An Export C of A, however, regardless of the country issuing it, does not automatically mean that the aircraft will be accepted in the United States. What we often see, is an aircraft owner who has made the purchase decision based on the Export C of A and consequently been stuck with modifications to the aircraft in order to issue that U.S. Airworthiness Certificate. The key is to, as simple as it seems, read the written detail of the Export C of A to find what the person signing the document is really certifying. If the exporting country issues a certification to the effect that the aircraft meets U.S. type design and is in a condition for safe operation, the FAA will honor the certification. As described earlier, the FAA (or a designee) will review the evidence presented (including the Export C of A) by the aircraft owner (applicant) seeking the U.S. Airworthiness Certificate. If the aircraft being imported does not come with a valid Export C of A then the FAA will evaluate that aircraft in accordance with 21.183(d)(2) and require that an inspection equivalent to a 100-hour inspection be performed by an appropriately rated person. In either case, if the FAA finds that the aircraft meets the conformity requirements "Conforms to Type Design" then it will issue a U.S. Airworthiness Certificate.
It should be no surprise if you find that an aircraft that has been operated in a foreign country has a slightly different configuration. This is because each individual country has its own approved type design as well. What this means is that in order for an aircraft manufactured to the U.S. type design to be operated in a foreign country, there may be some configuration changes that need to be made. One example that comes to mind is the Raytheon King Air B200 (reference sidebar on page 62). The B200's U.S. configuration places the electrical inverters in the wings. In order to operate that aircraft in the United Kingdom, the inverters must be relocated to a different location. The design approved in the United Kingdom prohibits the inverters from being located in the proximity of fuel lines and in the King Air B200 fuel lines run through the wings. This is just one example of a configuration change. There are actually several specific modifications required for the King Air B200, as an example, all of which can be incorporated by installing what Raytheon refers to as "a UK Kit." Information regarding configuration changes required for export can generally be found on the aircraft U.S. Type Certificate Data Sheet (TCDS). Sticking with the King Air B200 example, we'll look at the Type Certificate Data Sheet for that aircraft. Looking at the section titled "Data Pertinent to all Model 200 Series" we find the following:
"The following models when modified to the applicable Beech modification drawing, are eligible for operations as noted below:
"The above models are eligible for return to U.S. certification when those portions of the above listed modifications which do not comply with U.S. requirements have been removed or replaced."
So you see, the United Kingdom kit is really Beech Mod No. 101-005004. One important note here is the second statement. Aircraft can only return to U.S. certification when elements of the Mod not approved by U.S. design have been removed or replaced. What this means is that we must not make any assumptions about the Beech Mod for United Kingdom conformity being FAA approved. The question must be presented to Raytheon for resolution.
This King Air example is just one of several. Many TCDS list special conditions for the issuance of an Export C of A. The sidebar on the opposite page offers a few keys to remember when it comes to the import of an aircraft into the United States.
Keys to remember when importing an aircraft
- Determine what country the aircraft was manufactured in and what country the aircraft was originally certified in. If the aircraft was not originally certified in the United States it may never have conformed to U.S. type design.
- Trace through the records and find out if the aircraft has ever held a U.S. Airworthiness Certificate. If the aircraft has never been certificated in the United States, the FAA must issue the new U.S. Airworthiness Certificate (not a DAR).
- Look at the TCDS for the aircraft and find out if any special conditions exist for the country or countries the aircraft is coming from. This will provide a clue as to what may need to be removed or modified for U.S. certification.
- Find out if any portions of the required modifications are approved for U.S. certification. It may be that modifying the aircraft for U.S. certification is cost prohibitive.
- Find out what bilateral agreements are in place for the exporting country. Appendix 4 to Advisory Circular 21-23A includes a table listing all of the countries with which the United States has bilateral airworthiness agreements.
- Find out if the exporting country issued an Export C of A for the aircraft. If so get a copy and read it carefully. Make sure the certifying DAR or FAA inspector sees a copy as well. It may make their job easier.
- Review the maintenance records to find any major repairs or major alterations that may require FAA Form 337's be created to properly document the work.
- There are many foreign repair stations that have the authority under U.S. regulation to work on U.S. certificated aircraft, however, when the aircraft is under German registry for example, the aircraft will have been approved for return to service under the German rule not the United States. You may be able to go back to the repair agency and receive U.S. certification for previous work.
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