Export package preparation
Repair and alteration records review for an export package
This review prepares an aircraft's repair and alteration history so the export package does not stall on a repair the receiving side will not accept. It is run for the exporting party as the package is assembled, before handover. It ties each repair to its damage disposition, confirms the approved data behind it, and checks the return-to-service entries that closed the work, then flags repairs the receiving authority is likely to challenge. You receive a repair map keyed to the export questions, a gap list ranking repairs by acceptance risk, and a document request set for the substantiation still owed.
When this review is needed
- An export package is being assembled and the repair history has to satisfy the receiving side.
- Structural repairs were carried out under data the receiving authority may not recognize.
- A major alteration on the airframe has an approval basis that has to be shown before export.
- A prior export was challenged on a repair and the package is being rebuilt to close the question.
The problem
A repair that was routine to accomplish becomes a document problem at export, because the receiving side judges the approved-data basis rather than the workmanship. Damage dispositions recorded without the substantiation they reference, alterations whose approval files have gone missing, and return-to-service entries signed under a privilege the receiving side does not honor all sit quietly in the file until the package is examined. The exporting party then has to prove the basis for work done years earlier, often after the shop that did it has moved on.
What gets reviewed
- Each structural repair tied to its damage report and disposition
- The approved data behind each repair and major alteration confirmed
- Return-to-service entries closing each repair traced to the signatory
- Alterations reconciled to the configuration the export documentation asserts
- Repairs the receiving side is likely to challenge raised before handover
- A repair map indexed to the export package questions
Scope this review
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What gets validated
- Each structural repair references approved or acceptable data with the substantiation on file
- Damage dispositions carry the analysis or data the repair claims to rest on
- The signatory who returned each repair to service held a privilege the receiving side will honor
- Alterations reconcile to the configuration the export documentation records
- Repairs flagged for the receiving side are supported by retrievable substantiation
Evidence normally required
- The full repair and alteration history for the airframe, presented as a repair map
- Damage reports and dispositions with the approved data each repair cites
- The return-to-service records that closed each repair and alteration
- The receiving side's requirements for repair and alteration evidence
- Configuration and modification status for the serial number
Common discrepancies
- A structural repair with no substantiation behind the data it cites
- A major alteration whose approval file is missing from the record set
- A return-to-service entry signed under a privilege the receiving side will not honor
- A repair recorded against a configuration the export documentation does not reflect
What is at stake
A repair the receiving side rejects can hold the export until the basis is reconstructed or the repair is re-substantiated, and some approval files cannot be rebuilt at all. Where the basis is genuinely lost, the alteration may have to be removed or carried as a disclosed limitation, and the cost of either falls on the exporting party against a shipping date already set.
How the work runs
Map the repairs
Assemble every structural repair and major alteration with its damage disposition.
Confirm the basis
Tie each repair to its approved data and verify the substantiation is on file.
Check the closures
Confirm return-to-service entries were signed under a privilege the receiving side will honor.
Rank and request
Sort repairs by acceptance risk and request the missing substantiation before handover.
What the buyer receives
- A repair map keyed to the export package questions
- A gap list sorting repairs by acceptance exposure and how recoverable the basis is
- A document request set for the missing repair substantiation
Who uses the output
- Continuing-airworthiness teams evidencing the repair basis the export asserts
- Records staff recovering substantiation for older repairs
- Asset managers tracking whether repair evidence gaps threaten the export date
How the work fits into the transaction or program
The review tests the repair history while the export package is open, so contested repairs surface before the receiving side raises them and while the shops that did the work can still be reached. Its gap list drives the substantiation recovery, and the repair map sits in the export package alongside the AD status and release certificates.
Start with a single asset
Confirm the status list matches the underlying evidence.
Jurisdiction-specific considerations
FAA, EASA, and TCCA judge the acceptability of repair data differently, so a repair accepted where it was done is not guaranteed acceptance by the receiving side. The review identifies repairs whose basis will need a bilateral acceptance path or fresh substantiation before the export can close.
Regulatory limits
The review assembles and tests repair evidence so the receiving side can evaluate it. It does not approve a repair, issue or validate approved data, or make any airworthiness determination on the airframe.
What this review does not cover
- Authoring or approving new repair or alteration data for the airframe
- Physical survey of the repaired areas of the structure
- Any airworthiness determination on the airframe
Specific to this review
- At export a repair is judged on its approved-data basis, not its workmanship, so a sound repair with a missing basis is the one that stalls the package.
- Return-to-service privilege does not travel with the export: a signature valid where the work was done may need a recognized basis for the receiving side.
- Structural repair substantiation is the hardest evidence to rebuild once the shop that produced it is gone, so it is recovered while leverage over that shop remains.
Sources
U.S. Government (eCFR). Maintenance recordkeeping content and approval-for-return-to-service requirements, including 43.9, 43.11, and Appendix B.
U.S. Government (eCFR). Records an owner or operator must keep, including total time in service, current status of life-limited parts, and AD compliance.
European Union / EASA. Continuing airworthiness, maintenance records, CAMO responsibilities, and the airworthiness review process in the EASA system.
U.S. Government (eCFR). Export airworthiness approval requirements and special requirements of an importing authority.
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
Frequently asked questions
A repair was accepted when it was carried out. Why does export change that?
Export shifts the question from workmanship to whether the receiving side will recognize the approved-data basis. The review confirms each repair rests on data the receiving side accepts, or identifies where a bilateral path or fresh substantiation is needed before the package ships.
Relevant glossary terms
Related pages
Where this fits
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