Yes. PMA also means the part is a “legal direct substitute” for the original part. This can be airframe type limited, etc.
Interesting about radios… my project was making plug-compatible King autopilot servos 
Peter, production approval and PMA are not exactly the same. PMA includes both design and production approval, but it’s not the only kind of production approval in existence. In particular, PMA is an approval for manufacturing of non-OEM parts. Also, if I understand it correctly, it is a “minor” kind of approval, which only applies to parts as opposed to assemblies or units of equipment – that is, PMA can cover production of pistons or hoses but not engines or radios.
What is the “production approval”?
Is it an organisational QA approval? Some years ago I looked into making a PMA part and you needed such approval for that. It was virtually impossible to obtain it for a company outside the US. Well you could do it, but you would have to host multiple FAA inspectors visiting, and it really was not viable for a small company.
It would not surprise me if you needed an organisational QA approval for making TSO parts, or parts claimed to meet TSO requirements. After all, you are issuing a CofC and (in theory) that has to be issued against a specific QA framework.
The FAA says that VAL radios cannot be installed in type certified aircraft because VAL do not have a production approval under FAR Pt. 21.
It appears that VAL mean to say that their radios conform to TSO, and that the FAR require them to conform to TSO, but don’t need to be approved, and hence could be installed, following the minor/major mod decision making process. This misses the FAAs point entirely (if this is indeed what they want to say)
On a quick read this appears that the FAA says you need TSO avionics (which is true, although merely demonstrating compliance with TSO should also meet the regs; we did this before) while VAL’s response is a mixed bag of stuff which doesn’t mean a lot; in particular their major/minor alternation discussion seems to be irrelevant.
From here
Speaking of certificates of conformity, their use seems to have precipitated a recent scandal with VAL Avionics and their non-TSO NAV/COM systems. FAA issued an unapproved part notice, local copy whereas VAL countered with this. local copy What a mess…
Post moved from here
By the way – I am sure in the AOPA magazine 12-24 months ago there was all sorts of chat about “certified” Aircraft being able to benefit from the sort of Avionics that were seen in the non-certified sector. Also at that time, Grant Shapps working on deregulation.
Then in April 2016 it was announced that the Dynon EFIS d10a could be installed in a PA28 but not sure if in the US or EU land?
Is some deregulation about to happen in the EU or is it all more complicated?
Thanks – Archer 181
There is always a catch. Mode S transponders and 8.33 kHz radios for instance. There is no requirement that any of this must be certified in a non certified aircraft in Europe. But the “radio authority” and the airspace require these gadgets to adhere to certain performance specs. To show conformance to those specs is way out of reach for a normal person, so the only way to get the required radio and transponder is to purchase ETSO certified equipment.
An airplane manufacturer could of course manage to show conformance of of non certified equipment without actually certify it. But I don’t think we know all the implications this kind of system will create. I don’t think this kind of system will be any simpler.
Funny that… I always paid full list, AFAIK.
But my point stands… X% of 2k is less than X% of 10k.
The FAA is not stupid and they are really careful to not introduce undesirable precedents, so the inclusion of autopilots is massively significant.
Obviously this is great news but I just hope there isn’t a backlash, especially in Europe.
" It would also wipe out a lot of installer margins because 25% of 2k (uncertified) is a lot less than 25% of 10k (certified), but the installation labour is the same."
Whilst the dealer price does normally does include a 25% discount (some are less) no-one ever retails at list, so isn’t making anything like the margins you’re suggesting. The normal retail margin is typically 10-15%.
