FAA Form 8130-3 Airworthiness Approval Tag
What does it really mean?
By Joe Hertzler
The FAA’s current description/ definition of the Airworthiness Approval Tag is found in AC (Advisory Circular) 20-62D under section 7, paragraph a.
FAA Form 8130-3, Airworthiness Approval Tag, identifies a part or group of parts for export approval and conformity determination from production approval holders. It also serves as approval for return to service after maintenance or alteration by an authorized Part 145 Repair Station, or a U.S. Air Carrier having an approved Continuous Airworthiness Maintenance Program under Part 135.
As you can see from this definition, the form has two distinct purposes:
1. It is used to approve or certify that new and used parts meet conformity requirements from the "Original" Airworthiness side of the FAA.
2. To certify approval for return to service following maintenance from the "Recurrent" Airworthiness side of the FAA.
Functions of Form 8130-3
Since the early 1990’s when the form was revised to meet both these purposes, there has been some confusion about who is authorized to use the form and what the form actually signifies when it is received. The purpose of this article is to clarify the two distinct functions of FAA Form 8130-3 and identify what you should look for to determine its intended use.
The original 8130 form
To start with, it is important to provide a definition. Aviation products have been separated into three different classes dependent upon the complexity and or use of the product and are defined as Class I, II, and III products by 14 CFR Part 21.321, which has remained unchanged since March of 1979.
(1) A Class I product is a complete aircraft, aircraft engine, or propeller, which-
(i) Has been type certificated in accordance with the applicable Federal Aviation Regulations and for which Federal Aviation Specifications or type certificate data sheets have been issued; or,
(ii) Is identical to a type certificated product specified in paragraph (b)(1)(i) of this section in all respects except as is otherwise acceptable to the civil aviation authority of the importing state.
(2) A Class II product is a major component of a Class I product (e.g., wings, fuselages, empennage assemblies, landing gears, power transmissions, control surfaces, etc), the failure of which would jeopardize the safety of a Class I product; or any part, material, or appliance, approved and manufactured under the Technical Standard Order (TSO) system in the "C" series.
(3) A Class III product is any part or component which is not a Class I or Class II product and includes standard parts, i.e., those designated as AN, NAS, SAE, etc.
(4) The words "newly overhauled" when used to describe a product means that the product has not been operated or placed in service, except for functional testing, since having been overhauled, inspected and approved for return to service in accordance with the applicable Federal Aviation Regulations."
Back in the old days, FAA form 8130-3 was used strictly for the purpose of exporting Class II and III parts. The certification for export approval for these parts came from the FAA or an FAA designee (DAR). These "Export Certificates of Airworthiness" were needed when a foreign customer called and asked us to ship a Class II or Class III part. We would then call the local FAA, or a DAR with which we had established a relationship, and ask them to issue the 8130-3 certificate for the part(s). We then placed the 8130-3 certificate with the part and shipped it to the foreign customer.
That procedure has not changed much; however, the form has changed immensely and its purpose has become a bit more complex.
The last time I wrote about the 8130.3 Airworthiness Approval Tag was nine years ago when it first came into existence.
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