EASA Form 1 Has Changed – What Does this Mean for You?

The EASA Form 1 has changed!  Despite the change, though, this should have relatively little impact on those who are relying on the EASA Form 1 in conjunction with aircraft parts transactions.  In particular, the changes are limited to EASA Form 1 for articles from simple general aviation aircraft, which means that the change will have very little effect on the commercial aviation community.

The text on the new Form 1 remains nearly identical to the old text. The only change was to the footer, which has been changed as follows:

Old Footer: EASA Form 1 — MF/145 Issue 2

New Footer: EASA Form 1 — MF/CAO/145 Issue 3

It is important to recognize that other than the footer, the text on the form has not changed at all.

Why is the Footer Important?

The text in the footer of the EASA Form 1 is important because it links you back to the instructions that were used for completing the form.

EASA actually maintains two different versions of the EASA Form 1 – a version published in Part M for maintenance purposes and a version published in Part 21 for production purposes.  The Part 21 version of the form has a footer that reads “EASA Form 1-21 Issue 2,” and this footer indicates that the form was completed under the Part 21, Annex I, Appendix I instructions.

EASA Form 1 with the new footer (“EASA Form 1 — MF/CAO/145 Issue 3”) means that the form has been completed using the new changed instructions.  Thus, we need to look at those changes to understand how to respond to this new version of the Form 1.

What are the Changes?

The instruction changes associated with Issue 3 of the EASA Form 1 are minimal.  Only the instructions for completing block 12 and block 14a have been changed.  The instructions for completing block 12 and block 14a have been amended (1) to include reference to the Part CAO regulations and (2) to abbreviate “Certificate of Release to Service” as “CRS.”

EASA has established rules for a “combined airworthiness organisation,” or CAO, which is an organization that has both CAMO privileges and also maintenance privileges.  CAOs are authorized to work on non-complex aircraft that are not operated by an air carrier (i.e. simple general aviation aircraft).

In summary, the only substantive change to the EASA Form 1 instructions in issue 3 is conforming instructions that permit CAOs (under the CAO regulations) to issue the Form 1.

The new text for the block 12 instructions is here – with additions underlined and deletions shown with strike-through:

For maintenance organisations approved in accordance with Subpart F of Annex I (Part-M) or Annex Vd (Part-CAO, the component CRS certificate of release to service statement referred to in point M.A.613 and CAO.A.070, as applicable:

“Certifies that, unless otherwise specified in this block, the work identified in block 11 and described in this block was accomplished in accordance with the requirements of Section A, Subpart F of Annex I (Part-M) ) or Annex Vd (Part-CAO) to Regulation (EU) No 1321/2014 and in respect to that work the item is considered ready for release to service. THIS IS NOT A RELEASE UNDER ANNEX II (PART-145) TO REGULATION (EU) No 1321/2014”

 

The new text for the block 14a instructions is here – with additions underlined and deletions shown with strike-through:

Mark the appropriate box(es) indicating which regulations apply to the completed work. If the box “other regulations specified in block 12” is marked, then the regulations of the other airworthiness authority(ies) must be identified in block 12. At least one box must be marked, or both boxes may be marked, as appropriate.

For all maintenance carried out by maintenance organisations approved in accordance with Section A, Subpart F of Annex I (Part M) or Annex Vd (Part-CAO) to Regulation (EU) No 1321/2014, the box “other regulation specified in block 12” shall be ticked and the CRS certificate of release to service statement be entered made in block 12. In that case, the certification statement “unless otherwise specified in this block” is intended to address the following cases:

(a) where maintenance could not be completed;

(b) where maintenance deviated from the standard required by Annex I (Part-M) or Annex Vd (Part-CAO);

(c) where maintenance was carried out in accordance with a requirement other than that specified in Annex I (Part-M) or Annex Vd (Part-CAO); in this case, block 12 shall specify the particular national regulation.

For all maintenance carried out by maintenance organisations approved in accordance with Section A of Annex II (Part-145) to Regulation (EU) No 1321/2014, the certification statement “unless otherwise specified in block 12” is intended to address the following cases:

(a) where maintenance could not be completed;

(b) where maintenance deviated from the standard required by Annex II (Part-145);

(c) where maintenance was carried out in accordance with a requirement other than that specified in Annex II (Part-145); in this case, block 12 shall specify the particular national regulation.’;

Where Can I Find the New Form 1 Instructions?

EASA publishes Easy Access Rules for Continuing Airworthiness.  Many people in the industry have relied on the Easy Access Rules to identify the relevant EASA standards.  EASA is transitioning to the eRules on Continuing Airworthiness.  The eRules represent a comprehensive, single system for the drafting, sharing and storing of EASA rules.  Like the Easy Access Rules, it is an unofficial statement of the rules (the official version is the version found in the EU Implementing Regulations.

The ERules have been updated to reflect the four EU Commission Implementing Regulations that took effect since the April 2019 publication of the Easy Access Rules (the most recent publication):

  • (EU) 2018/1142 (14 August 2018);
  • (EU) 2019/1383 (8 July 2019);
  • (EU) 2018/1142 (14 August 2018);
  • (EU) 2020/270 (25 February 2020).

This means that the 2019 version of the Easy Access Rules does not include the new revision of the EASA Form 1, but the eRules do include the new form (and its new completion instructions).  It can be found in Annex I, Appendix II of Part M.

 

FAQ: Can I Receive the Old Version of the Form 1 (for EU-registered aircraft)?

When receiving satisfactory-condition aircraft parts under EASA 145.A.42, the receiver typically must obtain them with an EASA Form 1 or equivalent.

Unless EASA does something (in the future) to invalidate an old EASA Form 1, properly completed prior versions of the EASA Form 1 remain acceptable.  One reason for this is because the EASA regulations specify receipt of an EASA Form 1, but they do not specify a specific version or revision level for receipt.  Before issue 3 became live, maintenance would have been required to be documented on issue 2.

So yes, if you are receiving aircraft parts with an EASA Form 1 and want to confirm that the documentation meets the requirements of EASA Form 1, then the mere fact that the EASA Form 1 is the old version (issue 2) does not invalidate the documentation.

But be careful, because if an aircraft part was approved for release to service by an EU repair station on or after March 24, 2020, then it should be have been relased on issue 3 of the EASA Form 1.  EASA has not yet released guidance on what to do if an EU repair station uses issue 2 of the EASA Form 1 after that date, but if it is considered to be an error then the repair station shold be able to issue a replacement on the issue 3 version of the Form pursuant to Part M, Appendix II, Paragraph 4.

Also note that there is no change to the EASA Form 1 for new parts (the Part 21 footer remains valid).

 

FAQ: If My Business is a Repair Station with EASA Credentials then Can We Issue the Old Version of the Form 1?

After maintenance on a component, a repair station holding Part 145 certification in the EU issues a certificate of release to service (“CRS”).  The regulations typically require the CRS to be issued on the EASA Form 1 referred to in Appendix II of Annex I (Part-M).  As of March 24, 2020, the new version of the EASA Form 1 (issue 3) is the current version found in Appendix II of Annex I (Part-M).  Therefore EU repair stations should now be using the issue 3 version of the EASA Form 1.

This may require a change to the Maintenance Organization’s Exposition (MOE) for the 145 organization if the MOE specified use of EASA Form 1 issue 2 (e.g. in the forms section of the MOE).  If your Maintenance Organization’s Exposition has not been updated to permit use of EASA Form 1 issue 3, then you should coordinate with your local CAA.

 

FAQ: Can I Receive the New Version of the Form 1 (for US-registered aircraft)?

In the United States, a dual-release EASA Form 1 is accepted under the Maintenance Implementation Procedures (MIP) of the Bilateral Aviation Safety Agreement.  Neither the MIP, nor the Mainenance Annex Guidance (which interprets the MIP), specifices the issue version of the EASA Form 1, so any issue should be equally acceptable under those agreements.

Yes, if the EASA Form 1 is properly completed as a dual release, then either the issue 2 version or the issue 3 version should be acceptable to allow a part to be received for ultimate installation on a US-registered aircraft.

 

FAQ: What About New Parts?

This change only affects maintenance releases.  It does not apply to EASA Form 1 for release of new production parts from a POA holder’s system.

If you look at the footers on your EASA Form 1s, you should see two different types of footers.  The EASA Form 1 for new production parts should say:

EASA Form 1-21 Issue 2

But if you look at your maintenance release EASA Form 1, it will say one of these two things in the footer:

Old Footer before March 24, 2020: EASA Form 1 — MF/145 Issue 2

New Footer as of March 24, 2020: EASA Form 1 — MF/CAO/145 Issue 3

EASA has two different sets of instructions for completing EASA Form 1, and the version of the instructions used to complete the form correlates to the footer on the form.  The new instructions (and the new footer) are only associated with the maintenance instructions and they are related to the new privileges for CAOs to issue EASA Form 1 as a maintenance release.  Nothing has changed for the production release; and production releases continue to be documented on the same version of the form that has been used.

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

One Response to EASA Form 1 Has Changed – What Does this Mean for You?

  1. George D'Aurio says:

    Nice article, Jason. Thank you. I noticed that the official EASA Form 1 found here:

    Click to access Consolidated_Regulation_%28EU%29No1321-2014_on_Continuing_Airworthiness.pdf


    has a single quote at the end of the new text (EASA Form 1 — MF/CAO/145 Issue 3). It reads EASA Form 1 — MF/CAO/145 Issue 3′.
    Probably a typo but I can remember when the 8130-3 form first came out, it had a typo and we were told to include the misspelled word when we duplicated that form.

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