required by point 21.A.15(e).
If the applicant is not able to complete the product certification by the new target date, the
applicant may choose again between the two options of either submitting a new application or
applying for a new extension of this application.
9. GM 21.A.16B is deleted.
10. GM 21.A.17B(a)(1) is deleted.
11. AMC 21.A.20(b) is deleted.
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12. Appendix to AMC 21.A.20(b) is deleted.
13. GM 21.A.20(b) is deleted.
14. New GM 21.A.20 is inserted as follows:
GM 21.A.20 Compliance demonstration process
Point 21.A.20 applies to the compliance demonstration process for a type certificate (TC) (or a
restricted type certificate (RTC)) and, by cross references to Part-21, Subpart D and E, to compliance
demonstration processes for major changes to a TC (see point 21.A.97(b)(3)) and an STC (see
point 21.A.115(b)(4)).
Applicants for a TC (or an RTC) should apply point 21.A.20 in full. Applicants for a major change to a TC
or an STC are required (see points 21.A.97(b)(3) and 21.A.115(b)(4)) to apply point 21.A.20.
‘As applicable to the change’ means that:
— the certification programme to be followed is the one prepared for the major change or STC in
accordance with point 21.A.93, as accepted by EASA: and
— the certification basis (consisting of the type certification basis, operational suitability data (OSD)
certification basis, and the environmental protection requirements) is the one established by
EASA in accordance with point 21.A.101 and notified to the applicant in accordance with
point 21.B.105 (for a major change to a TC) or point 21.B.109 (for an STC).
Point 21.A.20 also applies to major changes to a TC or an STC approved by design organisation
approval (DOA) holders under their privilege as per point 21.A.263(c)(8) or (9) (see also points
21.A.97(b)(3) and 21.A.115(b)(4)). As in this case there is no application and no EASA involvement,
point 21.A.20 should be applied with the following adaptions:
— the certification programme to be followed, including the certification basis and the detailed
means of compliance, should be almost identical to the one accepted by EASA for a major
change or an STC when approved for the scope of the privilege as per point 21.A.263(c)(8) or (9);
it may differ in some aspects (e.g. the detailed description of the changes), but it should be
shown to remain in the frame of the corresponding justification document; and
— the means by which such compliance has been demonstrated (see point 21.A.20(a)) and the final
declaration of compliance (see point 21.A.20(e)) should be kept on record and submitted to
EASA only if EASA requests them during its DOA continued surveillance process.
15. New GM 21.A.20(b) is inserted as follows:
GM 21.A.20(b) Reporting on the compliance demonstration process
The applicant should report to EASA any unexpected difficulty or event encountered during the
compliance demonstration that invalidates or appreciably affects the assumptions previously made, for
example:
— an increase in the severity of the consequences of a certain condition (e.g. failure mode) of the
product;
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— significantly reduced margin(s) for the ‘pass/fail’ criteria of the compliance demonstration;
— changes to the test sequences and conditions that are not in line with the certification
specifications or guidance;
— an unusual interpretation of the results of the compliance demonstration; and
— any significant failure or finding resulting from the tests performed as per points 21.A.33 or
21.A.35.
The applicant should also evaluate whether the unexpected difficulty or event encountered will impact
the certification programme and, if necessary, amend it as per point 21.A.15(c).
16. AMC 21.A.20(c) is amended as follows:
AMC 21.A.20(c) Compliance documentation
1. Compliance documentation comprises of one or more test or inspection programmes/plans,
reports, drawings, specifications, calculations, analysis etc. and provides a record of the means
by which compliance with the applicable type-certification basis, the operational suitability
certification basis and environmental protection requirements is demonstrated.
2. Each compliance document should normally contain:
- an adequate link with the corresponding certification programme
- the reference of the certification specifications, special conditions or environmental
protection requirements addressed by the document;
- substantiation data demonstrating compliance (except test or inspection
programmes/plans);
- a statement by the applicant declaring that the document provides the proof of
compliance for which it has been created; and
- the appropriate authorised signature.
3. Each compliance document should have a number and issue date. The various issues of a
document should be controlled and comply with point 21.A.55.
17. GM 21.A.20(d) is amended as follows:
GM 21.A.20(d) Final statement
All compliance demonstrations in accordance with the certification programme, including all the
inspections and tests in accordance with point 21.A.33 and all flight tests (including the function and
reliability tests) in accordance with point 21.A.35, should be completed before the issuance of the final
statement of compliance required by point 21.A.20(d).
If so agreed by the AgencyEASA, some compliance documentation may be produced after the issuance
of the final statement of compliance required by 21.A.20(d).
‘No feature or characteristics’ in point 21.A.20(d)(2) means the following: while every effort is made to
address in the applicable certification basis all the risks to product safety or environment that may be
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caused by the product, experience shows that safety-related events may occur with products in
service, even though compliance with the certification basis is fully demonstrated. One of the reasons
may be that some existing risks are not properly addressed in the certification basis. Therefore, the
applicant has to declare that they have not identified any such features or characteristics.
Point 21.A.20 also applies by reference to minor changes, in which case the risk to product safety or to
environmental protection is quite low. Nevertheless, minor changes should not be approved if either
the applicant/design organisation approval (DOA) holder approving minor changes under their
privileges, or EASA, is aware of a feature or characteristic that may make the product unsafe for the
uses for which certification is requested.
18. New GM 21.A.21(a)(3)(i) is inserted as follows:
GM 21.A.21(a)(3)(i) Clarification of the term ‘determined’
A type certificate ‘determined’ in accordance with Part-21 means a type certificate, or a document
allowing the issuance of a certificate of airworthiness, issued before 28 September 2003 by a Member
State complying with Article 3(1)(a) of Regulation (EU) No 748/2012.
19. GM No 1 to 21.A.21(f), 21.A.23(b) and 21.A.103(a)(4) is amended as follows:
GM No 1 to 21.A.21(f)(b), 21.A.23(b) and 21.A.103(a)(4)21.A.95(c), 21.A.97(c), 21.A.115(c),
21.B.103(b), 21.B.107(b) and 21.B.110(b) Approval of operational suitability data (OSD)
It is acknowledged that it may not always be possible to have the operational suitability data available
on the date of the issue of the (restricted) type certificate (TC), change approval or supplemental type
certificate (STC). The derogation provided by points 21.A.21(fb), 21.A.23(b) and
21.A.103(a)(4)21.A.95(c), 21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.110(b) areis
intended for that case. The TC, change approval or STC can be issued before compliance with the
operational suitability dataOSD certification basis has been demonstrated.
However, the OSD have toneeds to be approved before the data must beis used by a training
organisation for the purpose of obtaining a European Union (EU) licence, rating or attestation, or by an
EU operator. This is normally done uponbefore entry into service of the first aircraft by an EU operator
but could also be later for some of the OSD constituents, such as the definition of scope of validation
source data to support the objective qualification of a simulator, which should only be available when a
simulator has to be qualified.
The derogation in points 21.A.103(a)(4)(21.A.97(c), 21.A.115(c), 21.B.103(b), 21.B.107(b), and
21.B.110(b) is applicable to all major changes to a TC, so it is also applicable to minor design changes
when triggering a major master minimum equipment list (MMEL) change, and alsoas well as to changes
where onlyat least one of the OSD constituent changes is major.
However, there may be a need to make one or several OSD constituents available before the entry into
service. For example, there may be a need to start training activities before all OSD constituents
contained in the OSD application can be approved. Making use of the derogation of point 21.A.21(f),
21.A.23(b), or 21.A.103(a)(4), the relevant OSD constituent can be approved under the TC, a change
approval or the STC, the use of which can then be limited to specific purposes.
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There may, in some specific cases, even be a need to make provisional OSD available before the TC (or
STC) is issued. In such cases, before the availability of a complete and fully compliant OSD, the Agency
can confirm partial compliance of only one or several provisional OSD constituents.
20. GM 21.A.33 is amended as follows
GM 21.A.33(d) Inspections and Ttests
The obligation of the applicant to allow EASA to witness or carry out any test or inspection as per
point 21.A.33(d) applies generally once the applicant completes the compliance demonstration and
issues the declaration of compliance as per point 21.A.20(d).
Moreover, for extensive certification projects, the following more practical arrangement applies. The
requirements of 21.A.33(a) should not preclude the applicant requestingmay request the AgencyEASA
to makeperform or witness flight or other tests of particular aspects of the product during its
development and before the type design is fully defined and a Ddeclaration of Ccompliance can be
issued for all the applicable certification specifications (CSs). However in case of flight test, before EASA
performs or witnesses any flight test, the applicant should have performed subjectthese tests already
before the AgencyEASA tests and should ensure that no features of the product preclude the safe
conduct of the evaluation requested.
The AgencyEASA may require to repeatany such tests to be repeated once the type design is fully
defined to ensure that subsequent changes have not adversely affected the conclusions from any
earlier evaluation.
A statement of complianceconformity withas per point 21.A.33(b)(c) is also required for the above
tests.
21. New AMC 21.A.33 is inserted as follows:
AMC 21.A.33 Inspections and tests
Use of the term ‘applicant’: point 21.A.33 is applicable to type certification, major changes, major
repairs and supplemental type certificates (STCs). Despite using the word ‘applicant’, it is also
applicable to major changes, major repairs and STCs approved under DOA privileges (see
point 21.A.263(c),(5),(8) or (9)).
Proposed type design: this term defines the type design (or the portion of the type design) as it is
determined at the time when the inspection or test is undertaken.
Statement of conformity: for each certification inspection or test, the statement of conformity issued
in accordance with point 21.A.33(c), must address the conformity of the test specimen (see point
21.A.33(b)(1)) as well as of the test equipment and measuring equipment (see point 21.A.33(b)(2)).
Conformity of the test specimen: the statement of conformity required by point 21.A.33(c) is intended
to ensure that the manufactured test specimen adequately represents the proposed type design.
Possible types of non-conformity may be the following:
— Non-conformity between the design of the test specimen and the proposed type design. These
are typically defined in the early stage of the test planning, and should be addressed as early as
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possible (e.g. in the test plan). There may be several reasons for such a non-conformity: to
account for interfaces with the test equipment, to conservatively cover several or future design
configurations, etc.
— Non-conformity between the manufactured test specimen and the design of the test specimen.
Such a non-conformity may be the result of the manufacturing of the test specimen.
While it is convenient to define any possible non-conformity in (a) as early as possible, the applicant
does not need to make the distinction between (a) and (b) as long as both types of non-conformity are
explicitly addressed and justified in the statement of conformity or by cross reference to the test plan
or other documents.
Type certification is typically an iterative process where the design is under continuous evolution. If the
type design evolves since the time of the inspection or test, then the final type design should be
checked against the proposed type design (at the time of the inspection or test) and differences (if any)
should be analysed to ensure that the inspection or test results are representative of the final
configuration. However, such changes made to the type design may lead to invalidation of the
inspection or test results and a need to repeat the inspection or test. It is recommended that the
design organisation has a solid configuration management process to track the evolving type design.
Conformity of test and measuring equipment: the configuration of the test and measuring equipment
should be defined in the test plan and include the following:
— definition/design of the test equipment (relevant tools, mechanical parts, electronic components
used to execute the test); and
— definition of the measuring equipment:
type/model of sensors, together with their technical characteristics;
position and orientation of exciters and sensors; and
measuring electronic equipment (in some cases, this may include also the technique of
acquisition and post-processing of data).
The configuration of the test and measuring equipment should be defined and controlled through
certification test plans and supporting documentation, according to the design assurance system, if
applicable. The test plan should also include the following elements:
— the test cases, methods, and procedures for test execution;
— the pass-fail criteria; and
— pre-, during- and post-test inspections.
The statement of conformity of point 21.A.33(c) should confirm that the test and measuring
equipment conforms to its purpose, and that the sensors and measuring system are appropriately
calibrated. Any non-conformity should be assessed and it should be justified that it will not
compromise the test purpose and results. This can be done either in the statement of conformity or by
cross reference to other documents (test minutes of meetings, test notes, etc.).
Use of the term ‘adequate’: the test specimen as well as the test and measuring equipment are
considered to be ‘adequate’ as long as the test execution on the manufactured test specimen
(including any non-conformity) and the use of the installed test set-up does not compromise the test
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purpose and results (for example, by providing better performance than the proposed type design or
masking any potential failure mode or behaviour).
Changes that affect the validity of the statement of conformity (see point 21.A.33(e)(2)): if changes
need to be introduced to the test specimen or to the test and measurement equipment after the
statement of conformity is issued (and before the test is undertaken), the statement of conformity
must be updated. The updated statement of conformity must be made available to EASA before the
test if EASA informed the applicant that it will witness or carry out the tests.
Development versus certification tests: sometimes, tests of specimens that conform to a preliminary
design but are not intended for certification (known as development tests) are performed as part of a
risk control strategy and to develop knowledge of a subject. Problems and failures found during
development are part of the process of increasing the understanding of the design, including its failure
modes and the potential for optimisation. Such development tests do not need to meet the
requirements of point 21.A.33.
Any planned test event should be declared in advance to be either a development test or a certification
test. Tests that are intended to be performed only once should be declared certification tests.
Nevertheless, if agreed by EASA, it is acceptable for a development test to finally form part of the
compliance demonstration, and it may be declared afterwards a certification test as long as it meets
the requirements of point 21.A.33. For this reason, it is important to keep the configuration of such
tests under the control of the design organisation.
In addition to this, the level of involvement (LoI) notified by EASA as per 21.B.100(c) should be taken
into account: if EASA has determined that it will witness or conduct a certain test, this test may need to
be repeated so that EASA witnesses or conducts the test.
If the test specimen used for a certification test has already undergone a series of previous tests that
may affect or ultimately invalidate its acceptance as required by point 21.A.33(b), this aspect should be
considered when issuing the statement of conformity required by point 21.A.33(c), and specific
analyses or inspections may be required to support such a statement.
Because of the above aspects, EASA advises applicants to inform EASA if they intend to conduct a
campaign of development tests that may eventually be used as certification tests.
Availability of compliance data (see point 21.A.33(d)(1)): data and information requested from the
applicant for review should be made available in a reliable and efficient way agreed between the
applicant and EASA.
Point 21.A.33(d)(1) refers to any data or information related to compliance data; the scope of said
requirement is therefore not limited to inspections and tests. In particular, point 21.A.33(d)(1) is not
limited to data and information related to compliance demonstration items (CDIs) in which EASA is
involved.
22. GM to 21.A.90A is amended as follows:
GM to 21.A.90A Scope
The term ‘changes to the type certificate’ is consistently used in Part-21, Subpart D and E, as well as in
the related AMC and GM. This term does not refer to changing the document that reflects the type
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certificate (TC) but to the concept of TC as defined in 21.A.41. It means that the processes for the
approval of changes, as described in the said two Subparts, do not only apply to changes to the type
design, but may also apply to changes to:
— the operating limitations;
— the type certificate data sheet (TCDS) for airworthiness and emissions;
— the applicable type certification basis and environmental protection requirements with which
the Agencyapplicant has to demonstrates compliance;
— any other conditions or limitations prescribed for the product in the applicable certification
specifications (CSs) and environmental protection requirementsby EASA;
— the applicable operational suitability data (OSD) certification basis;
— the OSD; and
— the TCDS for noise.
NOTE: OSD is only applicable to aircraft TCs and not to engine or propeller TCs. Therefore, changes to
OSD are only relevant for changes to aircraft TCs.
23. GM 21.A.91 is amended as follows:
GM 21.A.91 Classification of changes to a type certificate (TC)
[…]
3 ASSESSMENT OF A CHANGE FOR CLASSIFICATION
3.1 Changes to the TC
21.A.91 addresses changes to all aspects of a TC. This includes changes to type design, as defined
in 21.A.31, as well as to the other constituents of a TC, as defined in 21.A.41. This GM provides
guidance on changes to the type design and changes to the operational suitability data (OSD). A
change to a TC can include a change to the type design and/or a change to the OSD.
3.2 Separate classification for type design and OSD
Although in the end, the change to the TC, which includes a change to a type design and a
change to OSD, will have only one classification, it will be possible to classify the
differentchanges to OSD componentsconstituents of the change independently. This willmay
facilitate the approval of a major change. with no verification by EASA of the OSD component if
the change to OSD is considered minor, or with no verification by EASA of the design change if
the design change is considered minor (Seesee also GM No 1 to 21.A.10321.B.107 and 21.B.110).
3.3 Classification Process (see also flow chart ‘Classification process’ in Appendix A to
GM 21.A.91attached diagram)
[…]
3.4 Complementary guidance for classification of changes
A change to the TC is judged to have an ‘appreciable effect on the mass, balance, structural
strength, reliability, operational characteristics, noise, fuel venting, exhaust emission,
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operational suitability or other characteristics affecting the airworthiness, environmental
protection or operational suitability of the product’ and therefore, should be classified as major,
in particular but not only, when one or more of the following conditions are met:
[…]
(e) where the change alters the airworthiness limitations or the operating limitations;
(ef) where the change is made mandatory by an airworthiness directive or the change is the
terminating action of an airworthiness directive (ref. 21.A.3B), see Note 1; and;
(fg) where the change introduces or affects functions where the failure effect is classified as
catastrophic or hazardous.
Note 1: The change previously classified as minor and approved prior to the airworthiness
directive issuance decision needs no re-classification. However, the AgencyEASA retains the right
to review the change and re-classify/re-approve if found necessary.
Note 2: The above conditions listed in (a) through (g) above are an explanation of the criteria
noted in 21.A.91.
For an understanding of how to apply the above conditions it is useful to take note of the
examples given in Appendix A to GM 21.A.91.
3.5 Complementary guidance on the classification of changes to OSD
[…]
3.6 Complementary guidance for classification of changes to aircraft flight manuals (AFMs)
The following changes to the AFM are deemed to be minor:
(a) revisions to the AFM associated with changes to type design classified as minor in
accordance with point 21.A.91.
(b) revisions to the AFM not associated with changes to type design (also identified as
stand-alone revisions) which fall into one of the following categories:
(1) changes to limitations or procedures that are made without altering or exceeding
the certification data (e.g. weight, structural data, noise, etc.);
(2) consolidation of two or more previously approved and compatible AFMs into one,
or compilation of different parts taken from previously approved and compatible
AFMs that are directly applicable to the individual aircraft (customization); and
(3) the introduction into a given AFM of compatible and previously approved AFM
amendments, revisions, appendices or supplements; and
(c) administrative revisions to the AFM, defined as follows:
(1) for the AFMs issued by the TC holder:
(i) editorial revisions or corrections to the AFM;
(ii) changes to parts of the AFM that do not require approval by EASA;
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(iii) conversions of previously Federal Aviation Administration (FAA)- or
EASA-approved combinations of units of measurement added to the AFM in a
previously approved manner;
(iv) the addition of aircraft serial numbers to an existing AFM where the aircraft
configuration, as related to the AFM, is identical to the configuration of
aircraft already covered by that AFM;
(v) the removal of references to aircraft serial numbers no longer applicable to
that AFM; and
(vi) the translation of an EASA-approved AFM into the language of the State of
design or State of registration.
(2) for AFM supplements issued by STC holders:
(i) editorial revisions or corrections to the AFM supplement;
(ii) changes to parts of the AFM supplement that are not required to be
approved by EASA;
(iii) conversions of previously FAA- or EASA-approved combinations of units of
measurement added to the AFM supplement in a previously approved
manner;
(iv) the addition of aircraft serial numbers to an existing AFM supplement where
the aircraft configuration, as related to the AFM supplement, is identical to
aircraft already in that AFM supplement; ‘identical’ means here that all
aircraft have to belong to the same type and model/variant;
(v) the addition of a new STC to an existing AFM supplement, when this
supplement is fully applicable to the new STC;
(vi) the removal of reference to aircraft serial numbers no longer applicable to
that AFM supplement; and
(vii) the translation of an EASA-approved AFM supplement into the language of
the State of design or the State of registration.
3.7 Complementary guidance for classification of changes to environmental protection
characteristics
See Section 8 of Appendix A to GM 21.A.91.
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24. Appendix A to GM 21.A.91 is amended as follows:
Appendix A to GM 21.A.91: Examples of Mmajor Cchanges per discipline
[…]
Classification process
Yes
No
(i)
Yes
No
reclassification
Yes
Minor Major
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Change to a type certificate (TC)
Goal: classification of changes to a TC as per point 21.A.91
Is there any appreciable effect on: Wherever there is doubt
— mass, as to the classification of
— balance, a change, EASA should
— structural strength,
be consulted for
— reliability,
clarification
— operational characteristics,
— noise, Yes
— fuel venting,
— exhaust emission,
— operational suitability, and
— other characteristics affecting the airworthiness
of the product?
No
No Is there any appreciable effect on any of the following? Yes
For design changes (please refer to Section 3.4):
— adjustment of the type certification basis; For changes to OSD
— a new interpretation of the requirements used for constituents, please refer
the type certification basis; to Section 3.4, as
— aspects of compliance demonstration that were applicable, and Section
not previously accepted; 3.5
— there is a considerable extent of new
substantiation data as well as a considerable
degree of reassessment and re-evaluation;
— the airworthiness limitations or the operating
limitations are altered;
— the change is mandated by an airworthiness
directive (AD) or a terminating action of an AD; and
— the change introduces or affects a function where
the failure condition is catastrophic or hazardous.
— See also Appendix A: examples:
1. Structure, 2. Cabin Safety, 3. Flight, 4. Systems, See also examples in
5. Propellers, 6. Engines, 7. Rotors and drive systems,
Section 3.5
8. Environment, and 9. Power plant installation.
EASA decides on Request for Yes Any good reason to No
classification reclassification reclassify as minor?
Minor Major
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25. New AMC 21.A.93(a) is inserted as follows:
AMC 21.A.93(a) Form and manner
The applicant should file an application using the web-based ‘EASA Applicant Portal’13 or the
application forms for the approval of major changes/major repair designs (FO.CERT.00031)14 or for the
approval of minor changes/minor repair designs (FO.CERT.0003215) which may be downloaded from
the EASA website.
The forms should be completed in accordance with the completion instructions embedded at the
bottom of the application forms, and sent to EASA by fax, email or regular mail following the
information provided on the EASA website16.
26. GM 21.A.93(b) is amended as follows:
GMAMC 21.A.93(b) Major Changes: ApplicationCertification programme for a change to a TC or an
STC
The description of the change should include an explanation of the purpose of the change,
pre-modification and post-modification configuration(s) of the product, schematics/pictures, and any
other detailed features and boundaries of the physical change (this may be supplemented by drawings
or outlines of the design, if this helps to understand the design change), as well as an identification of
changes in areas of the product functionally affected by the change and an identification of changes to
approved manuals. Guidance on areas changed and affected by the change is found in GM 21.A.101,
Section 3.9.1.
The level of detail should be the same regardless of whether the change is approved by EASA or under
a design organisation approval (DOA) privilege, to allow the change to be assessed in the frame of the
DOA surveillance.
Identification of re-investigations referred to in point 21.A.93(b)(2), necessary to demonstrate
compliance, does not mean the demonstrating of compliance itself, but the list of affected items
of the applicable certification basiscertification specifications for which a new demonstration is
necessary, together with the means (calculation, test or analysis) by which it is proposed to
demonstrate compliance.
Before submitting the application for a change, the analysis and classification activities of
points 21.A.91 and 21.A.101 should be performed using the corresponding GM. For repair designs, the
analysis of point 21.A.91 should be performed using GM 21.A.435(a).
For a major change, AMC 21.A.15(b) should be used as applicable to the change.
13
https://ap.easa.europa.eu (changes to the link provided may not be reflected in this document).
14
https://www.easa.europa.eu/document-library/application-forms/focert00031 (changes to the link provided may not be reflected
in this document).
15
https://www.easa.europa.eu/document-library/application-forms/focert00032 (changes to the link provided may not be reflected
in this document).
16
https://www.easa.europa.eu/document-library/application-forms/certificates-and-approvals (changes to the link provided may not
be reflected in this document).
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27. GM No 1 to 21.A.93(c) is amended as follows:
GM No 1 to 21.A.93(cb)(1)(iii) Interaction of changes to the type design and changes to operational
suitability data (OSD)
[…]
(e) When the design change makes an OSD constituent applicable (see GM No 1 to
21.A.15(d) — Clarification of the term ‘as applicable’the applicability of operational
suitability data (OSD) constituents) where it was not applicable before, that OSD constituent
should be added to the application for the approval of the change to the TC. In accordance
with paragraph (e), this does not apply to the OSD constituents SIMD and MCSD.
28. GM No 2 to 21.A.93(c) is amended as follows:
GM No 2 to 21.A.93(cb)(1)(iii) Interaction of changes to the type design and changes to the master
minimum equipment list (MMEL)
In general, it has to be assumed that changes to the type certificate (TC) that affect the type
design can have an effect on the MMEL.
Due to its alleviating nature, the MMEL is developed to improve aircraft use, thereby providing a
more convenient and economical air transportation for the public.
Therefore, not introducing an MMEL relief for new equipment, system or function has no effect on
the safety of the operation. The introduction of an MMEL relief for new equipment can, therefore,
be treated as a stand-alone MMEL change, separately from the design change, and can be
processed at a later date than the entry into service of the aircraft including the design change.
Not modifying an MMEL item whose validity is altered by a type design modification may,
however, have an effect on the safety of the operation. The applicant for a change to the TC that
changes the type design should, therefore, identify if this change needs to be supplemented by a
change to the MMEL. However, the update of MMEL relief for an already addressed equipment,
system or function can be treated at a later date than the entry into service of the aircraft
including the design change, provided that the change to the MMEL is of an alleviating nature.
When the change to the MMEL is not of an alleviating nature, it has to be made availableapproved
according to point 21.A.103(a)(4)21.A.97(b)(2) and (c).
[…]
29. New AMC 21.A.95 is inserted as follows:
AMC to 21.A.95 Requirements for the approval of a minor change
(a) Applicability of point 21.A.95
Point 21.A.95 is complied with by applicants to EASA for the approval of a minor change to a
type certificate (TC), and by design organisation approval (DOA) holders approving minor
changes under their own privileges (without EASA’s involvement).
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Point 21.A.95(d) only applies to applicants to EASA. For DOA holders approving minor changes
under their privileges, the substantiating data and the statement of compliance required by
point 21.A.95(d) should be produced but do not need to be submitted to EASA. They should be,
however, kept on record and submitted to EASA on request during its DOA continued
surveillance process.
(b) The approval process
The approval process comprises the following steps:
Note: Steps 1, 2 and 5 should be followed only by applicants for minor changes approved by
EASA. DOA holders approving minor changes under their privileges should refer to AMC No 1 to
21.A.263(c)(2) or AMC No 2 to 21.A.263(c)(2), as applicable to their approval process.
(1) Application
When the minor change is approved by EASA, an application should be sent, as described
in point 21.A.93(a) and (b) and GM 21.A.93(a).
(2) Certification programme
The certification programme should consist of the information defined in points
21.A.93(b)(1) and 21.A.93 (b)(2). Please refer to AMC 21.A.93(b) for further information.
(3) Certification basis
(4) Demonstration of compliance
(5) Statement of compliance
(c) Certification basis
The certification basis for a minor change consists of a subset of elements of the product
certification basis ‘incorporated by reference in the type certificate’ (see also additional
guidance below on the meaning of specifications that became applicable after those
‘incorporated by reference in the type certificate’) which have been identified in accordance
with point 21.A.93(b)(2) due to a reinvestigation of compliance being necessary as compliance
was affected by the minor change (see also additional guidance below on the meaning of
‘specific configurations’).
The certification basis ‘incorporated by reference in the type certificate’ is the certification basis
for the product as recorded in the type certificate data sheet (TCDS) for the product type/model
in the configuration(s) identified in accordance with point 21.A.93(b)(1)(i).
The certification basis contains the applicable airworthiness and (for aircraft only) operational
suitability data (OSD) certification specifications (CSs), environmental protection requirements
specified by reference to their amendment level, as complemented by special conditions,
equivalent safety findings, deviations, an ‘elect to comply’, etc., as applicable. See also the
additional guidance below on the meaning of ‘Minor changes affecting OSD constituents’.
By derogation from the above, CSs that became applicable after those incorporated by reference
in the TC may be used for the approval of a minor change (see the guidance below on
specifications that became applicable after those ‘incorporated by reference in the type
certificate’).
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If other changes are required for the embodiment of the minor change , the certification basis
corresponding to the product modified by these other changes should also be considered when
determining the certification basis for the minor change.
(d) Demonstration of compliance required by point 21.A.95(b)(1) and (2)
The applicant needs to demonstrate compliance with the certification basis established for the
minor change for all areas either physically changed or functionally affected by the minor
change.
(1) Means of compliance: the applicant should define and record the means (calculation, test
or analysis, etc.) by which compliance is demonstrated. Appendix A to AMC 21.A.15(b)
may be used to describe how compliance is demonstrated.
(2) Compliance documents: the compliance demonstration should be recorded in compliance
documents. For minor changes, one comprehensive compliance document may be
sufficient, provided that it contains evidence of all aspects of the compliance
demonstration. AMC 21.A.20(c) can also be used, where applicable.
See also the additional guidance below on ‘design information’.
(3) Aircraft manuals: where applicable, supplements to approved manuals (e.g. aircraft flight
manual (AFM), aircraft maintenance manual (AMM), etc.) may be issued.
See also additional guidance below on embodiment/installation instructions.
(e) Design information
The change to the type design is defined in terms of drawings, specifications, and any other
information that captures the change to the type design in accordance with point 21.A.31.
(f) Embodiment/installation instructions
The instructions for the embodiment/installation of the change (e.g. service bulletin,
modification bulletin etc.) should be defined. This may include the installation procedure, the
required material, etc.
(g) Minor changes affecting OSD constituents (e.g. master minimum equipment list (MMEL))
Minor changes to the type design may only have an effect on the MMEL (see GM No 1 to
21.A.93 (b)(1)(iii)). In this case, GM No 2 to 21.A.93 (b)(1)(iii) is also applicable. This also means
that a dedicated assessment of the effects of the minor type design change on the other OSD
constituents is not needed.
(h) Meaning of ‘specific configurations’ in point 21.A.95(e)
These ‘specific configurations’ are defined as the combination of the product type/model (on
which the minor change will be installed) with (if applicable) the list of those already approved
changes (minor, major, supplemental type certificate (STC)) that are required for the installation
of the minor change.
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(i) Certification specifications that became applicable after those incorporated by reference in the
type certificate
(1) Minor changes are those changes that do not affect the airworthiness of the aircraft and
thus are by definition non-significant as per point 21.A.101. This means that the
certification basis for the minor change may consist of the items of the certification basis
incorporated by reference in the TCDS of the product type/model, and normally, it should
not be necessary for a minor change to use CSs that became applicable after those
incorporated by reference in the type certificate.
(2) On the other hand, the applicant may elect to use later amendments of the affected CSs
for the compliance demonstration. This does not affect the classification of the change,
however, the applicant should also comply with any other CSs that EASA considers as
directly related.
(3) If other changes are required for the installation of the minor change (as explained in
‘specific configurations’), the certification basis for the minor change should also take into
account the corresponding certification basis.
(j) Meaning of ‘no feature or characteristics’ in point 21.A.95(b)(4)
See GM 21.A.20(d).
30. AMC 21.A.97 is amended as follows:
AMC 21.A.97 Compliance demonstration process for major changesRequirements for the approval
of a major change
1. AMC/GM to 21.A.20 should be used for a major change.
2. For major changes not requiring long and complex compliance demonstration activities, a
certification programme, as described in AMC 21.A.20(b), can be submitted with the application
in a simplified format. The certification programme should contain at least the following
elements:
- Purpose of change
- Description of change
- Applicability
- Applicable certification specifications, special conditions, equivalent safety findings and
environmental protection requirements
- The description on how compliance will be demonstrated, with selected means of
compliance (see Appendix to AMC 21.A.20(b) for the codes to be used) and reference to
compliance documents
- If relevant, the delivery schedule of compliance documents.
1. For major changes approved by EASA, the applicant should use all AMC to 21.A.20 as well as GM
to 21.A.20.
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2. For the application of point 21.A.97(c), see GM to21.A.21(f)(b), 21.A.95(c), 21.A.97(c),
21.A.115(c), 21.B.103(b), 21.B.107(b) and 21.B.110(b).
3. In accordance with point 21.A.97(c), the compliance demonstration process always takes into
account the specific configuration(s) in the type certificate (TC) to which the major change under
approval is applied. These configurations may be defined by type models/variants or by design
changes to the type design. The demonstration of compliance covers these applicable specific
configurations. Consequently, the approval of the major change excludes any other
configurations, in particular those already existing but not considered in the compliance
demonstration process as well as those that may be certified in future.
4. For major changes approved by the design organisation approval (DOA) holder on the basis of
their privilege as per point 21.A.263(c)(8), the process described under AMC No 2 to
21.A.263(c)(5)(8)(9) applies.
31. GM 21.A.101 to be amended.
32. GM No 1 to 21.A.101(g) is amended as follows:
GM No 1 to 21.A.101(g) Establishment of the operational suitability data (OSD) certification basis of
changedfor changes to type certificates (TCs)
This GM provides guidance on the application of point 21.A.101(g) in order to determine the applicable
OSD certification basis in accordance with points 21.A.101(a), (b), (c), (d), (e) and (f) for major changes
to the OSD of type-certified aircraft.
1. Minor changes
Minor changes to the OSD are automatically considered not significant under 21.A.101(b)outside
the scope of point 21.A.101. See GM 21.A.95 for their certification basis.
2. Major changes
a. If the design change that triggered the change to the OSD constituent is classified as non-
significant, the change to the OSD constituent is also non-significant.
b. If the design change that triggered the change to the OSD constituent is classified as
significant, the change to the OSD constituent should comply with the latest amendment
of the applicable CSs, unless the exceptions of point 21.A.101(b)(3) apply or unless the
OSD change can be classified as minor as per point 21.A.91. The guidance of GM 21.A.101,
chapter 3, paragraph 10 Section 3.10, regarding the exceptions ‘impractical’ and ‘not
contributing materially to the level of safety’ can be applied by analogy and as far as
applicable to OSD changes.
c. Stand-alone changes to an OSD constituent are considered to be non-significant.
d. When a new OSD constituent is added or required to be added, it should comply with the
latest amendment of the applicable certification specification (CSs).
e. In accordance with Article 7a(3) of Regulation (EU) No 69/2014, the Operational
Evaluation Board (OEB) reports and Master Minimum Equipment Lists (MMEL) issued in
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accordance with the JAA procedures or by the AgencyEASA before the entry into force of
Regulation (EU) No 748/201269/2014, are deemed to constitute the OSD approved in
accordance with 21.A.21(e)point 21.B.103(a)(2).
The original procedures, guidance material (GM), advisory circular joint (ACJ) and/or
acceptable means of compliance (AMC), as well as advisory material joint (AMJ) material,
that were used to establish the original documents (JAA/AgencyEASA MMEL or OEB
report), are deemed to be the original certification basis for these documents.
g. Point 21.A.101(c) provides an exception from the requirements of point 21.A.101(a) for a
change to the OSD of certain aircraft under a specified maximum weight. If an applicant
applies for a change to the OSD for an aircraft (other than rotorcraft) of 2 722 kg (6 000 lb)
or less maximum weight, or for a non-turbine-powered rotorcraft of 1 361 kg (3 000 lb) or
less maximum weight, the applicant can demonstrate that the changed OSD complies with
the OSD certification basis incorporated by reference in the TC. The applicant can also
elect to comply, or may be required to comply, with a later amendment. See also Chapter
4, Section 24.1 (GM No. 1 to 21.A.101) for specific guidance on this provision.
Note: Rrefer to GM No 1 to 21.A.15(d) for applicability of OSD to aircraft other-than-complex motor-
powered aeroplanesaircraft.
33. GM No 1 to 21.A.103, 21.A.115 and 21.B.70 is amended as follows:
GM No 1 to 21.A.103, 21.A.115 and 21.B.7021.B.107 and 21.B.110 Operational suitability data (OSD)
considerations for Aapproval of changes to type certificates (TCs)
The requirement for the AgencyEASA in 21.B.70points 21.B.107(c) or 21.B.110(c), which should be by
analogy considered also by design organisation approval (DOA) holders approving changes or issuing
supplemental type certificates (STCs) under their privileges (without EASA’s involvement), mainly
addresses stand-alone changes to OSD. For such stand-alone OSD changes, there is a separate
classification process (see GM 21.A.91, Sections 3.2 and 3.5), and the way to administer the changes
depends on the extent of the change, but normally, an update of the TCDS is not required. However,
the requirement can also be applied to combinations of design changes and OSD changes.
Changes to TCs can comprise several interrelated changes to different components of the TC. For
example, a change to the cockpit design may trigger a change to the flight crew data, being part of
OSD, and, therefore, included in the TC.
All interrelatedInterrelated changes should ultimately be approved together under a single approval.
However, before issuing such a comprehensive approval, it is possible that different processes are used
for the different parts of the change.
The complete change can be split up, e.g. in a change to the type design and changes to the OSD
constituents. Each part of the change can be classified as minor or major separately (see GM 21.A.91
and Figure 1).
— In caseIf all parts of the change are classified as minor, the design organisation approval (DOA)
holder can approve the whole change.
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— In caseIf one or more parts of the change is/are classified as major, while the associated part(s)
of the change is/are classified as minor, the approved design organisation can propose to the
AgencyEASA not to verify the classification and the part(s) of the change classified as minor in
accordance with its privilege under 21.A.263(b)2 or 3as part of its proposal for EASA’s level of
involvement (LoI) (see point 21.A.93(b)(3)(iii). The AgencyEASA should then accept the part(s) of
the change classified as minor without further verification. Once it is satisfied that compliance
has been demonstrated for the part(s) of the change classified as major, EASA can then issue the
complete change approval or supplemental type certificate (STC).
— In caseIf all parts of the change are classified as major, the AgencyEASA will issue the approval
for the whole change once it is satisfied that compliance has been demonstrated.
Figure 1
Classification and approval of change to a TC combined with a change to a type design and a change to OSD
*TBD means that the involvement is determined by EASA in accordance with point 21.B.107.
In this example, the DOA holder has the privilege to approve minor changes only.
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If the DOA holder holds a privilege in accordance with points 21.A.263(c)(8) or 21.A.263(c)(9), the
whole change may be approved by the DOA holder, provided that the change is within the scope of the
DOA’s terms of approval.
34. New AMC 21.A.113(a) is inserted as follows:
AMC 21.A.113(a) Form and manner
The applicant should file an application using the web-based ‘EASA Applicant Portal’17 or the
application form for a supplemental type certificate (STC) (FO.CERT.00033)18 which may be
downloaded from the EASA website.
The form should be completed in accordance with the completion instructions embedded at the
bottom of the application form, and sent to EASA by fax, email or regular mail following the
information provided on the EASA website19.
35. AMC 21.A.114 is deleted.
36. New AMC 21.A.115 is inserted as follows:
AMC 21.A.115 Requirements for the issuance of a supplemental type certificate (STC)
(a) For STCs approved by EASA, AMC and GM to point 21.A.20 should be followed by the applicant.
(b) For the application under point 21.A.115(c), see GM 21.A.21(f), 21.A.23(b) and 21.A.115(c).
(c) In accordance with point 21.A.115(d), the compliance demonstration process must always cover
the specific configuration(s) in the type certificate (TC) to which the STC under approval is
applied. These configurations may be defined by type models/variants or by design changes to
the type design. The demonstration of compliance should cover these specific applicable
configurations. Consequently, the approval of the STC excludes any other configurations, in
particular those that already existed, but were not considered in the compliance demonstration
process, and those that may be certified in future.
(d) For STCs approved by the design organisation approval (DOA) holder under their privilege as per
point 21.A.263(c)(9), the process described under AMC No 2to 21.A.263(c)(5)(8)(9) applies.
17
https://ap.easa.europa.eu (changes to the link provided may not be reflected in this document).
18
https://www.easa.europa.eu/document-library/application-forms/focert00033 (changes to the link provided may not be reflected
in this document).
19
https://www.easa.europa.eu/document-library/application-forms/certificates-and-approvals (changes to the link provided may not
be reflected in this document).
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37. GM No.1 to 21.A.239(a) is amended as follows:
GM No. 1 to 21.A.239(a) Design assurance system
[…]
3.1.5 Maintenance and Operating Instructions
(a.) Ensuring the preparation and updating of all maintenance and operating
instructions (including instructions for continued airworthiness and Sservices
Bbulletins) needed to maintain airworthiness (continuing airworthiness) in
accordance with relevant CS. For that purpose, the applicant should:
— establish the list of all documents it is producing to comply with the
Appendix referred to in CS 23.1529, CS 25.1529, CS 27.1529,
CS 29.1529, CS-E 20/25 or CS-P 40 (NPA P-3)
— establish a system to collect in-service experience to be used for the
improvement of the instructions
— define procedures and organisation to produce and issue these
documents, using where applicable and so elected 21.A.263(c)(3)
privilegeunder the obligation of point 21.A.265(h); the procedures
should cover:
preparation, including format and language (available industrial
standards can be referred to and used);
proofreading (checking for clarity, readability, typos, etc.);
checking of technical consistency with the corresponding
approved change(s), repair(s) or approved data, including
effectivity, description, effects on airworthiness and
environmental protection, especially when limitations are
changed;
checking of feasibility in practical applications; and
responsibilities and authorised signatories.
(b.) In accordance with points 21.A.57, 21.A.61, 21.A.107, 21.A.119, 21.A.120A
and 21.A.449, ensuring that these documents are provided to all
affectedknown operators and involved authorities.
3.1.6 Operational Suitability Data (OSD)
(a.) Ensuring the preparation and updating of all operational suitability data(OSD)
in accordance with the relevant CSs. For that purpose, the applicant should:
— establish the list of all the documents it is producing to comply with CS-
MMEL or CS-GEN-MMEL, CS-FCD, CS-CCD, CS-SIMD and CS-MCSD, as
applicable;
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— define their procedures and their organisation to produce and issue
these documents, using where applicable and so elected 21.A.263(c)(3)
privilegeunder the obligation of point 21.A.265(h); the procedure
should cover the aspects described in 3.1.5(a) above.
[…]
38. GM No 2 to 21.A.243(d) to be amended.
39. GM 21.A.247 to be amended.
40. GM 21.A.263(b) is deleted.
41. AMC 21.A.263(b)(1) is deleted.
42. AMC No 1 to 21.A.263(c)(1) is amended as follows:
AMC No 1 to 21.A.263(c)(1) Procedure for the classification of changes to a type certificate (TC) or
to a supplemental type certificate (STC) and of repairs designs as ‘minor’ or ‘major’
1. INTENT
This AMC provides the means to develop a procedure for the classification of changes to a TC or
to that part of the product covered by an STC, and repairs designs.
Each design organisation approval (DOA) applicant should develop its own internal classification
procedure following this AMC, in order to obtain the associated privilege under 21.A.263(c)(1).
2. PROCEDURE FOR THE CLASSIFICATION OF CHANGES TO A TCTYPE CERTIFICATE OR TO THAT PART
OF THE PRODUCT COVERED BY AN STC, AND REPAIRS DESIGNS
2.1 Content
The procedure should address the following points:
— the identification of changes to a TCtype certificate or to that part of the product
covered by an STC, and repairs designs,
— classification,
— justification of the classification,
— authorised signatories, and
— supervision of changes to a TCtype certificate or to that part of the product covered
by an STC, and repairs designs initiated by sub-contractors.
For changes to a TCtype certificate or to that part of the product covered by an STC, the
criteria used for the classification should be in compliance with point 21.A.91 andas
further explained in GM 21.A.91.
For repairs, the criteria used for classification should be in compliance with point 21.A.435
andas further explained in GM 21.A.435.
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2.2 Identification of changes to a TCtype certificate or to that part of the product covered by
an STC, and repairs designs
The procedure should indicate how the following are identified:
— major changes to a TCtype certificate or to that part of the product covered by an
STC or major repairs;
— those minor changes to a TCtype certificate or to that part of the product covered
by an STC or minor repairs where additional work is necessary to demonstrate
compliance with the CS and environmental protection requirements; and
— other minor changes to a TCtype certificate or to that part of the product covered
by an STC or minor repairs requiringthat require no further demonstration of
compliance.
2.3 Classification
The procedure should show how the effects on airworthiness, operational suitability and
environmental protection are analysed, from the very beginning, by reference to the
applicable requirements.
If no specific CS or environmental protection requirements are applicable to the change or
repairs, the above review should be carried out at the level of the part or system where
the change or repair is integrated and where specific CS or environmental protection
requirements are applicable.
2.4 Justification of the classification
All decisions of classification of changes to a TCtype certificate or to that part of the
product covered by an STC, and repairs designs as ‘major’ or ‘minor’ should be recorded
and, for those which are not straightforward, also documented. These records should be
easily accessible to the AgencyEASA for sample checking.
2.5 Authorised signatories
All classifications of changes to a TCtype certificate or to that part of the product covered
by an STC, and repairs designs should be accepted by an appropriate authorised signatory,
belonging to or tasked by the Office of Airworthiness, as explained in GM No 1 to
21.A.239(a)(3.1.4)(r).
The procedure should indicate the authorised signatories for the various products listed in
the terms of approval.
For those changes or repairs that are handled by sub-contractors, as described under
paragraph 2.6, it should be described how the DOA holder manages its classification
responsibility.
2.6 Supervision of changes to a TCtype certificate or to that part of the product covered by an
STC, and repairs designs initiated by sub-contractors
The procedure should indicate, directly or by cross-reference to written procedures, how
changes to a TCtype certificate or to that part of the product covered by an STC, and
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repairs designs may be initiated and classified by sub-contractors and are controlled and
supervised by the DOA holder.
43. AMC No 2 to 21.A.263(c)(1) is amended as follows:
AMC No 2 to 21.A.263(c)(1) Privileges — Organisations designing minor changes to a type certificate
(CTC) or a supplemental type certificate (STC) and minor repairs to products: classification procedure
1. Content
The procedure should address the following points:
— configuration control rules, especially the identification of changes to a TCtype certificate
or to that part of the product covered by an STC, and repairs designs;
— classification in compliance with point 21.A.91 and considering GM 21.A.91 for changes
and GM 21.A.435 for repairs;
— justification of the classification;
— authorised signatories.
2. Identification of changes to a TC type certificate or to that part of the product covered by an STC,
and repairs designs
The procedure should indicate how the following minor changes to a type certificate or minor
repairs are identified:
— those minor design changes to a type certificate or minor repairs where additional
substantiation data is necessary to demonstrate compliance with the CS or environmental
protection requirements
— other minor design changes to a type certificate or minor repairs requiring no further
demonstration of compliance.
3. Classification
The procedure should show how the effects on airworthiness, operational suitability and
environmental protection are analysed, from the very beginning, by reference to the applicable
requirements.
If no specific requirements are applicable to the change or the repair, the above review should
be done at the level of the part or system where the change or repair is integrated and where
specific CS or environmental protection requirements are applicable.
For repair, see also GM 21.A.435.
4. Justification of the classification
All decisions on classification of changes to a TCtype certificate or to that part of the product
covered by an STC, and repairs designs as ‘minor‘ should be recorded and, for those which are
not straightforward, also documented.
These records should be easily accessible to the AgencyEASA for sample checking.
It may be in the format of meeting notes or register.
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5. Authorised signatories
All classifications of changes to a TCtype certificate or to that part of the product covered by an
STC, and repairs designs should be accepted by an appropriate authorised signatory.
The procedure should indicate the authorised signatories for the various products listed in the
terms of approval.
44. AMC No 1 to 21.A.263(c)(2) is amended as follows:
AMC No 1 to 21.A.263(c)(2) Procedure for the approval of minor changes to a type certificate (CTC)
or a supplemental type certificate (STC), andor minor repairs
1. INTENT
This AMC provides the means to develop a procedure for the approval of minor changes to a
type certificateTC or to that part of the product covered by an STC, andor minor repairs.
Each design organisation approval (DOA) applicant should develop its own internal procedures
following this AMC in order to obtain the associated privilege under 21.A.263(c)(2).
2. PROCEDURE FOR THE APPROVAL OF MINOR CHANGES TO A TYPE CERTIFICATETC OR TO THAT
PART OF THE PRODUCT COVERED BY AN STC, ANDOR MINOR REPAIRS
2.1 Content
The procedure should address the following points:
— compliance documentation;
— approval under the DOA privilege;
— authorised signatories;
— supervision of minor changes to a type certificateTC or to that part of the product covered
by an STC or minor repairs handled by sub-contractors.
2.2 Compliance documentation
For those minor changes to a type certificateTC or to that part of the product covered by an STC,
andor minor repairs where additional work to demonstrate compliance with the applicable CS
and environmental protection requirements is necessary, compliance documentation should be
established and independently checked as required by point 21.A.239(b).
The procedure should describe how the compliance documentation is produced and checked.
2.3 Approval under the DOA privilege
2.3.1 For those minor changes to a type certificateTC or to that part of the product covered by an STC,
andor minor repairs where additional work to demonstrate compliance with the applicable CS
and environmental protection requirements is necessary, the procedure should define a
document to formalise the approval under the DOA privilege.
This document should include at least:
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— the identification and brief description of the change or repair and the reasons for the
change or repair;
— the applicable CS or environmental protection requirements and methods of compliance;
— references to the compliance documents;
— effects, if any, on limitations and on the approved documentation;
— evidence of the independent checking function of the demonstration of compliance;
— evidence of the approval under the privilege of point 21.A.263(c)(2) by an authorised
signatory; and
— the date of the approval.
For repairs, see AMC 21.A.433(a).
2.3.2 For the other minor changes to a type certificateTC or to that part of the product covered by an
STC, andor minor repairs, the procedure should define a means to identify the change or repair
and the reasons for the change or repair, and to formalise its approval by the appropriate
engineering authority under an authorised signatory. This function may be delegated by the
Office of Airworthiness but should be controlled by the Office of Airworthiness, either directly or
through appropriate procedures of the DOA holder’s design assurance system.
2.4 Authorised signatories
The persons authorised to sign for the approval under the privilege of point 21.A.263(c)(2)
should be identified (name, signature and scope of authority) in appropriate documents that
may be linked to the handbook.
2.5 Supervision of minor changes to a type certificateTC or to that part of the product covered by an
STC, andor minor repairs handled by sub-contractors
For the minor changes to a type certificateTC or to that part of the product covered by an STC,
andor minor repairs described in 2.3.2, thatwhich are handled by sub-contractors, the procedure
should indicate, directly or by cross-reference to written procedures, how these minor changes
to a type certificateTC or to that part of the product covered by an STC, andor minor repairs are
approved at the sub-contractor level and the arrangements made for control and supervision by
the DOA holder.
45. AMC No 2 to 21.A.263(c)(2) is amended as follows:
AMC No 2 to 21.A.263(c)(2) Privileges — Organisations designing minor changes to a type certificate
(TC) or a supplemental type certificate (STC) and minor repairs to products: procedure for the
approval of minor changes to a TC or minor repairs
1. Content
The procedure should address the following points:
— compliance documentation;
— approval under the DOA privilege;
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— authorised signatories.
2. Compliance documentation
For those minor changes to a type certificateTC or to that part of the product covered by an STC,
and minor repairs where additional work to demonstrate compliance with the applicable CS and
environmental protection requirements is necessary, compliance documentation should be
established and independently checked as required by point 21.A.239(b).
The procedure should describe how the compliance documentation is produced and checked.
3. Approval under the DOA privilege
3.1. For those minor changes to a type certificateTC or to that part of the product covered by an STC,
and minor repairs where additional work to demonstrate compliance with the applicable CS or
environmental protection requirements is necessary, the procedure should define a document
to formalise the approval under the DOA privilege.
This document should include at least:
(a) the identification and brief description of the change or the repair and the reason for
change or repair;
(b) the applicable CS or environmental protection requirements and methods of compliance;
(c) references to the compliance documents;
(d) effects, if any, on limitations and on the approved documentation;
(e) evidence of the independent checking function of the demonstration of compliance;
(f) evidence of the approval under the privilege of point 21.A.263(c)(2) by an authorised
signatory; and
(g) the date of the approval
For repairs, see also AMC 21.A.433(a).
3.2. For the other minor changes to a type certificateTC or to that part of the product covered by a
STC, and minor repairs, the procedure should define a means to identify the change or repair
and the reasons for the change or repair, and to formalise its approval by the appropriate
engineering authority under an authorised signatory. This function should be controlled through
appropriate procedures of the DOA holder’s design assurance system.
4. Authorised signatories
The persons authorised to sign for the approval under the privilege of point 21.A.263(c)(2)
should be identified (name, signature and scope of authority) in appropriate documents that
may be linked to the handbook.
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46. New AMC No 3 to 21.A.263(c)(2) is inserted as follows:
AMC No 3 to 21.A.263(c)(2) Procedure for the approval of minor changes to a type certificate (TC)
which affect the aircraft flight manual (AFM)
1. Intent
This AMC provides additional guidance for developing a procedure for the approval of minor
changes to a TC which affect the aircraft flight manual (AFM).
Each design organisation approval (DOA) applicant/holder should develop its own internal
procedure, based on these guidelines.
For guidance on the classification of changes to a TC which affect the AFM, see GM 21.A.91.
2. Procedure for the approval of minor changes to a TC which affect the AFM
2.1 Content
The procedure should address the following points:
— assessment of any change to a TC for the impact of the change on the AFM;
— preparation of revisions or supplements to the AFM;
— classification of the change to a TC, taking into account the impact on the AFM;
— classification of stand-alone revisions or supplements to the AFM;
— control of the configuration of the AFM;
— approval of the revisions or supplements to the AFM; and
— approval statement.
2.2 Assessment of a change for its impact on the AFM
The procedure should include an assessment of whether or not the AFM is impacted by the
change.
2.3 Preparation
The procedure should indicate how revisions or supplements to the AFM are prepared and how
the coordination among the persons in charge of design changes is performed.
2.3 Classification
The procedure should indicate how changes to a type certificate which affect the AFM are
classified, in accordance with the criteria of GM 21.A.91, Section 3.4.
The procedure should indicate how the decisions of classification are recorded, documented and
signed.
Easy accessibility of these records to EASA for sample checking should be ensured.
All classifications should be accepted by an appropriate authorised signatory. The procedure
should indicate the authorised signatories for the various products listed in the terms of
approval.
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2.4 Configuration control of the AFM
The procedure should explain the traceability of changes in order for any user of the AFM to
understand who has approved what. Especially if a given page has been revised several times, it
should be clear which part(s) of the page has/have been approved by EASA under which
approval, and which part(s) has/have been approved under the privilege of a DOA holder.
2.5 Approval
The procedure should indicate how the approval under the privilege of point 21.A.263(c)(2) is
formalised.
The authorised signatories should be identified (name, signature), together with the scope of the
authorisation, in a document linkable to the DOA handbook.
2.6 Approval statement
The amended AFM, or the supplement to the AFM, approved under the privilege of
point 21.A.263(c)(2) should be issued under the obligation of point 21.A.265(h) (see
point 21.A.265(h) and the related GM) with a respective statement in the log of revisions.
47. GM 21.A.263(c)(3) is deleted.
48. GM 21.A.263(c)(4) is deleted.
49. AMC 21.A.263(c)(6) is amended as follows:
AMC 21.A.263(c)(6) Procedure for the approval of the conditions for issueissuing of a permit to fly
1. INTENT
This AMC provides means to develop a procedure to determine that an aircraft can fly, under the
appropriate restrictions compensating for non-compliance with the certification basis applicable
to the aircraft category.
Each DOA applicant or holder mustshould develop its own internal procedure following this
AMC, in order to obtain the privilege to make this determination and approve associated
conditions without AgencyEASA’s involvement, under 21.A.263(c)(6). When the privilege does
not apply, the DOA holder will prepare all the necessary data required for the determination in
accordance with the same procedure required for the privilege, and will apply for AgencyEASA’s
approval.
The establishment of flight conditions may include conditions related to engines/propellers
without a type certificate or with unapproved changes that are fitted on the aircraft, for which a
permit to fly is requested. These conditions (i.e. installation, operating, maintenance conditions
or limitations) should be defined by the organisation responsible for the design of the
engine/propeller and provided to the organisation responsible for the design of the aircraft.
In this context, the organisation responsible for the design of the engine/propeller acts as a
supplier of the organisation responsible for the design of the aircraft. These conditions should be
established and substantiated under the arrangement between the organisation responsible for
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the design of the aircraft and the organisation responsible for the design of the
engine/propeller. The establishment and substantiation of these conditions is the ultimate
responsibility of the organisation responsible for the design of the aircraft.
[…]
50. New AMC No 1 to 21.A.263(c)(5)(8)(9) is inserted as follows:
AMC No 1 to 21.A.263(c)(5)(8)(9) Scope and criteria
1. Definition of ‘certain major repairs’
‘Certain major repairs’ for which privileges may be granted as per point 21.A.263(c)(5) are:
(a) major repairs to products or auxiliary power units (APUs) for which the design
organisation approval (DOA) holder holds the type certificate (TC) or the supplemental
type certificate (STC) or European technical standard order (ETSO) authorisation; or
(b) major repairs to products or APUs for which the DOA holder does not hold the TC or the
STC or ETSO authorisation and that meet the criteria of 2.2(a), (b) and (c) below.
1.2 Eligibility criteria
An EASA approval may be required in cases of major repairs proposed by DOA holders which are
the TC, STC or APU ETSO authorisation holders if the major repair is:
(a) related to a new interpretation of any item of the certification basis as used for type
certification (such as the certification specifications (CSs), certification review items (CRIs)
for special conditions, equivalent safety findings, deviations or ‘elect to comply’); and
(b) related to the application of a CS that is different from the one used for type certification.
Note: this should be established at the time of granting the privilege to the DOA holder or later
through an EASA-agreed procedure.
2. Definition of ‘certain major changes’ and ‘certain supplemental type-certificates’
‘certain major changes’ and ‘certain supplemental type-certificates’ for which privileges may be
granted as per point 21.A.263(c)(8)(9) are changes similar to those that have been previously
approved by EASA for the same DOA holder.
The similarity of the changes is to be seen in terms of the design, the installation, and the
operational characteristics, whereas their repetitiveness in terms of the applicable requirements
and compliance demonstration.
In this context, a ‘requirement’ means any element of the type certification basis as specified in
point 21.B.80 or operational suitability data (OSD) certification basis as specified in point 21.B.82
or the environmental protection requirement as specified in point 21.B.85.
2.1 Criteria for limitations on eligibility
The following types of changes are not eligible:
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(a) changes that require a revision to a type certificate data sheet (TCDS) (e.g. the
introduction of a derivative model or variant) or a type certificate data sheet for noise
(TCDSN);
(b) changes that require an amendment to the existing certification basis by a special
condition, equivalent safety finding, deviation or ‘elect to comply’;
(c) changes that revise airworthiness limitations or operating limitations, unless otherwise
agreed with EASA;
(d) changes that are intended to be used as alternative means of compliance (AltMoC) to an
airworthiness directive (AD);
(e) changes that are made mandatory by an AD or that are the terminating action of an AD;
(f) changes classified as significant in accordance with point 21.A.101;
(g) changes for which, in the affected area and for the operations for which the design is to be
certified, more conservative certification requirements are applicable which were not
used in the description of the EASA-approved procedure of the DOA holder, e.g. in the
case of a type, model or modification applicability with a later, more stringent certification
basis;
(h) changes that affect the noise and/or emissions characteristics of the changed product
unless otherwise agreed with EASA;
(i) changes that affect a part or system, a single failure of which may have a catastrophic
effect upon the product, and for which critical characteristics have been identified which
should be controlled to ensure the required level of integrity;
(j) changes to engines or propellers, a single failure of which may have a hazardous effect
upon the product, and for which critical characteristics have been identified which should
be controlled to ensure the required level of integrity; and
(k) changes for which a non-compliance has been found in the referenced change during the
continued-airworthiness process.
2.2 Criteria for major repairs, major changes and STCs for which the privileges of
point 21.A.263(c)(5)(8)(9) may be granted
The following criteria need to be met:
(a) Similarity
The installation on the product, the design, the operation, and the equipment qualification
are basically the same as in projects for which EASA has already been involved and issued
an approval for the same DOA holder.
(b) Repetitiveness of the certification process
The whole certification process is repetitive, i.e. identical to, or part of, an already
approved referenced process. For a change or repair that is a part of the referenced
‘certain major repairs’, ‘certain major changes’ or ‘certain supplemental type-certificates’,
the certification process is still identical to the one for the affected change. This is the case
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when each compliance demonstration is performed to the same extent in accordance with
the same requirements, GM, and content of the interpretative material, as well as with
the same means and method of compliance (not only the same means of compliance
(MoC) code).
Note: in this AMC, a ‘requirement’ means any element of the type certification basis as
specified in point 21.B.80 or OSD certification basis as specified in point 21.B.82 or an
environmental protection requirement as specified in point 21.B.85.
(c) Performance and experience in previous projects
EASA should have classified as ‘medium’ or ‘high’ the level of performance of the
organisation during at least the latest project referenced, for demonstrating ‘similarity’
and ‘repetitiveness’.
In addition, EASA should have classified as ‘low’ or ‘very low’ the likelihood of an
unidentified non-compliance for all included compliance demonstration items (CDIs)
identified in at least the latest project referenced, for demonstrating ‘similarity’ and
‘repetitiveness’ (applying the criteria for the determination of EASA’s level of involvement
in product certification, see AMC 21.B.100(a) and 21.A.15(b)(6)).
The process to obtain and to use the privileges of point 21.A.263(c)(5)(8)(9) is described in
AMC No 2 to 21.A.263(c)(5)(8)(9).
51. New AMC No 2 to 21.A.263(c)(5)(8)(9) is inserted as follows:
AMC No 2 to 21.A.263(c)(5)(8)(9) Procedure for the approval of a major repair, a major change to a
type certificate (TC), or a supplemental type certificate (STC) by a design organisation approval (DOA)
holder under their privileges
This AMC describes the process to be followed in order to obtain and use the privilege to approve
‘certain major repairs’, ‘certain major changes’ to a TC and ‘certain supplemental type certificates’ as
defined in 1. and 2. of AMC No 1 to 21.A.263(c)(5)(8)(9).
1. PROCESS FOR OBTAINING A PRIVILEGE
A DOA holder applying for the privileges referred to in point 21.A.263(c)(5), (8) or (9) should:
(a) Submit to EASA an application for a significant change in the design assurance system (see
point 21.A.247).
(b) Establish internal procedures for the application of the privilege covering the following
elements, and add them to the application:
(1) The definition of the ‘list associated with the privilege’ of certain major
repairs/changes/STCs. The ‘list associated with the privilege’ is a list of all ‘certain
major changes’, certain STCs and ‘certain major repairs’ (or families thereof) plus
the associated ‘justification document’ references for which the privileges as per
point 21.A.263(c)(5), (8) and (9) have been granted.
(2) A ‘justification document’ for a ‘certain major repair’, ‘certain major change’ or a
‘certain STC’, as applicable.
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The ‘justification document’ should contain:
(i) The reference(s) to the EASA-approved major change(s), STC(s) and major
repair(s), which is/are used to demonstrate the DOA holder’s experience and
performance.
Note: the number of already EASA-approved major change(s), STC(s) or major
repair(s) used to demonstrate the DOA holder’s experience and performance
is based on an assessment of the scope of the ‘certain major repairs’, ‘certain
major changes’ or ‘certain supplemental type-certificates’ which is requested
to be added to the ‘list associated with the privilege’, as well as on the
performance of the DOA holder during previous projects.
(ii) The certification programme(s) of the major change(s), STC(s), or major
repair(s), accepted by EASA, used to demonstrate the applicant’s experience
and performance.
(iii) The applicable product configuration(s).
The applicant should list the type(s) and model(s) to which the major
change(s)/STC(s)/repair(s) applies/apply or may apply. Exceptionally, this may
be done for a dedicated product, system or equipment if the type or model
has no technical influence on the major change(s)/STC(s)/repair(s), i.e. when
the installation issues are negligible (e.g. the TCAS 7.1 software change for a
certain equipment), such a listing is not mandatory, but it needs to be
justified.
(iv) The list of ‘requirements’ for demonstration of compliance, if not identical to
the ones referenced in the certification programme.
(v) The certification process, if not identical to the one referenced in the
certification programme.
(vi) A detailed description with all technical data relevant to the installation of the
product, the design, the operation and the qualification which ensures the
proper use of the privilege for future major changes, major repairs or STCs.
This description should include the criteria defining the conditions that should
be met in order to apply the privileges.
(vii) Any other limits on the use of the privilege.
(3) The assessment of the acceptability of major repairs, major changes or STCs against
the ‘list associated with the privilege’ and the ‘justification document’ of ‘certain
major repair’, ‘certain major changes’ or ‘certain supplemental type-certificates’ for
using the privilege.
(4) The approval process, including the templates to be used, the authorised
signatories, records management and the provision of a ‘summary list’ of major
changes, major repairs and STCs approved under the privilege of
point 21.A.263(c)(5)(8)(9). This process should clarify that the approval is issued
under the DOA holder’s privilege.
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The persons authorised under the privilege of point 21.A.263(c)(5), (8) and (9)
should be identified by name, signature and scope of authority in appropriate
documents and referenced in the procedure.
A ‘summary list’ of all major changes, STCs and major repairs approved under a
privilege should be provided to EASA on a regular basis, as agreed with EASA.
(5) Extension of the ‘list associated with the privilege’ after the privilege is granted.
After the granting of the privilege, the initial list of ‘certain major repairs’, ‘certain
major changes’ and ‘certain STCs’ under the privilege may be further extended by
an EASA agreement, as shown in Section 2. as well as Figures 2 and 3 below.
(c) Identify in the ‘list associated to the privilege’ the eligible major changes, major repairs or
STCs proposed for inclusion in the scope of the privilege (see also AMC No 1 to
21.A.263(c)(5)(8)(9)).
(d) Provide a ‘justification document’ for each proposed certain major change, certain major
repair or certain STC identified under (c) above.
Note: the ‘list associated with the privilege’ identifying all certain major repairs, certain major
changes and certain STCs and the associated ‘justification document(s)’ are to be referenced in
the DOA holder procedure mentioned under (b) above.
The process for obtaining the privilege, referred to in 21.A.263(c)(5)(8)(9), is summarised in
Figure 1 below:
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Approval of the process for a privilege as per
21.A.263(c)(5), or (8) or (9).
The DOA holder submits an application to EASA in accordance with
21.A.247.
The DOA holder proposes an internal procedure covering the following:
definition of the List associated to the privilege ;
creation of the Justification document ;
assessment of major repairs/changes or STCs against the List associated to
the privilege ;
approval process of major repairs/changes or STCs using the privilege as
per 21.A.263(c)(5), or (8) or (9; and)
extension of the list associated to the privilege .
The DOA holder Identifies major repairs, major changes or STCs eligible for
inclusion in the list associated to the privilege using criteria provided in AMC
No 1 to 21.A.263(c)(5)(8)(9).
The DOA holder provides a Justification document for each proposed major
repair, major change or STC included in the list associated to the privilege .
Does EASA agree with the proposed
NO
procedure(s)?
YES
EASA reviews the justification
document(s) Proposed.
The DOA Holder to
resubmit the justification
document or remove it
from the list. Does EASA agree with the justification
NO document(s)?
YES
List associated to
A new privilege under 21.A.263(c)(5)/(8)/(9) is the privilege
granted and the initial List associated to the
privilege is accepted.
Figure 1
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The privilege referred to in point 21.A.263(c)(5)(8)(9) may be used by a DOA holder for the
approval of major repairs, major changes or STCs, as applicable, under the following conditions:
(a) the privilege has already been granted by EASA;
(b) the major repair/change/STC to be approved falls under the ‘list associated with the
privilege’ agreed by EASA; and
(c) the criteria established in the relevant ‘justification document’ are met and the relevant
assessment is recorded.
If all the above conditions are met, the privilege may be used, and the approval of major repairs,
major changes or STCs, as applicable, can be obtained by the DOA holder without EASA’s
involvement.
Note: if a DOA holder applies for a third-country validation after having approved a modification
under its DOA holder privilege, EASA may review some of the compliance demonstration data in
order to support the validation activity.
2. EXTENSION OF THE ‘PRIVILEGE LIST’ OF ‘CERTAIN MAJOR REPAIRS’, ‘CERTAIN MAJOR CHANGES’
OR ‘CERTAIN STCs’ AFTER THE PRIVILEGE IS GRANTED
When the DOA holder intends to update the ‘list associated with the privilege’, a ‘justification
document’ needs to be provided to EASA, as described in Section 1.(b)(2) above. After EASA
agrees with the updated ‘privilege list’ as part of the DOA holder’s procedure, the DOA holder
may proceed as per Section 4. below.
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New repair design
proposal
Is the 21.A.263(c)(5)
NO YES
privilege already
granted?
Does the DOA
holder wishes to YES
NO NO TC, STC or
obtain the privilege YES
21.A.263(c)(5)? ETSOA holder?
Apply the
flow chart of
Figure 1.
Does the repair fall in the list associated
NO with the privilege + meet all criteria of the YES
relevant ‘justification document’?
Does the DOA Holder wish to
include the repair in the list YES
NO
associated with the Use of the
privilege? 21.A.265(c)(5)
privilege
NO
Is the repair eligible?
Please refer to AMC No 1 to
21.A.263(c)(5)(8)(9)
YES
The DOA holder
to provide a
‘justification
document.’
Major repair Does EASA agree to include the
NO
application to repair in the list associated with the YES
EASA privilege?
Major repair The list associated to the
approved by privilege is updated.
---
EASA
Figure 2
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New change to
be approved.
Is the 21.A.263(c)(8)/(9)
NO privilege already YES
granted?
Does the DOA holder wish to
NO obtain the 21.A.263(c)(8)/(9) YES
privilege? Does the change fall in the list
Apply the associated with the privilege +
YES
flow chart of meet all criteria of the relevant
Figure 1. ‘justificationn. document’?
NO
Use of privilege
Does the DOA holder wish to 21.A.265(c)(8)/(9)
NO include the change in the list YES
associated with the privilege?
Is the change eligible?
NO Please refer to AMC No 1 to YES
21.A.263(c)(5)(8)(9).
The DOA holderto
provide a
‘justification
document’.
Does EASA agree to include the change in
NO YES
Major change the List associated with the privilege?
application to
EASA
The list associated with
the privilege is updated.
---
Major change
approved by EASA.
Figure 3
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3. TC, STC OR APU ETSOA HOLDER APPROVAL OF A MAJOR REPAIR UNDER A MAJOR REPAIR
PRIVILEGE — SPECIFIC CONSIDERATIONS
TC, STC or APU ETSOA DOA holders that intend to approve a major repair design under the
privilege of point 21.A.263(c)(5) should ensure that:
(a) the type certification basis for the product, part or appliance to be repaired are identified
together with all other relevant requirements;
(b) all records and substantiation data including documents demonstrating compliance with
all relevant requirements are provided to EASA for review; and
(c) an assessment is made as to whether or not the repair design is affected by the presence
of any STC.
4. DOA HOLDER’S APPROVAL BASED ON THE PRIVILEGE FOR A MAJOR REPAIR, MAJOR CHANGE OR
STC — SPECIFIC CONSIDERATIONS
For the approval of
— major repairs by DOA holders that are not the TC, STC or APU ETSO authorisation holders;
— major changes; and
— STCs
by a DOA holder under the privilege of point 21.A.263(c)(5)(8)(9), the following should be
considered.
4.1 Eligibility of the proposed major repair, major change or STC
The DOA holder should assess the proposed major repair, major change or STC against the ‘list
associated to the privilege’ and the ‘justification document’ of ‘certain major repairs’, ‘certain
major changes’ or ‘certain supplemental type-certificates’ in order to determine whether the
criteria of AMC No 1 to 21.A.263(c)(5)(8)(9), Section 2.2 are met.
4.2 Forms for approval certificates
The DOA holders should use the following forms for the issuance of an approval under their
privilege:
— EASA form XXX20 for a major repair;
— EASA form XXX21 for a major change; and
— EASA form XXX22 for a STC.
For the numbering of major changes to TCs, STCs, as well as of major repairs approved under the
privilege, please refer to AMC No 3 to 21.A.263(c)(5)(8)(9).
20
A link to this EASA form will be created when EASA publishes the Decision amending Decision N° 2012/020/R (‘AMC and GM to part 21’).
21
A link to this EASA form will be created when EASA publishes the Decision amending Decision N° 2012/020/R (‘AMC and GM to part 21’).
22
A link to this EASA form will be created when EASA publishes the Decision amending Decision N° 2012/020/R (‘AMC and GM to part 21’).
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4.3 Approval under the DOA holder’s privilege
When the DOA holder makes use of the privilege of point 21.A.263(c)(5),(8) or (9), they should
include the following in the certification data package:
— a record of the assessment as described in 4.1 above;
— the reference to the ‘justification document’;
— the applicable product configuration;
— the applicable CS or environmental protection requirements and methods of compliance;
— the compliance documents;
— the effects, if any, on limitations and on the approved documentation;
— the evidence of the independent checking of the compliance demonstration;
— the approval document containing the statement of the approval under the privilege of
point 21.A.263(c)(5)(8)(9) by an authorised signatory; and
— the date of approval.
In any case, before the major change, STC or major repair is approved under the DOA privilege,
the DOA holder should ensure that the Part-21 requirements, in particular points 21.A.97,
21.A.115, and 21.A.433, are met.
4.4 Authorised signatories
An authorised person that is identified and authorised as described in Section 1.(b)(4) above
should sign the approval under the privilege of point 21.A.263(c)(5), (8) and (9).
4.5 Summary list
The DOA holder should add to the ‘summary list’ as described in Section 1. (b)(4) above the
major change, STC or major repair approved under the privilege of point 21.A.263(c)(5), (8) and
(9).
52. New AMC No 3 to 21.A.263(c)(5)(8)(9) is inserted as follows:
AMC No 3 to 21.A.263(c)(5)(8)(9) Numbering system for supplemental type certificates (STCs),
major changes, and major repairs issued by design organisation approval (DOA) holders, and
information to EASA
STCs, major changes and major repairs issued by a DOA holder under their privilege of
point 21.A.263(c)(9) should each be given a unique and consecutive reference number using the
following numbering system:
DOA holder Type of Year of Month of Day of Sequential Issue
Dash
reference certificate approval approval approval number reference
STC or MCH
21Jxxx 17 05 10 — 01 A
or MRE
Example: 21J999STC170307—01A
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Note: ‘MCH’ refers to ‘major changes’, ‘MRE’ to ‘major repairs’.
With reference to STCs only, after the STC approval, the DOA holder should send a copy of the STC to
EASA in a timely manner (as agreed with EASA).
53. New GM 21.A.265(h) is inserted as follows:
GM 21.A.265(h) Designation of data and information issued under the authority of a design
organisation approval (DOA) holder
1. INTENT
This GM provides guidance for complying with the obligation of 21.A.265(h) and addresses the
various aspects that the DOA holder should cover in order to have a comprehensive procedure
for the designation of data and information.
2. SCOPE
The term ‘data and information’ as used in point 21.A.265(h) also includes instructions.
Data and information referred to in point 21.A.265(h) are issued by a DOA holder and cover the
following:
— embodiment instructions for design changes or repairs (usually in the form of a service
bulletin, a modification bulletin, repair instructions or engineering order, etc.);
— manuals required by Part-21 or applicable CS (such as aircraft flight manual (AFM),
rotorcraft flight manual, operation suitability data (OSD), instructions for continuing
airworthiness (ICA), etc.);
— mandatory continued-airworthiness measures (usually in the form of service bulletin); and
— additional data to be defined by the DOA holder (e.g. alternative maintenance instructions
that are not, per se, instructions for continuing airworthiness).
The obligation does not apply to — and the statement provided with the data and information
should not be used on — the following documents:
— certification documents (e.g. certification programme, compliance checklist, etc.);
— compliance documents;
— design data transferred to production organisations; and
— production deviations (also referred to as ‘unintended deviations’ or ‘concessions’).
3. RATIONALE
The purpose of this obligation is to give certainty to the end users about the approval status of
the data and information issued by the DOA holder.
4. STATEMENT
The statement provided with the data and information should also cover those items prepared
by subcontractors or vendors that the DOA holder has declared as applicable to their products.
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The technical content of the statement is related to the design data and information. The
approval included in the statement means that:
— the design data have been appropriately approved ; and
— the information contains practical and well-defined installation or inspection methods,
and, when those methods are implemented, the product should be in conformity with the
approved design data.
Note: data and information related to measures required by point 21.A.3B(b) (airworthiness
directives (ADs)) are submitted to EASA to ensure their compatibility with the content of an AD
(see point 21.A.265(e)), and contain a statement that they are, or will be, subject to an AD issued
by EASA.
54. GM 21.A.431(a) is amended as follows:
GM 21.A.431A(a) Scope
[…]
NB: Flow Chart 1 addresses the procedures that should be followed for products where the State of
design is a Member State
Flow Chart 2 addresses procedures that should be followed for products where the State of
design is not a Member State.
[…]
The operator performs a
preliminary assessment of the
damage and preliminary repair
classification
Develop repair
Minor or Major? Minor solution and apply
for approval
DOA
Major holder
(DOAH)
Yes
Minor
Is this within the
Classification by the DOAH EASA
DOAH’s scope?
No
Major
Yes
Is this within the approved
scope of 21.A.263(c)(5)?
No
Approval
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OPERATOR Products where the State of Design is a Member State
Damage
Initial assessment
Other DOA TC/STC Holder EASA
& DOA
Is there an (Member States) (Member States)
existing solution
available and yes
approved ?
APPLY
SOLUTION
no
Agency
New design
TC/STC Holder
Is Applicant no Send data Other DOA Classification
DOA ? to :
yes Classification Classification Approval
process
Classification
B no Minor ? Approval
Minor ? no B process
Approval of design
yes
yes
Approval of design A A Approval of design Approval of design A
Legend: A : go to “ Apply solution “ B : go to EASA or TC/STCH for approval of major repair (only if T C/STC holder has
DOA privilege for major repair)
OPERATOR Products where the State of Design is not a Member State
Damage
Initial assessment
Other DOA EASA
( Member States)
Is there an
existing solution
available and yes
approved ?
APPLY
SOLUTION
no
Agency
New design
Is Applicant no Send data Other DOA Classification
DOA ? to :
yes Classification Approval
process
Classification
B no Minor ?
Minor ? no B Approval of design
yes
yes
Approval of design A A Approval of design A
Legend: A : go to “ Apply solution “ B : go to EASA for approval of major repair
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55. GM 21.A.431(d) is amended as follows
GM 21.A.431A(e)(d) Repairs to European technical standard order (ETSO) articles other than to an
auxiliary power unit (APU)
[…]
56. New AMC 21.A.432C(a) is inserted as follows:
AMC 21.A.432C(a) Form and manner
The applicant should file an application using the web-based ‘EASA Applicant Portal’23 or the
application forms for the approval of major changes/major repair designs (FO.CERT.00031)24 or for the
approval of minor changes/minor repair designs (FO.CERT.00032)25 which may be downloaded from
the EASA website.
The forms should be completed in accordance with the completion instructions embedded at the
bottom of the application forms, and sent to EASA by fax, email or regular mail following the
information provided on the EASA website26.
57. New AMC 21.A.432C(b) is inserted as follows:
AMC 21.A.432C(b) Certification programme for a repair design approval
Clarification of 21.A.432C(b)(1): the description of the repair should consist of:
— the pre- and post-repair configuration;
— a drawing or outline of the repair;
— a list of the detailed features;
— a description of the type and extent of the inspection; and
— an outline of the damage.
Clarification of 21.A.432C(b)(3): the identification of re-investigations does not refer to the
demonstration of compliance itself, but to the list of the affected certification specifications (CS),
together with the means of compliance.
58. AMC 21.A.433(a) and 21.A.447 is amended as follows:
23
https://ap.easa.europa.eu (changes to the link provided may not be reflected in this document).
24
https://www.easa.europa.eu/document-library/application-forms/focert00031 (changes to the link provided may not be reflected
in this document).
25
https://www.easa.europa.eu/document-library/application-forms/focert00032 (changes to the link provided may not be reflected
in this document).
26
https://www.easa.europa.eu/document-library/application-forms/certificates-and-approvals (changes to the link provided may not
be reflected in this document).
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AMC 21.A.433(ab)and 21.A.447 Repair design and record keeping
1. Relevant substantiation data associated with a new major repair design and record keeping
should include:
a. the identification of the damage identification and the reporting source,;
b. the major repair design approval sheet identifying the applicable specifications and
references of justifications,;
c. the repair drawing and/or instructions and scheme identifier,;
d. the correspondence with the holder of the type certificate (TC), supplemental type
certificate (STC), or auxiliary power unit European technical standard order (APU
ETSO) authorisation holder, if its advice on the design has been sought,;
e. the structural justification (static strength, fatigue, damage tolerance, flutter, etc.) or
references to this data,;
f. the effect on the aircraft, engines and/or systems, (performance, flight handling, etc.,
as appropriate),;
g. the effect on the maintenance programme,;
h. the effect on Aairworthiness Llimitations, the Fflight Mmanual and the Ooperating
Mmanual,;
i. any weight and moment changes,; and
j. special test requirements.
2. Relevant minor repair documentation includes paragraphs 1(a) and (c). Other points of
paragraph 1 may be included where necessary. If the repair is outside the approved data, a
justification for the classification is required.
3. Special consideration should be given to repairs that impose subsequent limitations on the
part, product or appliance, (e.g., engine turbine segments that may only be repaired a finite
number of times, the number of repaired turbine blades per set, oversizing of fastener
holes, etc.).
4. Special consideration should also be given to Llife -Llimited parts and Ccritical Pparts,
notably with the involvement of the type certificateTC or STC holder, when deemed
necessary under point 21.A.433(b)(a)(4).
5. Repairs to engine or APU critical parts would normally only be accepted with the
involvement of the TC holder.
59. New GM 21.A.435(b) is inserted as follows:
GM 21.A.435(b) Repair design approval
(a) REPAIR DESIGN APPROVAL BY EASA
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(1) Products first type-certified by EASA or first type-certified by a Member State (covering
those type-certified through Joint Aviation Authorities (JAA) procedures or under national
regulations and those nationally certified without a type certificate (TC))
EASA approval is required in cases of major repair designs proposed by design
organisation approval (DOA) holders that do not hold the necessary privilege as per
point 21.A.263(c)(5) to approve certain major repair designs, as well as in cases of minor
repair designs proposed by persons or organisations that do not hold a DOA.
(2) Products first type-certified by the competent authority (CA) of a third country
EASA approval is always required for major repairs on products first type-certified by the
CA of a third country. Approval privileges granted to DOA holders (see point 21.A.435(b))
are not available to TC holders of products first type-certified by the CA of a third country
unless this third-country has since joined EASA as a Member State. TC holders of products
first type-certified by the CA of a third country may need to be involved in a repair design
when an arrangement with the TC holder has been determined to be necessary under
point 21.A.433(a)(4).
For repairs approved by the CA of a third country, conditions for acceptance may be
defined in the bilateral arrangement between EASA and the third country. In the absence
of such an arrangement, the repair data should follow the approval route of Part-21.
(b) REPAIR DESIGN APPROVAL BY THE DOA HOLDER
(1) Approval by the DOA holder
Approval of repairs through the use of procedures agreed with EASA implies that the DOA
holder issues the approval without EASA’s involvement. EASA will monitor the application
of this procedure within the surveillance plan for the relevant organisation. When the
organisation exercises this privilege, the repair release documentation should clearly show
that the approval is issued on the basis of its privilege.
(2) Previously approved data for other applications
When it is intended to use previously approved data for other applications, it is expected
that an appropriately approved design organisation has checked the applicability and
effectiveness of this data. After damage identification, if a repair solution exists in the
available approved data, and if the application of this solution to the identified damage
remains justified by the previously approved repair design (structural justifications still
valid, possible airworthiness limitations unchanged), the solution may be considered to be
approved and may be used again.
(3) Temporary repairs
These are life-limited repairs to be removed and replaced by permanent repairs after a
limited service period. These repairs should be classified under point 21.A.435 and the
service period should be defined when the repair is approved.
(4) Fatigue and damage tolerance
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When the repaired product is released to service before the fatigue and damage tolerance
evaluation has been completed, the release should be for a limited service period defined
when the repair is issued.
60. GM 21.A.437 is deleted.
61. GM 21.A.437(a) is deleted.
62. AMC 21.A.437(b) is deleted.
63. New AMC 21.A.605(a)(1) is inserted as follows:
AMC 21.A.605(a)(1) Certification programme
(a) For the purpose of the compliance demonstration in accordance with point 21.A.606(b), the
applicant should:
(1) establish a certification programme;
(2) submit the plan to EASA; and
(3) keep the certification programme updated during the approval process.
(b) The certification programme should contain the following information:
(1) a detailed description of the relevant European technical standard order (ETSO) article,
including all of its configurations to be certified, the identification of any non-ETSO
functions, as well as safety means (if applicable);
(2) the operating characteristics and limitations or deviations from ETSO requirements;
(3) the intended use of the article and the kind of operations for which the approval is
requested;
(4) the applicable CS-ETSO requirements and optional aspects (DO-160 version,
demonstration of compliance with certification memoranda);
(5) the proposed means of compliance including the list of documents and deliverables for
EASA;
(6) an assessment of the safety aspects related to (1) to (5) above and of the main failure
conditions, in particular for any novel or unusual features;
(7) the way the applicant will record its justifications of compliance; and
(8) a project schedule, including major milestones.
64. New GM 21.A.605(b) is inserted as follows:
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GM 21.A.605(b) Reporting from the compliance demonstration process and updates to the
certification programme
The applicant should report to EASA any unexpected difficulty or event encountered during the
compliance demonstration which invalidates or appreciably affects the assumptions previously made,
e.g.:
— an increase in the severity of the consequences of a certain condition (e.g. failure mode) of the
article;
— one or more significantly reduced margins on ‘pass-fail’ criteria of the compliance
demonstration;
— an unusual interpretation of the results of the compliance demonstration;
— a deviation from the agreed means as defined in the certification programme;
— a change to the conditions set out in AMC to 21.B.100(b) and 21.A.605(a)(8) for the assessment
of EASA’s level of involvement (LoI); and
— any potential deviations discovered by the applicant.
The applicant should also evaluate whether the unexpected difficulty or event encountered will impact
the certification programme and, if necessary, they should amend the certification programme as per
point 21.A.603.
65. New AMC 21.A.606(d) is inserted as follows:
AMC 21.A.606(d) Declaration
A European technical standard order (ETSO) authorisation is granted in accordance with point 21.B.117
and only if non-interference with non-ETSO functions is ensured. The related declaration should
confirm that compliance with the applicable ETSO is successfully demonstrated and that all
assumptions, constrains, deviations, limitations, and open problem reports relevant for the approval of
the installation are defined both for ETSO and non-ETSO functions.
66. New GM 21.B.75 is inserted as follows:
GM 21.B.75 Special conditions
The term ‘novel or unusual design features’ should be judged in view of the applicable certification
basis for the product. A design feature, in particular, should be judged as a ‘novel or unusual design
feature’ when the certification basis does not sufficiently cover this design.
The term ‘unsafe condition’ is used with the same meaning as described in GM 21.A.3B(b).
The term ‘newly identified hazards’ is intended to address new hazards that have been identified (e.g.
during the certification process of a new product) which, if not addressed by a special condition, should
be addressed by an airworthiness directive (AD) immediately after the issuance of the type certificate
(TC).
67. New GM 21.B.80 is inserted as follows:
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GM 21.B.80 Type-certification basis for a type certificate (TC) or restricted type certificate (RTC)
1. INTRODUCTION
This GM addresses the type certification basis for a TC or RTC.
2. APPLICABLE CERTIFICATION SPECIFICATIONS (CSs) (see point 21.B.80(a))
The type certification basis for a TC or RTC consists of the airworthiness CSs that were effective
on the date of application and applicable for that certificate.
The effectivity date of the initial application may be changed, as per point 21.A.15(f)(2), when
the effectivity period of an application for a type certificate is exceeded, or it is evident that it
will be exceeded, and the applicant requests an extension; see GM 21.A.15(e) and (f).
The certification basis is then revised accordingly.
3. ELECT TO COMPLY (see point 21.B.80(a)(1))
It is also possible for an applicant to elect to comply with a CS that entered into force after the
date of application.
EASA should assess if the proposed certification basis is appropriate to ensure that the ‘elect to
comply’ proposal includes any other CSs that are ‘directly related’ to one or several of the CSs in
it.
Directly related CSs are those that are deemed to contribute to the same safety objective by
building on each other’s requirements, addressing complementary aspects of the same safety
concern, etc. Typically, they are adopted simultaneously with, or prior to, the CSs with which the
applicant has elected to comply.
4. EQUIVALENT LEVEL OF SAFETY (see point 21.B.80(a)(2))
In cases when the applicable CS(s) cannot be literally complied with, either in part or fully, EASA
may accept a suitable alternative, which provides an equivalent level of safety through the use
of appropriate compensating factors.
In cases in which the requirements contain not only objectives but also prescriptive parts, an
equivalent level of safety may be accepted if:
— the objectives are met by designs or features other than those required in the CS; or
— suitable compensating/mitigating factors are proposed.
5. ALTERNATIVE MEANS OF COMPLIANCE (AltMoC) (see point 21.B.80(a)(3))
EASA may accept or prescribe alternative means of compliance when the safety objective is met
by using a different method of compliance demonstration than the one prescribed by the CSs
defined in point 21.B.80(a).
In the case of a TC, the AltMoC should provide a demonstration of compliance with the essential
requirements for airworthiness laid down in Annex I to Regulation (EC) No 216/2008.
In the case of an RTC, the AltMoC should provide a sufficient level of safety with regard to the
intended use.
Note: ‘ AltMoC’ should not be confused with ‘AMC’.
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6. SPECIAL CONDITIONS (see point 21.B.75)
EASA may also prescribe special conditions in accordance with point 21.B.75. Guidance on
special conditions is provided in GM 21.B.75.
68. GM 21.B.82(a) to be developed.
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69. New AMC 21.B.100(a) and 21.A.15(b)(6) is inserted as follows:
AMC 21.B.100(a) and 21.A.15(b)(6) Level of Involvement (LoI) in a certification project for a type
certificate (TC), a major change to a TC, a supplemental type certificate (STC) or a major repair design
1. Definitions
Risk: the combination of the likelihood and severity that is associated with a non-compliance
with part of the certification basis.
Likelihood: a prediction of how likely an occurrence of non-compliance with part of the
certification basis is, based on a combination of the novelty and complexity of the proposed
design and its related compliance demonstration activities, as well as on the performance of the
design organisation.
Severity: a measure of the potential impact of the non-compliance with part of the certification
basis on product safety or on the environment.
Compliance demonstration item (CDI): a meaningful group of compliance demonstration
activities and data identified in the certification programme, which can be considered in isolation
for the purpose of performing a risk assessment.
EASA Panel: an EASA Panel is composed of one or more experts, responsible for a particular
technical area. Each technical area addressed during aircraft certification is covered by an EASA
Panel.
EASA discipline: a discipline is a technical sub-area of an EASA panel.
EASA’s level of involvement (LoI): the compliance demonstration activities and data that EASA
retains for verification during the certification process, as well as the depth of the verification.
2. Background
The applicant has to submit a certification programme for their compliance demonstrations in
accordance with point 21.A.15(b). The applicant has to break down the certification programme
into CDIs and provide their proposal for EASA’s LoI.
The applicant may also indicate the EASA panel(s) affected by each CDI.
This AMC explains:
(a) how to propose EASA's LoI for each CDI as per points 21.A.15(b)(5) and (6),
21.A.93(b)(3)(ii) and (iii), as well as 21.A.113(b); and
(b) how EASA will determine its LoI on the basis of the criteria established in point 21.B.100.
EASA will review the proposal and determine its LoI. Both parties, in mutual trust, should ensure
that the certification project is not delayed through the LoI proposal and determination.
Additionally, in accordance with point 21.A.20, the applicant has the obligation to update the
certification programme, as necessary, during the certification process, and report to EASA any
difficulty or event encountered during the compliance demonstration process which may require
a change to the LoI previously notified to the applicant.
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In such a case or when EASA has other information affecting the assumptions on which the LoI
was based, EASA will revisit its LoI determination.
In accordance with points 21.A.33, 21.A.447, and 21.A.615, irrespective of the LoI, EASA has the
right to review any data and information related to compliance demonstration.
Note: this AMC should not be considered as interpretative material for the classification of
changes or repairs.
3. Principles and generic criteria for the LoI determination
EASA determines its LoI based on the applicant’s proposal in view of the risk (the combination of
the likelihood of an unidentified non-compliance with the severity of the consequences of it).
This is performed after proper familiarisation with the certification project in three steps:
— Step 1: identification of the likelihood of an unidentified non-compliance,
— Step 2: identification of the risk class, and
— Step 3: determination of EASA’s LoI.
This AMC contains criteria, common to all EASA panels, for the determination of:
— novel or unusual features of the certification project, including operational, organisational
and knowledge management aspects;
— complexity of the design and/or compliance demonstration;
— performance and experience of the design organisation of the applicant in the domain
concerned;
— criticality of the design or technology and the related safety and environmental risks,
including those identified on similar designs; and
— data and activities to be retained by EASA.
Additional panel-specific criteria are available in further interpretative material published by
EASA.27
For simple products, panel-specific criteria should only be considered for CDIs affecting noise,
propulsion, development assurance and safety assessment (DASA), operational suitability data
(OSD), and software and airborne electronic hardware. For the purpose of this AMC, simple
products are those other than products related to CS-23 commuter, CS-25, CS-27, and CS-29
aircraft.
The criteria used to determine the likelihood and the severity of an unidentified non-compliance
generally allow a proportionate approach to be applied, in particular in order to differentiate
between CS-25 and General Aviation (GA) aircraft projects.
3.1. LoI determination at CDI level
The determination of EASA’s LoI is performed at the level of the CDI (please refer to
AMC 21.A.15(b)(5) and 21.B.100(a)).
27
Such draft additional criteria are contained as an attachment to the following proposed Certification Memorandum (CM), available
at: http://www.easa.europa.eu/documents/public-consultations/proposed-cm-21a21b-001.
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The applicant should demonstrate that all affected elements of the type certification basis as
specified in point 21.B.80 and OSD certification basis as specified in point 21.B.82, and of the
environmental protection requirements as specified in 21.B.85, the corresponding means and
methods of compliance as well as the corresponding certification activities and data are fully
covered by the proposed CDIs. If the provided data does not clearly show that this is the case,
the applicant should clearly state to EASA that all the above-mentioned elements are fully
covered.
3.2. Method for determining the likelihood of an unidentified non-compliance
3.2.1. Principle
The likelihood of an unidentified non-compliance is assessed on the basis of the following
criteria:
— novelty,
— complexity, and
— the performance of the design organisation.
3.2.2. Novelty
For the purpose of risk class determination, the following simplification has been made:, a CDI
may be either novel or non-novel.
Whether or not a CDI is novel is based on the extent to which the respective elements of the
certification project as well as the related requirement or means of compliance are new/novel to
either the industry as a whole or the applicant including their subcontractors, or from an EASA
panel perspective.
The determination that a CDI is novel may be driven by the use of new technology, new
operations, new kind of installations, the use of new requirements or the use of new means of
compliance.
When an applicant utilises a type of technology for the first time, or when that applicant is
relatively unfamiliar with the technology, this technology is considered ‘novel’, even if other
applicants may be already familiar with it. This also means that a type of technology may no
longer be novel for one applicant, while it may still be novel for other applicants.
The following list includes some examples:
— new materials or combination of materials;
— new application of materials or combination of materials;
— new manufacturing processes;
— new or unusual aircraft configuration and/or system architecture;
— novel reconfiguration of systems;
— new interface or interaction with other parts or systems;
— unusual location of a part or a system, or unusual construction;
— new or unusual use;
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— new functions;
— new kind of operations;
— the potential for new failure modes;
— introduction of a new threat (e.g. new threats regarding fire, fuel, hydrogen, energy
storage devices, etc.) or a new prevention/detection/mitigation method;
— new maintenance techniques;
— novel operating conditions or limitations;
— new human-machine interface (HMI);
— new flight or cabin crew tasks.
Another consideration is the extent to which requirements, means of compliance or guidance
have changed or need to be adapted due to particular novel features of the design.
The following list includes some examples:
— recently issued or amended CS paragraphs with which the applicant has little or no
experience;
— new or adapted special conditions;
— new or adapted equivalent safety findings;
— new or adapted deviations;
— new or adapted guidance or interpretative material;
— new or adapted means of compliance (i.e. other than those previously applied by the
applicant) or unusual means of compliance (different from the existing guidance material
and/or different from industry standard practices), e.g. the replacing of tests by
simulation, numerical models or analytical methods;
— the use of new or adapted industry standards or in-house methods, as well as EASA’s
familiarity with these standards and methods;
— a change in methodology, tools or assumptions (compared to those previously applied by
the applicant), including changes in software tools/programmes;
— novelty in the interpretation of the results of the compliance demonstration e.g. due to
in-service occurrences (compliance demonstration results are interpreted differently from
the past).
Additional new guidance/interpretative material in the form of new certification memoranda
(CMs) may be considered for the determination of novelty if its incorrect application/use may
lead to an unidentified non-compliance. In the context of novelty, the time between the last
similar project and the current project of the applicant should also be considered.
3.2.3. Complexity
For the purpose of risk class determination, the following simplification has been made: a CDI
may be either complex or non-complex.
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For each CDI, the determination of whether it is complex or not may vary based on factors such
as the design, technology, associated manufacturing process, compliance demonstration
(including test set-ups or analysis), interpretation of the results of the compliance
demonstration, interfaces to other technical disciplines/CDIs, and requirements.
Compliance demonstration may be considered to be ‘complex’ for a complex (or highly
integrated) system, which typically requires more effort from the applicant.
The following list includes some examples:
— Compliance demonstration where challenging assessments are required, e.g.:
for requirements of a subjective nature, i.e. those that require a qualitative
assessment, and do not have an explicit description of the means of compliance
with that requirement, or the means of compliance are not a common and accepted
practice; this is typically the case where the requirement uses terms such as
‘subjective’, ‘qualitative’, ‘assessment’ or ‘suitable’/‘unsuitable’ — in contrast,
engineering judgement for very simple compliance demonstration should not be
classified as ‘complex’;
a test where extensive interpretation of the results may be anticipated;
an analysis that is sensitive to assumptions and potentially resulting in a low margin
of safety;
the classification of structures, depending on the conservatism of the method;
an advanced analysis of dynamic behaviour;
a multidisciplinary compliance demonstration where several panels are involved
and interface areas need to be managed (e.g. sustained engine imbalance,
extended-range twin-engine operation performance standards (ETOPS), 2X.1309
assessment, flight in known icing conditions, full authority digital engine control
(FADEC)-controlled engines, etc.);
the representativeness of the test specimen;
— introduction of a complex work sharing with system or equipment suppliers.
For major changes, the complexity of the change should be taken into account rather than the
complexity of the original system.
Whether or not a CDI is complex should be determined in a conservative manner if this cannot
be determined at an early stage of the certification project. When greater clarity has been
achieved, the complexity may be re-evaluated and the LoI adapted accordingly.
3.2.4. Performance of the design organisation
The assessment of the level of performance of the design organisation takes into account the
applicant’s experience with the applicable certification processes, including their performance
on previous projects and their degree of familiarity with the applicable certification
requirements.
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For approved design organisations, EASA uses relevant data to consider the design organisation’s
expected performance at an organisational, panel or discipline level, depending on data
availability.28
This data stems from design organisation audits, the applicant’s measured level of performance
on previous projects, and their performance during the familiarisation phase. EASA shares this
data with the respective design organisations (in form of the design organisation approval (DOA)
dashboard).
For each CDI proposed by the applicant, the DOA holder’s performance associated with the
affected disciplines or panels is to be considered.
In case one CDI affects more panels or disciplines, a conservative approach is to be followed
selecting the lower performance level. As an alternative, that CDI may be assessed separately for
each affected EASA panel or discipline.
If for a well-established organisation there is no shared performance data available at panel
level, it may be acceptable to propose the overall DOA holder’s performance. In case the
organisation or its scope are fundamentally new, ‘unknown’ performance should be
conservatively proposed.
The determination of the performance of the design organisation may also take into
consideration information that is more specific or more recent as compared to the DOA holder’s
dashboard, e.g. experience gained during technical familiarisation with the current certification
project, the performance of compliance verification engineers and of the affected technical
areas, as well as the performance of the design organisation in overseeing subcontractors and
suppliers.
For applicants, for which EASA has agreed in accordance with point 21.A.14(b) to use procedures
setting out specific design practices, as an alternative means to demonstrate their capability
(excluding European technical standard order (ETSO) applicants, covered by point 21.B.100(b)),
or for applicants who demonstrate their capability by providing EASA with the certification
programme in accordance with point 21.A.14(c), the performance of the organisation is not
known to EASA. Therefore, the assumed level of performance is ‘unknown’.
Exceptionally, EASA may consider a higher level of performance for a specific CDI if so proposed
and properly justified by the applicant.
The following list includes some examples:
— a CDI with which EASA is fully familiar and satisfied (from previous similar projects)
regarding the demonstration of compliance proposed by the applicant;
— if the applicant fully delegates the demonstration of compliance to suppliers holding a
DOA, the performance level of the supplier may be proposed.
3.2.5. Likelihood of an unidentified non-compliance
The likelihood of an unidentified non-compliance is the first step necessary to determine the risk
class.
28
The ultimate objective is to define the organisation’s performance at the discipline level.
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The likelihood of an unidentified non-compliance should not be confused with the likelihood of
occurrence of an unsafe condition as per AMC 21.A.3B(b). In fact, said AMC provides EASA’s
confidence level that the design organisation addresses all details of the certification basis for
the CDI concerned and that a non-compliance will not occur.
The likelihood of an unidentified non-compliance is established in four categories (very low, low,
medium, high), depending on the level of performance of the design organisation as assessed by
EASA, and on whether the CDI is novel or complex, as follows:
Step 1 — Likelihood of an unidentified non-compliance
CDI No novel or complex No novel, but Novel and complex
aspects complex aspects; aspects
Performance Novel, but no
level of the DOAH complex aspects
High Very low Low Medium
Medium Low Medium High
Low or unknown Medium High High
3.3. Severity
The severity is the second step necessary to determine the risk class.
The severity is determined as a result of an assessment of the potential impact of a
non-compliance on part of the certification basis regarding airworthiness or the environmental
protection of the product. For the purpose of risk class determination, the following
simplification has been made: the impact of a non-compliance can be either critical or non-
critical.
Some of the below guidance has been derived from GM 21.A.91, not due to a major/minor
change classification but because the same considerations may be applied to determine the
effect of a non-compliance on airworthiness or environmental protection at CDI level. It is
therefore normal that some of the CDIs of a major change consisting of several CDIs may be
critical and others non-critical.
The severity of a CDI should be classified as critical if, for example:
— a function, component or system is introduced or affected where a failure effect is
classified as hazardous or catastrophic at the aircraft level, for instance for ‘equipment,
systems and installations’, e.g. where applicable, as defined in 2X.1309;
— a CDI has an appreciable effect on the HMI (displays, approved procedures, controls or
alerts);
— airworthiness limitations or operating limitations are established or potentially affected;
— a CDI is affected by an existing airworthiness directive (AD), or affected by (an)
occurrence(s) potentially subject to an AD, or by a safety information bulletin (SIB); or
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— a CDI affect parts classified as critical as per CS 27.602/29.602, CS-E 515, or with a
hazardous or catastrophic failure consequence (e.g. principal structural element as per
CS 25.571).
If the classification of the severity level of a CDI as critical is based on the criterion that the CDI is
affected by an AD, then the severity level of that CDI may be reclassified by EASA as non-critical
due to the involvement of EASA in the continued-airworthiness process.
During the early stages of a project, the severity level in terms of the potential safety
consequence of a failure may not always be known, but should be conservatively estimated and
the LoI subsequently re-evaluated, if appropriate.
3.4. Method for the determination of risk classes
The risk is determined as a combination of the severity of the consequences of an unidentified
non-compliance with part of the certification basis (vertical axis) and of the likelihood of the
unidentified non-compliance (horizontal axis) using the following matrix.
As a consequence, four qualitative risk classes are established at the CDI level.
Step 2 — Risk classes
Likelihood (see
Section 3.2.5)
Severity Very low Low Medium High
(see Section 3.3)
Non-critical Class 1 Class 1 Class 2 Class 3
Critical Class 1 Class 2 Class 3 Class 4
The various inputs and the resulting risk class determination are of a continuous nature rather
than consisting of discrete steps. The risk classes provide an order of magnitude of EASA’s
involvement and are used as a qualitative indicator for the determination of EASA’s involvement
described in Section 3.5 below.
Under specific circumstances, the risk class determined on the basis of the above criteria may be
reduced or increased on the basis of justified and recorded arguments.
For a reused and well-proven item of compliance demonstration for which:
— the CDI is independent of the affected product type or model; and
— the design, operation, qualification, and installation of the product are basically the same;
and
— the certification process is identical to one that was used in a modification already
approved by EASA,
the CDI may be accepted as similar, resulting in a reduced LoI as the likelihood of an unidentified
non-compliance is low.
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Furthermore, when a truly identical CDI is reused for the compliance demonstration in a new
project, the LoI is reduced to the acceptance of the certification plan as the likelihood of an
unidentified non-compliance is very low.
3.5. Determination of EASA’s LoI
EASA’s LoI in compliance demonstration verification should be proposed by the applicant and
determined by EASA in Step 3 on the basis of the qualitative risk class identified per CDI in Step 2
as well as by applying sound engineering judgement.
EASA’s LoI is reflected in a list of activities and data, in which EASA retains the verification of
compliance demonstration (e.g. compliance data review and acceptance, test witnessing, etc.),
as well as the depth of the verification. The depth of the verification for individual compliance
reports, data, test witnessing, etc. may range from spot checks to extensive reviews. EASA
always responds to those retained compliance demonstration activities and data with
corresponding comments or a ‘statement of no objection’.
In addition, some data not retained for verification may be requested for information. In this
case, no ‘statement of no objection’ will be provided.
It is recommended that the LOI is proposed for each of the EASA disciplines involved.
Depending on the risk classes determined in Section 3.4 above, EASA’s LoI in compliance
demonstration verification data and activities may be as follows:
— risk Class 1: after acceptance of the certification programme, there is no further EASA
involvement in verifying the compliance activities performed by the applicant to
demonstrate compliance at CDI level;
— risk Class 2: EASA’s LoI is typically limited to the review of a small portion of the
compliance data; there is either no participation in compliance activities or participation in
a small number of compliance activities (witnessing of tests, audits, etc.);
— risk Class 3: in addition to the LoI defined for Class 2, EASA’s LoI typically comprises the
review of a large amount of compliance data as well as the participation in some
compliance activities (witnessing of tests, audits, etc.); and
— risk Class 4: in addition to the LoI defined for Class 3, EASA’s LoI typically comprises the
review of a high amount of compliance data, the detailed interpretation of test results,
and the participation to a high number of compliance activities (witnessing of tests, audits,
etc.).
By default, the following activities require EASA’s involvement in all cases:
— initial issues of, and changes to, a flight manual (for those parts requiring EASA approval
and not falling under the DOA holder’s privilege);
— classification of failure cases affecting handling qualities and performance, when
performed through test (in flight or a simulator); and
— initial issues of, and non-editorial changes to, airworthiness limitations.
If the risk assessment (Steps 1 and 2 above) is made on the level of a compliance demonstration
activity or on the level of a document, the risk class provides an indication for the depth of the
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involvement, i.e. the verification may take place only for certain compliance data within a
compliance document.
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4. Documentation of the LoI
The LoI proposal in the certification programme should include the applicant’s proposal
regarding the compliance demonstration verification activities and data that would be retained
by EASA, as well as the data on which the LoI proposal has been based. For this purpose, the
applicant should appropriately document the analysis per CDI, considering the above criteria. In
obvious cases, it is considered sufficient for the applicant to simply indicate whether or not a CDI
is novel or complex, and whether or not the impact is critical.
EASA documents the LoI determination by accepting the certification programme or, if it
deviates from the proposal, by recording its analysis considering the deviations from the
proposal, and notifies the applicant accordingly.
5. Sampling during surveillance of the DOA holder
It should be noted that all previously defined risk classes may be complemented by sampling of
the project files during surveillance of the DOA holder, independently from the ongoing
certification project. This is necessary in order to maintain confidence in the DOA system and to
constantly monitor its performance.
70. New AMC 21.B.100(b) is inserted as follows:
AMC 21.B.100(b) Level of involvement (LoI) in projects for minor changes and minor repairs
In contrast to 21.B.100(a), the assessment of the LoI for minor repair designs and minor changes is
performed by EASA at the level of the certification project.
EASA reviews the information provided by the applicant in accordance with point 21.A.93 (b) for novel
or unusual features, the complexity of the design and/or the compliance demonstration, as well as the
criticality of the design or technology.
An application for EASA’s approval of a minor change implies that the applicant either does not hold a
(design organisation approval) DOA or that the change is outside the DOA holder’s terms of approval.
However, EASA takes into account the performance and experience of the applicant with similar design
changes, for which data may be already available at EASA. The applicant may be also requested to
present its experience with similar design changes if insufficient information is available at EASA.
Per definition (see point 21.A.91), a minor change has no appreciable effect on the airworthiness of the
product. Therefore, the potential impact of a non-compliance with part of the certification basis
regarding the airworthiness or environmental protection aspects of the product should in most cases
be non-critical.
This facilitates the assessment of the likelihood of an unidentified non-compliance.
A process similar to the one described in AMC 21.B.100(a) and 21.A.15(b)(6) should be used to justify
and document EASA’s LoI.
Following a first assessment of the criticality of the described design or technology, EASA evaluates the
existence of any novel or unusual features as well as the complexity of the design and/or the
compliance demonstration.
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Depending on the results of this evaluation, and based on the table below, EASA determines its LoI as
follows:
Risk class
Non-novel and
Class A Class A
non-complex
Non-critical
Novel and/or
Class B Class C
complex
Critical All cases Class C Class C
Experience Experience
high or medium low or unknown
— Class A: EASA’s involvement is limited to the review of the information summarising the main
results of the compliance demonstration, without any participation in compliance activities
(witnessing of tests, audits, etc.).
— Class B: in addition to the LoI defined for risk Class A, EASA’s involvement is limited to the review
of those compliance elements related to the identified novel or unusual features, complexity of
the design and/or compliance demonstration. EASA may exceptionally participate in the related
compliance activities (witnessing of tests, audits etc.).
— Class C: EASA’s involvement is limited to the review of all the compliance documents related to
the identified criticality of the design or technology, if applicable, or to the identified novel or
unusual features. EASA may participate in the related compliance activities (witnessing of tests,
audits etc.)
71. New AMC 21.B.100(b) is inserted as follows:
AMC 21.B.100(b) Level of involvement (LoI) in European technical standard order authorisation
(ETSOA) projects
The applicant for an ETSOA is required to demonstrate its capability by obtaining EASA’s agreement for
the use of procedures that set out specific design practices.
The assessment by EASA that these procedures are properly applied is performed solely through the
various ETSOA projects of the applicant. No regular organisation audits are performed by EASA outside
the ETSOA projects.
A properly completed Form 34 and the certification programme including a technical description of the
proposed design of the ETSO article are the basis for the determination of the initial EASA’s LoI.
EASA assesses the compliance of the proposed ETSO article with the ETSO requirements as defined in
the CS-ETSO applicable standards as well as the compliance with Part 21, Subpart O (e.g. design of
declaration performance (DDP), ETSO Marking, rating of performance, etc.). The ETSOA applicant
should deliver a complete data package per point 21.A.605.
EASA’s LoI is further reassessed and adapted throughout the certification project until the ETSOA is
issued, depending on the applicant’s data as well as on the ETSO project changes regarding the
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applicant’s compliance demonstration (e.g. methods, design changes, deviations, limitations, problem
reports, etc.).
1. Principles
EASA’s LoI in ETSO projects is defined based both on the responsibility of EASA to assess the
applicant’s demonstration of compliance and on the risk evaluated, according to the following
criteria:
— the applicant’s level of experience in the ETSO process and scope of work;
— the applicant’s level of performance in the ETSO scope of work;
— the use of novelties in the technology/design or in the means of compliance; and
— the complexity of the ETSO article.
1.1 Applicant’s experience in the ETSOA process and scope of work
This Section addresses the experience of the applicant’s organisation in the ETSOA process, as
well as in the scope of the ETSO article certification basis and of the related requirements. The
presence of any of the following aspects contributes to EASA’s identification of the risk related
to the level of experience of the applicant in the ETSOA process or to the scope of work of the
article:
— the applicant is new and has just applied for the acceptance of its procedures by EASA, or
it is the first project of the applicant after EASA has accepted such procedures;
— the organisation has changed significantly the agreed procedures; and
— the scope of work of the ETSOA project (ETSO standards) is new to the applicant.
1.2 ETSOA applicant’s performance within its scope of work
The ETSOA applicant’s level of performance within this scope of work is evaluated using criteria
that enable EASA to identify a risk in the applicant’s performance:
— the applicant has deficiencies in its procedures used to demonstrate compliance with
certification requirements;
— the assessment of the applicant’s compliance on previous projects in the same ETSO scope
of work has revealed significant issues in complying with the certification requirements, in
the completion of data or in the repetition of errors;
— the scope of work is new to the applicant’s team at the facilities where the project is
developed or the team had significant issues on preceding projects;
— EASA has not conducted an ETSOA project assessment of the applicant in the same ETSO
scope of work for a long period (i.e. 2 or 3 years); and
— the applicant did not regularly report minor changes, or occurrences in a timely manner.
1.3 Novelty in the technology or in the means of compliance
By ‘novelty’ is understood the use of new technology, new sensors, new material, the use of new
requirements or the use of new means of compliance. When an applicant is faced with
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technology for the first time, or when that applicant is relatively unfamiliar with the technology,
this is considered ‘novel’ even if other applicants may be already familiar with that technology.
Also related to novelty is the extent to which requirements, means of compliance or guidance
need to be adapted due to particular novel features of the design.
The following list includes some examples:
— recently issued standards within CS-ETSOs, with which the applicant has limited
experience;
— new deviation requests;
— new guidance;
— new means of compliance (i.e. other than those previously applied by the applicant) or
unusual means of compliance (different from existing guidance material and/or different
from industry standard practices);
— the use of new industry standards or new in-house methods, as well as EASA’s familiarity
with these methods and standards;
— changes in methodology, tools or assumptions (compared to those previously applied by
the applicant), including changes in software tools/programmes.
Technology or means of compliance may be new/novel either from a global industry, applicant
or EASA perspective.
1.4 Complexity
Complexity may result from the design, technology, associated manufacturing process,
compliance demonstration (including test set-ups or analysis), as well as from the variety of
ETSOs with which the applicant intends to comply, and their possible interactions.
The demonstration of compliance may be ‘complex’ for complex (or highly integrated)
equipment, which typically requires more effort from the applicant.
1.5 Criticality of the design and of the technology
The criticality levels of the design and of the technology of the ETSO article is considered, but has
a minor impact on the definition of EASA’s LoI. The main reasons are:
— the assessment of ETSO compliance is as important for an ETSO article hosting a critical
function as it is for equipment hosting a less critical function (e.g. flight data recorder);
and
— the criticality of the design or technology is not always defined for an ETSO article, and it
may depend on the installation of the design or technology (e.g. multifunction display),
which may only occur later.
2. Determination of EASA’s LoI
EASA’s LoI in the assessment of the applicant’s compliance demonstration is determined by
EASA on the basis of the qualitative risk class and the EASA responsibilities in assessing the ETSO
project certification data package, together with the procedures for compliance with the ETSO
requirements (Part-21, Subpart O, and CS-ETSO).
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EASA’s LoI is reflected in a list of activities, during which EASA verifies the demonstration of
compliance (e.g. document review and acceptance, test witnessing, sampling on the applicant’s
site, desktop assessments, etc.).
The ETSO applicant is responsible for providing a complete ETSO certification data package.
2.1 Definition of the LoI classes
EASA’s LoI for an ETSO certification project is classified as one of the following:
— class high
— class high reduced
— class medium, and
— class basic.
Class ‘high reduced’ is by default the initial EASA’s LoI in an ETSO project.
The following is a description of each class:
— High
EASA evaluates and samples/checks in an extensive manner all compliance data to assess
the applicant’s demonstration of compliance with the ETSO applicable standards. EASA
assesses the applicant’s DDP and general compliance with Part 21, Subpart O. EASA
performs desk reviews as well as on-site assessments of compliance demonstration. This
occurs when design and verification evidence are available.
— High reduced
EASA assesses all compliance data; sampling/check is significant and adapted to the
likelihood of an unidentified non-compliance. The sampling rate may be reduced if the
content of the life cycle data provides confidence in compliance and is focused in the area
where confidence needs to be gained. EASA assesses the DDP and general compliance
with Part 21, Subpart O. EASA performs desktop reviews and performs an on-site
assessment of the applicant’s compliance demonstration. This occurs when design and
verification evidence are available.
— Medium
EASA assesses all compliance data, but for some compliance data, it performs no or
limited sampling/checking. EASA adapts its sampling and focuses it on the likelihood of an
unidentified non-compliance, taking into account the level of complexity and novelty of
the project. EASA assesses the DDP and general compliance with Part 21, Subpart O.
EASA performs desk reviews and may perform an on-site assessment of the applicant’s
compliance demonstration.
— Basic
EASA assesses the DDP and general compliance with Part 21, Subpart O, and verifies the
completeness of the data package.
Generally, EASA performs a desktop assessment.
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3. The process of determining EASA’s LoI
The determination of EASA’s LoI is captured as a process.
This process is performed mainly in 3 steps and is illustrated in the following figure:
Familiarisation
meeting, when
needed
Delivery of the Assessment of the
Start of the ETSO certification project scope
project programme
(incl. certification
programme)
Minor change?
1- Initial LoI determination
Focused review Assess the experience of the applicant in the
& issue of the the ETSO process & scope And/or the applicant’s
certificate performance in the ETSO scope of work
(§1.1, § 1.2)
The applicant
is novel or did
not perform as
LoI high
expected in
previous
projects
LoI high reduced
LoI
LoI high
increased
2- Reassessment of LoI
LoI high reduced
Project deliverables, the LOI confirmed
assessment of The based on project’s data:
applicant’s method, - novelty in the technology/
deviations/ MoC (§1.3),
limitations - complexity (§1.4) Reduced LoI
and interaction with - criticality (§1.5) sampling medium
the applicant - issues in the compliance
demonstration
- new deviations/limitations
Major change with
straightforward LoI basic
re-demonstration
Figure 1 — Process of determination of EASA’s LoI in ETSO certification projects
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3. Proposed amendments and rationale in detail
Step 1 consists of the initial LoI determination which EASA evaluates by assessing:
— 1.1 Applicant’s experience in the ETSOA process and scope of work according to Section
1.1 above, and
— 1.2 ETSOA applicant’s performance within its scope of work according to Section 1.2
above.
The result of this initial LoI determination is either high or high reduced.
Step 2 consists of reassessing EASA’s LoI. Throughout the ETSO project, EASA receives project
deliverables (e.g. plans, reports), means of compliance, requests for deviations, limitations, etc., and
interacts with the applicant.
If EASA’s LoI has been initially set to high reduced, EASA re-evaluates it considering:
— the 1.3 Novelty in the technology or in the means of compliance according to Section 1.3
above, and
— the complexity of the ETSO project according to Section 1.4 above.
The result of this re-assessment may vary from high to medium according to the following table:
Assessment results LoI adaptation
The ETSO article is novel and complex or a
significant issue is detected during the LoI is increased to high.
compliance demonstration.
The ETSO article is novel or complex or a new
LoI is confirmed as high reduced.
deviation is requested.(1)
The ETSO article is non-novel and non-complex,
no issue is detected during the compliance
LoI is decreased to medium.
demonstration or method, and no new deviation
or new limitation is requested.
There is a major change with straightforward
LoI is reduced to basic.
re-demonstration of the ETSO compliance.(2)
(1)
It refers to deviations from ETSO minimum operational performance standards (MOPSs), excluding
deviations for requesting compliance with a new revision of an industry MOPS standard.
(2)
When EASA agrees that a major change only requires a straightforward re-demonstration of the
ETSO compliance using previous methods, without any identified risk, then EASA’s LoI is reduced to
basic. Please note that this may only be defined after a minimum assessment of the applicant’s
compliance demonstration methods.
Note: for a minor change, this process does not apply; in that case, EASA’s LoI consists of an
assessment of the minor change classification, an update of the certificate, and an assessment of the
DDP, when needed.
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4. Impact assessment (IA)
4. Impact assessment (IA)
The IA, developed as part of NPA 2015-03 and further updated in the related Opinion No 07/2016 is
still applicable. Said IA assessed the following two options:
— Option 0 ‘Do nothing’: the baseline scenario where there would be no change to the current
rules; and
— Option 1 ‘Transparent LoI’: it represents a risk-based approach embedded in the draft rules
proposed in said Opinion.
Option 1 was the preferred one as the documented risk-based approach is expected to improve the
effectiveness, efficiency, transparency, and predictability of the certification process, allowing for a
better planning of the process with fewer delays as well as for a better allocation of both EASA’s and
the applicant’s certification staff resources. In addition, this Option already includes some safety
management system (SMS) elements to ensure compliance with ICAO Annex 19.
For additional details, please refer to NPA 2015-03 and Opinion No 07/2016.
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5. Proposed actions to support implementation
5. Proposed actions to support implementation
The LoI subject is frequently included in the Stakeholder Advisory Body (SAB) (former STeB) agenda,
therefore, its members are regularly updated on the progress in this field.
EASA presented the AMC/GM proposal at the certification design organisation workshop on
22 November 2017 and will organise dedicated LoI workshops/conferences in 2018/Q1 and 2018/Q2 in
order to facilitate the implementation of the changes introduced through the amendments both to
Part 21 and to the related AMC/GM.
Additionally, in January 2017, EASA published for public consultation a Certification Memorandum
(CM)29 containing additional information on the interpretation of new requirements contained in
21.A.15 and 21.B.100. The contents of this CM have been partially transposed into this NPA (please
refer to AMC 21.B.100(a) and 21.A.15(b)(6) in Section 3.1 of this NPA). The final version of this CM will
be published as soon as the European Commission issues the Regulation amending Regulation (EU) No
748/2012 (Part 21). The CM is complemented by domain-specific additional guidance on the
classification of novelty, complexity and severity. The additional guidance also provides the list of
activities/documents typically retained per risk class.
EASA has also launched several advanced application projects in order to test the proposed AMC/GM
on the proposal and determination of EASA’s LoI with volunteering companies, and to facilitate the
transition to the risk-based approach. Interested DOA holders who wish to take part in these test
projects may do so by sending an email to ‘IA_Part
[email protected]’.
In order to facilitate the implementation of the new LoI concept within smaller organisations, EASA will
also develop templates that may be used for the preparation of a certification programme.
29
http://www.easa.europa.eu/system/files/dfu/%27proposed%27%20CM-21.A_21.B-
001%20Issue%2001_Criteria%20for%20the%20determination%20of%20the%20Agency%27s%20level%20of%20involvement%20in
%20product%20certification_PUBL.pdf
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6. References
6. References
6.1. Related regulations
Commission Regulation (EU) No 748/2012 of 3 August 2012 laying down implementing rules for the
airworthiness and environmental certification of aircraft and related products, parts and appliances, as
well as for the certification of design and production organisations (OJ L 224, 21.8.2012, p. 1)
6.2. Affected decisions
Decision N° 2012/020/R of the Executive Director of the Agency of 30th October 2012 on acceptable
means of compliance and guidance material for the airworthiness and environmental certification of
aircraft and related products, parts and appliances, as well as for the certification of design and
production organisations (‘AMC and GM to part 21’) repealing Decision No 2003/01/RM of the
Executive Director of the Agency of 17 October 2003
6.3. Other reference documents
ToR and Concept Paper MDM.060 (RMT.0262 & RMT.0611 and RMT.0550 & RMT.0612) Issue 1
‘Embodiment of Level of Involvement (LOI) and Safety Management System (SMS) requirements into
Part-21, 27 August 2013
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7. Appendix
7. Appendix — Correlation table between Part 21 and the proposed amendments
thereto
To facilitate the review of the proposed AMC/GM to Part 21, the following correlation table has been
created.
This table provides cross references between the requirements of Part 21 (Regulation (EU)
No 748/2012, as amended by Regulations (EU) 2016/5, 2015/1039, as well as Nos 69/2014 and 7/2013)
and those included in the proposed amendments to Part 21 (Opinion No 07/2016).
Part 21 reference Opinion No 07/2016 reference
SECTION A SECTION A
SUBPART A SUBPART A
21.A.1 21.A.1
21.A.2 21.A.2
21.A.3A 21.A.3A
21.A.3B 21.A.3B
21.A.4 21.A.4
SUBPART B SUBPART B
21.A.11 21.A.11
21.A.13 21.A.13
21.A.14 21.A.14
21.A.15(a) 21.A.15(a)
21.A.15(b), (c), (d) 21.A.15(b)
N/a 21.A.15(c)
21.A.16A 21.B.70
21.A.16B 21.B.75
21.A.17A 21.B.80
21.A.17B 21.B.82
21.A.18 21.B.85
21.A.19 21.A.19
21.A.20(a), (b) 21.A.20(a)
N/a 21.A.20(b)
21.A.20(c) 21.A.20(c)
21.A.20(d) 21.A.20(d)(1)
21.A.20(e) 21.A.20(e)
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7. Appendix
21.A.21(a) 21.A.21(a)(1)
21.A.21(b) 21.A.21(a)(2)
21.A.21(c)(1) 21.A.21(a)(3)
21.A.21(c)(2) 21.B.80(a)(2)
21.A.21(c)(3) 21.A.20(d)(2)
21.A.21(d) 21.A.21(a)(3)
21.A.21(f) 21.A.21(b)
21.A.23 21.A.21
21.A.31 21.A.31
21.A.33(a) N/a
N/a 21.A.33
21.A.33(b) 21.A.33(b)
21.A.33(c) 21.A.33(d)(1)
N/a 21.A.33(c)
21.A.33(d), (e) 21.A.33 (d), (e)
21.A.35 21.A.35
21.A.41 21.A.41
21.A.44 21.A.44
21.A.47 21.A.47
21.A.51 21.A.51
21.A.55 21.A.55
21.A.57 21.A.57
21.A.61 21.A.61
21.A.62 21.A.62
SUBPART C SUBPART C
SUBPART D SUBPART D
21.A.90A 21.A.90A
21.A.90B 21.A.90B
21.A.91 21.A.91
21.A.92 21.A.92
21.A.93 first paragraph 21.A.93(a)
21.A.93(a) 21.A.93(b)
N/a 21.A.93(b) first paragraph, (b)(1)(i)
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7. Appendix
21.A.93(b) 21.A.93(b)(2)
21.A.93(c) 21.A.93(b)(1)(iii)
N/a 21.A.93(b)(3), (c)
21.A.95(a), (b) 21.A.95(a)
N/a 21.A.95(b) to (e)
21.A.97(a) N/a
21.A.97(b) 21.A.97(d) and 21.B.107(d)
N/a 21.A.97(a) to (c)
21.A.101 21.A.101
21.A.103(a)(1),(2),(3) 21.A.97(b)
21.A.103(a)(4) 21.B.107(b)
21.A.103(b) 21.B.107(a)(1)(i)
21.A.105 21.A.105
21.A.107 21.A.107
21.A.108 21.A.108
21.A.109 21.A.109
SUBPART E SUBPART E
21.A.111 21.A.111
21.A.112A 21.A.112A
21.A.112B 21.A.112B
21.A.113(a) and (b) 21.A.113(a) and (b)
N/a 21.A.113(c)
21.A.114 21.A.115(b)
21.A.115(a) 21.A.115(b)(4)
21.A.115(b) N/a
21.A.115(c) 21.A.115(b)(1)
21.A.115(d) 21.A.115(b)(5)
N/a 21.A.115(a)
N/a 21.A.115(b)(2) and (b)(3)
N/a 21.A.115(c)
N/a 21.A.115(d)
21.A.116 21.A.116
21.A.117 21.A.117
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7. Appendix
21.A.118A 21.A.118A
21.A.118B 21.A.118B
21.A.119 21.A.119
21.A.120A 21.A.120A
21.A.120B 21.A.120B
SUBPART F SUBPART F
21.A.121 21.A.121
21.A.122 21.A.122
21.A.124 21.A.124
21.A.125A 21.A.125A
21.A.125B 21.A.125B
21.A.125C 21.A.125C
21.A.126 21.A.126
21.A.127 21.A.127
21.A.128 21.A.128
21.A.129 21.A.129
21.A.130 21.A.130
SUBPART G SUBPART G
21.A.131 21.A.131
21.A.133 21.A.133
21.A.134 21.A.134
21.A.135 21.A.135
21.A.139 21.A.139
21.A.143 21.A.143
21.A.145 21.A.145
21.A.147 21.A.147
21.A.148 21.A.148
21.A.149 21.A.149
21.A.151 21.A.151
21.A.153 21.A.153
21.A.157 21.A.157
21.A.158 21.A.158
21.A.159 21.A.159
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 105 of 111
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7. Appendix
21.A.163 21.A.163
21.A.165 21.A.165
SUBPART H SUBPART H
21.A.171 21.A.171
21.A.172 21.A.172
21.A.173 21.A.173
21.A.174 21.A.174
21.A.175 21.A.175
21.A.177 21.A.177
21.A.179 21.A.179
21.A.180 21.A.180
21.A.181 21.A.181
21.A.182 21.A.182
SUBPART I SUBPART I
21.A.201 21.A.201
21.A.203 21.A.203
21.A.204 21.A.204
21.A.207 21.A.207
21.A.209 21.A.209
21.A.210 21.A.210
21.A.211 21.A.211
SUBPART J SUBPART J
21.A.231 21.A.231
21.A.233 21.A.233
21.A.234 21.A.234
21.A.235 21.A.235
21.A.239 21.A.239
21.A.243 21.A.243
21.A.245 21.A.245
21.A.247 21.A.247
21.A.249 21.A.249
21.A.251 21.A.251
21.A.253 21.A.253
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 106 of 111
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European Aviation Safety Agency NPA 2017-20
7. Appendix
21.A.257 21.A.257
21.A.258 21.A.258
21.A.259 21.A.259
21.A.263(a) and (b) N/a
21.A.263(c)(1) and (c)(2) 21.A.263(c)(1) and (c)(2)
21.A.263(c)(3) 21.A.265(h)
21.A.263(c)(4) 21.A.263(c)(2)
21.A.263(c)(5) to (c)(7) 21.A.263(c)(5) to (c)(7)
N/a 21.A.263(c)(8) and (c)(9)
21.A.265 21.A.265
SUBPART K SUBPART K
21.A.301 21.A.301
21.A.303 21.A.303
21.A.305 21.A.305
21.A.307 21.A.307
SUBPART L SUBPART L
SUBPART M SUBPART M
21.A.431A(a) to (e) 21.A.431A(a) to (e)
N/a 21.A.431A(f)
21.A.431B 21.A.431B
21.A.432A 21.A.432A
21.A.432B 21.A.432B
N/a 21.A.432C
21.A.433(a)(1) 21.A.433(a)(1)
21.A.433(a)(2) 21.A.433(b)
21.A.433(a)(3) 21.A.433(a)(2)
21.A.433(b) 21.A.433(a)(4)
N/a 21.A.433(a)(3)
21.A.435 21.A.435(a)
21.A.437 21.A.435(b)
21.A.439 21.A.439
21.A.441 21.A.441
21.A.443 21.A.443
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 107 of 111
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European Aviation Safety Agency NPA 2017-20
7. Appendix
21.A.445 21.A.445
21.A.447 21.A.447
21.A.449 21.A.449
21.A.451 21.A.451
SUBPART N SUBPART N
SUBPART O SUBPART O
21.A.601 21.A.601
21.A.602A 21.A.602A
21.A.602B 21.A.602B
21.A.603 21.A.603
21.A.604 21.A.604
21.A.605(a) to (f) 21.A.605(a)(2) to (a)(7)
N/a 21.A.605(a)(1)
N/a 21.A.605(a)(8)
N/a 21.A.605(b)
21.A.606(a) to (c) 21.A.606(a) to (c)
N/a 21.A.606(d)
21.A.607 21.A.607
21.A.608 21.A.608
21.A.609 21.A.609
21.A.610 21.A.610
21.A.611 21.A.611
21.A.613 21.A.613
21.A.615 21.A.615
21.A.619 21.A.619
21.A.621 21.A.621
SUBPART P SUBPART P
21.A.701 21.A.701
21.A.703 21.A.703
21.A.705 21.A.705
21.A.707 21.A.707
21.A.708 21.A.708
21.A.709 21.A.709
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 108 of 111
An agency of the European Union
European Aviation Safety Agency NPA 2017-20
7. Appendix
21.A.710 21.A.710
21.A.711 21.A.711
21.A.713 21.A.713
21.A.715 21.A.715
21.A.719 21.A.719
21.A.721 21.A.721
21.A.723 21.A.723
21.A.725 21.A.725
21.A.727 21.A.727
21.A.729 21.A.729
SUBPART Q SUBPART Q
21.A.801 21.A.801
21.A.803 21.A.803
21.A.804 21.A.804
21.A.805 21.A.805
21.A.807 21.A.807
SECTION B SECTION B
SUBPART A SUBPART A
21.B.5 21.B.5
21.B.20 21.B.20
21.B.25 21.B.25
21.B.30 21.B.30
21.B.35 21.B.35
21.B.40 21.B.40
21.B.45 21.B.45
21.B.55 21.B.55
21.B.60 21.B.60
SUBPART B SUBPART B
N/a 21.B.100
N/a 21.B.103
SUBPART C SUBPART C
SUBPART D SUBPART D
21.B.70 21.B.107(c)
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 109 of 111
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European Aviation Safety Agency NPA 2017-20
7. Appendix
N/a 21.B.107(a)
N/a 21.B.105
SUBPART E SUBPART E
N/a 21.B.109
N/a 21.B.110
SUBPART F SUBPART F
21.B.120 21.B.120
21.B.125 21.B.125
21.B.130 21.B.130
21.B.135 21.B.135
21.B.140 21.B.140
21.B.145 21.B.145
21.B.150 21.B.150
SUBPART G SUBPART G
21.B.220 21.B.220
21.B.225 21.B.225
21.B.230 21.B.230
21.B.235 21.B.235
21.B.240 21.B.240
21.B.245 21.B.245
21.B.260 21.B.260
SUBPART H SUBPART H
21.B.320 21.B.320
21.B.325 21.B.325
21.B.326 21.B.326
21.B.327 21.B.327
21.B.330 21.B.330
21.B.345 21.B.345
SUBPART I SUBPART I
21.B.420 21.B.420
21.B.425 21.B.425
21.B.430 21.B.430
21.B.445 21.B.445
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 110 of 111
An agency of the European Union
European Aviation Safety Agency NPA 2017-20
7. Appendix
SUBPART J SUBPART J
SUBPART K SUBPART K
SUBPART L SUBPART L
SUBPART M SUBPART M
N/a 21.B.113
N/a 21.B.115
SUBPART N SUBPART N
SUBPART O SUBPART O
N/a 21.B.117
SUBPART P SUBPART P
21.B.520 21.B.520
21.B.525 21.B.525
21.B.530 21.B.530
21.B.545 21.B.545
SUBPART Q SUBPART Q
APPENDICES APPENDICES
Appendix I Appendix I
Appendix II Appendix II
Appendix III Appendix III
Appendix IV Appendix IV
Appendix V Appendix V
Appendix VI Appendix VI
Appendix VII Appendix VII
Appendix VIII Appendix VIII
Appendix IX Appendix IX
Appendix X Appendix X
Appendix XI Appendix XI
Appendix XII Appendix XII
TE.RPRO.00034-006 © European Aviation Safety Agency. All rights reserved. ISO 9001 certified.
Proprietary document. Copies are not controlled. Confirm revision status through the EASA intranet/internet. Page 111 of 111
An agency of the European Union