Export airworthiness documentation review for FAA to EASA transitions

When this review is needed

• An export certificate of airworthiness application is being prepared and the supporting statements have to match the underlying records.
• The importing member state has published or communicated special requirements and someone must confirm the package answers each one.
• Status summaries prepared for the export application disagree with the AD, LLP, or modification records behind them.
• The delivery date is fixed and the export paperwork is the last dependency between closing and flight.

The problem

The export certificate is a summary document, and summaries inherit every unresolved discrepancy beneath them. Teams draft the export application from status lists prepared for the transaction, then discover that the importing authority reads the certificate together with the records and expects the two to agree. Special requirements from the importing state arrive late, are phrased generically, and still have to be answered item by item with evidence nobody assigned an owner to.

What gets reviewed

• Export certificate of airworthiness application data checked against the source records
• Importing-state special requirements mapped to the evidence answering each one
• AD, LLP, and modification status summaries reconciled with the underlying files
• Exceptions and deviations declared on the application, with their supporting justification
• Identification data on the application verified against registry documents and logbook entries
• Delivery-condition items in the transaction that depend on export paperwork

What gets validated

• Every statement on the export application traces to a record that says the same thing
• Each importing-state special requirement has a written answer and an evidence reference, none left as understood
• Declared exceptions on the application match what the gap list says is actually open
• AD and LLP summaries cited in the package recompute correctly from the status files delivered with the aircraft
• Serial numbers, registration marks, and engine identities are consistent across application, registry, and records

Evidence normally required

• Draft export certificate of airworthiness application and supporting statements
• Importing-state special requirements or correspondence from the receiving authority
• Current AD, LLP, and modification status files
• Registry documents, logbooks, and identification records
• The transition gap list from any records reviews already performed

Common discrepancies

• Special requirements answered by assertion, with no document behind the answer
• An export application drafted from an outdated status list that the records review has since corrected
• Exceptions negotiated in the transaction but never declared on the export paperwork
• Identity mismatches, such as an engine serial recorded differently in the registry file and the status summary

What is at stake

An export application that overstates what the records support gets returned with questions, and each round trip with two authorities burns days the delivery schedule does not have. Worse, statements made on export paperwork persist: a certified summary later contradicted by the records becomes a credibility problem for the whole package, inviting deeper review of items that would otherwise have passed.

How the work runs

What the buyer receives

• An evidence map tying each export statement and special-requirement answer to its source record
• A gap list of unsupported statements and unanswered requirements, ranked by schedule risk
• A document request set assigning each missing item to the party able to produce it

Who uses the output

• The team preparing and signing the export application
• Asset managers coordinating the delivery timeline against the paperwork critical path
• The receiving operator's CAMO, which imports the same evidence into its own review

How the work fits into the transaction or program

Export documentation is the final assembly point of the transition: the AD, LLP, repair, and modification reviews all feed it. This review therefore runs late in the sequence but before submission, acting as the last reconciliation between what the package claims and what the records prove, so the authorities see one consistent story.

Jurisdiction-specific considerations

Export from the US system runs under 14 CFR 21.321 and associated FAA export procedures, while acceptance on the European side is governed by EU 748/2012 and the importing member state's registration process, with ICAO Annex 8 supplying the shared airworthiness framework. Member states differ in how they phrase and apply special requirements, so the review treats the importing state's actual correspondence as the requirement set rather than a generic checklist.

Regulatory limits

The review verifies documentary consistency. It does not issue or apply for the export certificate, does not represent the owner before either authority, does not decide whether special requirements are satisfied, and makes no airworthiness determination. Those judgments belong to the FAA and the importing authority.

What this review does not cover

• Preparing or submitting the export application itself
• Registration, deregistration, or customs formalities
• Physical export survey or pre-delivery inspection of the aircraft

Specific to this review

• Importing states read export packages for internal consistency first; a mismatch between the application and an attached status list triggers wider scrutiny faster than any single missing document.
• Special requirements are answered permanently: the response filed at import becomes part of the aircraft's story on the new register and resurfaces at the next transition.
• The export certificate does not transfer airworthiness; the receiving state still runs its own review, which is why the same evidence set must work twice.
• Declared exceptions cost little at application time and are expensive to add later; undeclared open items found by the importing authority reset the review clock.

Sources

Frequently asked questions

Relevant glossary terms

Related pages

Where this fits