ETSO authorization
Conformity records support for ETSO authorization
This review readies the conformity records that an ETSO authorization rests on, confirming that each tested and delivered article traces to a controlled build standard. It is run by or for an equipment or avionics supplier while the authorization package is being assembled, ahead of the certifying authority's formal review. It checks article part and serial identity, the configuration each specimen was built to, and whether the units that produced the qualification results are eligible to represent the production standard. You get a gap assessment, an evidence map that links every conformity statement to its source, and a closure plan the supplier can work before submission.
When this review is needed
- Qualification testing is complete and the conformity file has to prove the tested units matched the intended production build.
- A specimen was reworked between test campaigns and the records must show which configuration each result belongs to.
- The authorization submission is being staged and every conformity statement needs a traceable source before it goes in.
- An internal audit flagged conformity paperwork that names parts without tying them to a released drawing or configuration index.
The problem
The records get written across the life of a test program, so the article that carries a serial number early can drift from the unit that produced the final qualification result. When a specimen is reworked, re-serialized, or swapped between rigs, the paperwork often keeps the old identity, and the tie between a DO-160G result and a controlled configuration quietly breaks. By the time the package is assembled, no single document proves the tested article and the production article are the same thing.
What gets reviewed
- Article part number and serial identity reconciled across test reports, build records, and the conformity statements
- The configuration each test specimen was built to, referenced to a released drawing or configuration index
- Eligibility of the tested units to represent the production standard being authorized
- Rework, re-serialization, and specimen substitution captured with the campaign each result belongs to
- Load-state conformity for software and hardware against the DO-178C and ARP4754B baselines under authorization
- Every conformity statement linked to a retrievable source rather than asserted on a summary sheet
Scope this review
Tell us the asset, the event, and the evidence in scope, and we will outline a focused first engagement.
Identify what is missing against the means of compliance.
What gets validated
- Each qualification result names an article whose configuration is fixed to a controlled drawing revision
- Serial numbers in the conformity file reconcile with the build records and the test-report headers
- A specimen reworked between campaigns carries a record of what changed and which results predate the change
- Software and firmware load states on the tested units match the baseline claimed for the production standard
- No conformity statement cites a configuration that the released drawing set does not support
Evidence normally required
- Certificates of conformity or conformity statements for the tested articles
- Build and manufacturing records showing the configuration each specimen was produced to
- Qualification test reports with their article identity and serial headers
- The released drawing set or configuration index for the production standard
- Any rework, deviation, or nonconformance records for the test specimens
Common discrepancies
- A test result whose specimen was reworked after the run, with no record fixing the result to the earlier build
- A serial number on a conformity certificate that does not appear in the build records for that configuration
- Firmware and software load states on the tested units that predate the baseline claimed for production
- A conformity statement asserted on a summary sheet with no traceable manufacturing record behind it
What is at stake
If conformity cannot be shown against a controlled build standard, the certifying authority cannot accept the qualification evidence as representative, and the results have to be re-argued or the testing repeated. That reopens a test campaign the supplier believed was closed and pushes the authorization date out, usually after commitments to an installer have already been made.
How the work runs
Fix article identity
Reconcile part and serial identity across build records, test reports, and conformity statements for each specimen.
Anchor to configuration
Tie each tested article to a released drawing revision or configuration index for the production standard.
Trace the load states
Confirm software and firmware baselines on the tested units match the standard being authorized.
Plan the closure
List each conformity statement without a source and sequence the records or retests needed before submission.
What the buyer receives
- A gap assessment listing each conformity statement that lacks a controlled configuration or source
- An evidence map tying every article identity and result to its build and test source
- A closure plan sequencing the missing conformity records the supplier needs before submission
Who uses the output
- Certification leads assembling the authorization package for the certifying authority
- Quality and configuration staff reconstructing the build identity behind each tested article
- Engineers deciding whether a reworked specimen's results can still represent the production standard
How the work fits into the transaction or program
Conformity records sit under the qualification and compliance evidence in an ETSO package: they are what lets the authority treat a test result as representative of the article being authorized. This review runs after testing and before submission, so a broken article-to-configuration link is found while the supplier can still fix records or re-run a specific test, rather than during the authority's own conformity check.
Start with a single asset
Reduce finding cycles by checking the package first.
Jurisdiction-specific considerations
Under the EASA authorization route, conformity is assessed against the production configuration the supplier is committing to, and Part 21 expects the tie between test specimen and production standard to be shown on records, not inferred. Where the same equipment is also pursuing an FAA TSO, the conformity evidence has to satisfy both authorities' expectations for article identity, so the review notes where a record acceptable to one may need supplementing for the other.
Regulatory limits
The review examines whether conformity records tie the tested and delivered articles to a controlled configuration. It does not issue a certificate of conformity, make an airworthiness or eligibility determination, grant an ETSO authorization, or bind the certifying authority to accept any specimen as representative.
What this review does not cover
- Performing or witnessing conformity inspection of the physical articles
- Re-running qualification tests on any specimen
- Issuing certificates of conformity or any authority approval
Specific to this review
- Conformity breaks most often at rework: a specimen changed between campaigns keeps its old serial, so results silently attach to a build that no longer exists.
- A qualification result is only usable if the article that produced it is eligible to stand for the production standard, which is a records question before it is a test question.
- Software and firmware load states are a frequent conformity gap because they change faster than the hardware serial identity that the paperwork tracks.
Sources
European Union / EASA. EASA design and production certification, STCs, ETSO authorizations, and EASA Form 1 release.
RTCA. Environmental qualification test categories and procedures referenced by TSO and equipment qualification.
RTCA. Objectives and lifecycle data for airborne software assurance, by design assurance level (DAL A-E).
U.S. Government (eCFR). Type certificates, STCs (Subpart E), TSO authorizations (Subpart O), PMA (Subpart K), and export airworthiness approvals (Subpart L).
Federal Aviation Administration. FAA type certification process, certification basis establishment, and compliance findings.
Frequently asked questions
Can we still use test results from a specimen we later reworked?
Sometimes, but only if the records fix which results predate the rework and show the change did not affect the characteristic being demonstrated. Where that record does not exist, the result cannot be treated as representative and either has to be re-argued or the test re-run on a conforming article.
Relevant glossary terms
Related pages
Where this fits
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