Parts without Form 1, 21.A.307 - New regulation

Niklas Larsson
Niklas Larsson • 17 February 2022
in community General Aviation
8 comments
2 likes

On the 18th of May we will see a new version of 21.A.307 which stipulates on what conditions you may install parts without EASA Form 1. Today it contains some helpful alleviations for ELA2 aircraft. However, with the introduction of Regulation (EU) 2021/699 and 21.A.307 (c) this is seriously restricted and depending on how you interpret it some would say that it is more restrictive that just getting a Form 1 in the first place.

Here is the text in (c):

(c) Parts and appliances listed in point (b) are eligible for installation in a type-certified product without being accompanied by an EASA Form 1, provided that the installer holds a document issued by the person or organisation that manufactured the part or appliance, which declares the name of the part or appliance, the part number, and the conformity of the part or appliance with its design data, and which contains the issuance date.

[applicable from 18 May 2022 — Regulation (EU) 2021/699]

I have not found any reason for this change even though I have looked through the working material. I admit that I did not notice and answered the NPA when it was active.

EASA, was the intention of the rule to remove this opportunity or make it more restrictive? Or was it an unintentional error during the rulemaking process?

How should we as stake holders use this new version?

There is no AMC or GM to (c) either.

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Comments (8)

Niklas Larsson
Niklas Larsson • 3 years ago

Hello Jannes,
Glad to hear from you, I hope everything is great with you. I have looked at the video and it did not provide me anything in detail about how this paragraph should be interpreted.
The way I see it is this:
Before May 2022 an ELA2 owner did not need an EASA Form 1 or a document from the manufacturer regarding the part.
From May 2022 an ELA2 owner will need a document for every part that is to be installed. If he or she does not have a Form 1 a document from the manufacturer will be required.

This makes the new regulation more restrictive than the previous one which meant that no document was required(as long as it fulfilled the criterias). It does not seem right.

What kind of document would fulfill the new (c)? Would an installation manual or similar be sufficient? Or an Illustrated Parts Catalogue?

Christophe Mutricy
Christophe Mutricy • 3 years ago

I share the view of Niklas. The new (c) is completely new and impose more justifications. What kind of document EASA expects us to attach to the aircraft file to prove that by example that an M5 nut is an M5 nut. With the old wording of 21.A.307, it was a standard part and that was it. Soon we'll need more redtape.

Niklas Larsson
Niklas Larsson • 2 years ago

Ok, so my CAMO says that from 18 May there is no longer a possibility to use owner accepted parts in a reasonable way. What should I tell them?

Patrick L
Patrick L • 2 years ago

So, are the changes only in regard to 2 additional categories?

FAQ Text:

From 18 May 2022, a new requirement 21.A.307 becomes applicable (refer to Regulation (EU) 2021/699). This means that certain new parts do not require an EASA Form 1 for installation during maintenance. What are the implications of these regulatory changes, especially for General Aviation? Are ‘standard parts’ and ‘owner-accepted-parts (former 21.A.307(c)-parts’) impacted?

Answer

In essence, two new categories of new parts will be permitted to be installed during maintenance of European registered aircraft without the parts being accompanied with an EASA Form 1, but with an alternative document instead:

parts with negligible safety effect as identified by the holder of the design approval (according to 21.A.307(b)3);
parts with negligible safety effect as identified by EASA in CS-STAN for standard changes/repairs (according to 21.A.307(b)4)
This will permit fabrication of the above parts by organisations which are not approved as productions organisations (POA), which was considered too stringent for the manufacturing of parts having negligible safety impact in case of non-conformities.

Note that already for years, and after the new regulatory change will become applicable, ‘standard parts’ (parts i.a.w. 21.A.307(b)1) and ‘owner-accepted-parts’ (parts i.a.w. 21.A.307(b)2) are not required to be accompanied with an EASA Form 1 when they fulfil certain conditions.

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