21.A.801 Identification of products
Regulation (EU) 2021/1088
(a) The identification of products shall include the following information:
1. the manufacturer’s name;
2. the product designation;
3. the manufacturer’s serial number;
4. the ‘EXEMPT’ mark in case of an engine, when the competent authority has granted an exemption from the environmental protection requirements;
5. any other information the Agency finds appropriate.
(b) Any natural or legal person that manufactures an aircraft or engine under Subpart G or Subpart F shall identify that aircraft or engine by means of a fireproof plate that has the information specified in point (a) marked on it by etching, stamping, engraving, or other approved method of fireproof marking. The identification plate shall be secured in such a manner that it is accessible and legible, and will not likely be defaced or removed during normal service, or lost or destroyed in an accident.
(c) Any natural or legal person that manufactures a propeller, propeller blade, or propeller hub under Subpart G or Subpart F shall identify it by means of a plate, stamping, engraving, etching or other approved method of fireproof identification that is placed on it on a non-critical surface, contains the information specified in point (a), and will not likely be defaced or removed during normal service or lost or destroyed in an accident.
(d) For manned balloons, the identification plate prescribed in point (b) shall be secured to the balloon envelope and shall be located, if practicable, where it is legible to the operator when the balloon is inflated. In addition, the basket, load frame assembly and any heater assembly shall be permanently and legibly marked with the manufacturer's name, part number, or equivalent, and serial number, or equivalent.
21.A.803 Handling of identification data
Regulation (EU) No 748/2012
(a) No person shall remove, change, or place identification information referred to in point 21.A.801(a) on any aircraft, engine, propeller, propeller blade, or propeller hub, or in point 21.A.807(a) on an APU, without the approval of the Agency.
(b) No person shall remove or install any identification plate referred to in point 21.A.801, or in point 21.A.807 for an APU, without the approval of the Agency.
(c) By way of derogation from points (a) and (b), any natural or legal person performing maintenance work under the applicable associated implementing rules may, in accordance with methods, techniques and practices established by the Agency:
1. remove, change, or place the identification information referred to in point 21.A.801(a) on any aircraft, engine, propeller, propeller blade, or propeller hub, or in point 21.A.807(a) on an APU; or
2. remove an identification plate referred to in point 21.A.801, or point 21.A.807 for an APU, when necessary during maintenance operations.
(d) No person shall install an identification plate removed in accordance with point (c)(2) on any aircraft, engine, propeller, propeller blade, or propeller hub other than the one from which it was removed.
21.A.804 Identification of parts and appliances
Regulation (EU) No 2021/699
(a) Each part or appliance which is eligible for installation in a type-certified product shall be marked permanently and legibly with:
1. a name, trademark, or symbol identifying the manufacturer in a manner identified by the applicable design data;
2. the part number, as defined in the applicable design data; and
3. the letters EPA for parts or appliances produced in accordance with approved design data not belonging to the type-certificate holder of the related product, except for ETSO articles and for parts and appliances covered under point (b) of point 21.A.307.
(b) By way of derogation from point (a), if the Agency agrees that a part or appliance is too small or that it is otherwise impractical to mark a part or appliance with any of the information required by point (a), the authorised release document accompanying the part or appliance or its container shall include the information that could not be marked on the part or appliance.
GM 21.A.804(a)(1) Identification of parts and appliances
ED Decision 2012/020/R
It is not the intent of 21.A.804(a)(1) to introduce an obligation for a production organisation (manufacturer) to mark new parts or appliances with information which is not identified by the design approval holder. Therefore, the physical marking of parts and appliances is only required when established by the design approval (TC, STC, ETSO, repair, change) holder.
For designs (TC, STC, ETSO, repair, change) approved after 28 December 2009 (the date of entry into force of Commission Regulation (EC) No 1194/2009), the design approval holder is required to identify to the manufacturer how the marking in accordance with 21.A.804(a)(1) should be done. This can be limited to identifying a marking field, possible depth and/or means etc., without prescribing the actual text or symbols to be used.
GM1 21.A.804(a)(3) Identification of parts and appliances
ED Decision 2021/001/R
EUROPEAN PARTS APPROVAL (EPA) MARKING FOR REPAIR PARTS
The EPA marking only applies to the parts, specifically designed or modified for the repair, to be incorporated as part of the repair design. If the repair scheme does not require the addition of any new parts or the use of modified parts, there is no need to mark the repaired part with the letters ‘EPA’.
AMC1 21.A.804(b) Identification of parts and appliances
ED Decision 2021/001/R
EASA AGREEMENT FOR THE DESIGN APPROVAL HOLDER TO DEROGATE FROM POINT 21.A.804(a)
A design approval holder may apply point 21.A.804(a) or make use of the derogation defined in point 21.A.804(b) by clarifying, in the relevant procedures, the conditions (e.g. the minimum dimensions of a (flat) area on a part suitable for marking) in which the marking on the part may be completely or partially omitted. This can also be supported by examples of parts or cases when certain parts do not have to be marked.
In such cases, the relevant design data (e.g. drawings) should specify the contents and location of the information that could not be marked on the part (i.e. the information to be provided in the authorised release document or on the container).
21.A.805 Identification of critical parts
Regulation (EU) No 748/2012
In addition to the requirement of point 21.A.804, each manufacturer of a part to be fitted on a type-certificated product which has been identified as a critical part shall permanently and legibly mark that part with a part number and a serial number.
GM1 21.A.805 Identification of critical parts
ED Decision 2021/001/R
PARTS TO BE MARKED
For the purposes of point 21.A.805, a part that requires individual traceability for the management of its continued airworthiness, as identified by the design approval holder, shall be permanently marked with a part number and a serial number.
The need for the design approval holder to identify and mark parts may be related to specific requirements for critical parts included in a certification specification. For instance, according to point (c) of CS-E 110 Drawings and Marking of Parts — Assembly of Parts: ‘Certain parts (including Engine Critical Parts; see CS-E 515) as may be required by the Agency must be marked and the constructor must maintain records related to this marking such that it is possible to establish the relevant manufacturing history of the parts.’ Another example is in point AC 29.602 of FAA AC 29-2C, as referenced in Book 2 of CS-29: ‘(7) – Critical parts are identified as required, and relevant records relating to the identification are maintained such that it is possible to establish the manufacturing history of the individual parts or batches of parts.’
Another typical case is for any part subject to an individually specified life limit or inspection requirement when it is also possible for that part to be removed from one serial number of the associated product during maintenance and installed on another serial number of the same product. In this case, the traceability of the part, which is necessary for continued airworthiness management purposes, is not assured through the serial number of the product alone, and it is necessary to maintain records for the part through its serial number.
21.A.807 Identification of ETSO articles
Regulation (EU) No 748/2012
(a) Each holder of an ETSO authorisation under Subpart O shall permanently and legibly mark each article with the following information:
1. the name and address of the manufacturer;
2. the name, type, part number or model designation of the article;
3. the serial number or the date of manufacture of the article or both; and
4. the applicable ETSO number.
(b) By way of derogation from point (a), if the Agency agrees that a part is too small or that it is otherwise impractical to mark a part with any of the information required by point (a), the authorised release document accompanying the part or its container shall include the information that could not be marked on the part.
(c) Each person who manufactures an APU under Subpart G or Subpart F shall identify that APU by means of a fireproof plate that has the information specified in point (a) marked on it by etching, stamping, engraving, or other approved method of fireproof marking. The identification plate shall be secured in such a manner that it is accessible and legible, and will not likely be defaced or removed during normal service, or lost or destroyed in an accident.