FAA to EASA transitions
Preparing repair and alteration records for an FAA to EASA transfer
This review examines the repair and alteration file of an FAA-registered aircraft before it moves to an EASA registry. A records specialist works through damage charts, FAA Form 337s, DER-approved repair data, and return-to-service entries and asks one question of each: will the receiving CAMO and its authority accept this as substantiated? The review runs during transition planning, before the records package is delivered. It produces a repair map keyed to substantiation evidence, a gap list, and a document request set aimed at the items EASA reviewers most often challenge.
When this review is needed
- An FAA-registered aircraft is being sold or leased into an EASA member state and the records package is being assembled.
- The receiving CAMO has started asking how structural repairs on the airframe were approved and by whom.
- A pre-delivery records audit flagged repairs documented only by a logbook entry with no supporting data.
- The lessor wants the repair file settled before marketing the aircraft to European operators.
The problem
Repairs approved inside the FAA system carry paperwork the EASA side does not read the same way. A Form 337 with a field approval, a repair substantiated by DER data, or a dent recorded only against the structural repair manual all pass a US review, then draw questions from an importing authority that wants to see how each repair connects to approved data it recognizes. The person assembling the package usually finds out which repairs are contested only after handover, when the timeline is already committed.
What gets reviewed
- Inventory of every recorded repair and alteration on airframe, engines, and installed components
- Approval basis for each repair: SRM, DER-approved data, field approval, or STC-related repair data
- Return-to-service entries and the linkage between each repair and its accomplishment records
- Damage charts and the repair map reconciled against logbook and work-order history
- Major versus minor classification as the EASA side will read it, flagged where the FAA classification will not carry over
- Receiving-authority and CAMO questions already raised, mapped to the evidence that answers them
Scope this review
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What gets validated
- Every repair on the damage chart appears in the repair map with a substantiation reference
- Each FAA Form 337 in the file has its approved-data source identified rather than assumed
- Repairs substantiated by DER data include the FAA Form 8110-3 and its applicability to this serial number
- Return-to-service entries name the repair data actually used, and the referenced revision existed at the time of the work
- No repair relies solely on an entry citing the SRM generically without chapter and figure
Evidence normally required
- Damage charts, dent-and-buckle records, and any existing repair map
- FAA Form 337s with attached approved data or field-approval signatures
- Work orders, task cards, and return-to-service entries for each repair event
- DER 8110-3 forms and repair-design substantiation packages where they exist
- Correspondence with the receiving CAMO or authority, including any import findings so far
Common discrepancies
- A structural repair recorded on a 337 whose approved data was never attached and cannot be located
- Field-approved alterations the EASA reviewer treats as unsubstantiated changes to type design
- Repair map entries that do not match the physical damage chart delivered with the aircraft
- Logbook return-to-service entries citing the SRM with no chapter, figure, or allowable-damage reference
What is at stake
Repairs the receiving side cannot tie to acceptable data become open items on the import review. Each one either delays the certificate of airworthiness on the new register, forces late engineering work to re-substantiate the repair, or leads to a physical re-inspection the schedule never budgeted. A single major structural repair without traceable approval can hold an otherwise complete transition.
How the work runs
Build the repair inventory
Extract every repair and alteration from logbooks, work orders, 337s, and damage charts into one indexed list.
Trace each approval basis
Attach the SRM reference, DER data, field approval, or STC repair data behind each entry and note what is missing.
Read the file as EASA will
Flag items with no EASA-acceptable path and rank them by acceptance risk and time to cure.
Issue the map and requests
Deliver the repair map, gap list, and targeted document requests to the parties who can close each item.
What the buyer receives
- A repair map keyed to substantiation evidence for every recorded repair and alteration
- A gap list ranked by how likely each item is to block EASA acceptance
- A document request set naming the shop, operator, or designee that can supply each missing item
- A short readiness summary the asset manager can hand to the receiving CAMO
Who uses the output
- Technical-records leads assembling the delivery package for the EASA side
- Asset managers negotiating condition items with the receiving operator
- The receiving CAMO preparing its own import review and airworthiness review
How the work fits into the transaction or program
The repair file is one strand of a full FAA to EASA transition. It usually runs alongside the modification-status and AD reviews, and its output feeds the master gap list for the transition. Because repair substantiation questions take the longest to close, this strand is normally started first, well before the export certificate work begins.
Start with a single asset
Confirm the status list matches the underlying evidence.
Jurisdiction-specific considerations
Both systems require repairs to rest on approved or accepted data, but they draw the lines differently. FAA practice leans on 14 CFR Part 43, Form 337, field approvals, and DER-approved data. The EASA side works from Part-21 repair approvals and expects a clear path from each repair to data it can accept under EU 748/2012, with continuing-airworthiness records held to Part-M standards under EU 1321/2014. Field approvals and some DER approvals have no direct EASA counterpart, so the review flags where equivalence will need to be argued rather than assumed.
Regulatory limits
The review assesses documentation, no more. It does not approve repair data, does not classify repairs on behalf of any authority, does not issue or predict the outcome of an airworthiness review, and does not make an airworthiness determination for the aircraft. Acceptance decisions stay with the receiving authority and CAMO.
What this review does not cover
- Physical inspection of repairs on the aircraft
- Engineering re-substantiation or new repair-design work
- Filing or negotiating the import application with the receiving authority
Specific to this review
- FAA field approvals are the single most common sticking point in this file: they exist nowhere in the EASA system, so each one has to be traced to underlying data an EASA reviewer can accept.
- A repair map that disagrees with the physical dent-and-buckle chart invites a full re-survey, which costs more schedule than any paperwork gap.
- Older 337s often circulated without their attached data; the copy retained in the FAA aircraft registry file sometimes fills gaps the operator archive cannot.
- Repairs performed under an SRM revision later superseded remain valid, but the entry must cite the revision in force at the time, and reviewers check the dates.
- The bilateral agreement between the US and EU eases production and export paperwork, yet it does not convert every FAA repair approval into EASA-accepted data automatically.
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
Will EASA accept repairs approved through an FAA field approval?
Sometimes, but never automatically. A field approval is a US mechanism with no EASA equivalent, so the receiving side looks at the data behind it. If the underlying substantiation is traceable and technically sound, acceptance is achievable; if the file holds only the signed block on the 337, expect questions and plan time to recover or recreate the data.
Relevant glossary terms
Related pages
Where this fits
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