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EASA Restricted Type Certificate (CS-VLA)

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Some (all !?) CS-VLA aircraft have an EASA "Restricted " Type Certificate. What is “Restricted” here? Is the TC not ICAO-compliant or is it the restriction to VFR or even day VFR?

ESKC (Uppsala/Sundbro), Sweden

I think it is a certified aircraft with uncertified components (avionics, engine, prop).

Ask them [email protected]

Freelance IRI / CB-IR Instructor
LOWG | Worldwide

Snoopy wrote:

Ask them [email protected]

Good idea! I’ll be back.

ESKC (Uppsala/Sundbro), Sweden

Just out of curiosity, where can the RESTRICTED comment be found? In the Aquila 210 Type Certificate, I cannot find the wird restricted and it is certified as a VLA:


Aquila 210 does not have an RTC. It has a TC.

Mainz (EDFZ), Germany

VLA is fully certified while RTC not. VLA#RTC


Yes the reason I know is the same as Snoopy’s.

As an example in the Discus 2c-FES glider TCDS (p32 and 37)
local copy

E.I General, point 3

Airworthiness Category:
Restricted category (see E.V. Note 6)
Powered Sailplane, JAR 22 – Utility

E.V Notes, note 6

Model Schempp-Hirth Discus-2c FES is only eligible for a Restricted Certificate of Airworthiness as engine and propeller are accepted as part of the aircraft according to PART 21.A.23(c)(2).
Last Edited by Xtophe at 28 Jan 11:00
Nympsfield, United Kingdom

Michal wrote:

VLA is fully certified while RTC not. VLA#RTC

So what isn’t “fully certified” in a RTC and what are the practical consequences?

ESKC (Uppsala/Sundbro), Sweden

as far as I know I think you can use RTC as any other LSA or part 23 aircraft – training, time building. Some RTCs are even approved for Night flying.


Snoopy wrote:

Ask them [email protected]

So I did and this was the reply:

The references for the legal background for restricted TC are
* the basic regulation EU 2018/1139 and
* Part-21 (Annex I to Regulation (EU) No 748/2012 as amended with EU 2019/897¬).

According to the basic regulation EU 2018/1139 (Article 18) a restricted TC is issued when the “design of an aircraft does not comply with the essential requirements referred to in Article 9” (annex II) of the same regulation. The conditions for issuance of a TC or an RTC are in part 21. In particular, according to point 21.B.103 of part 21, a TC or an RTC for A/C can be issued when the applicant has demonstrated compliance to the certification basis defined by the Agency. According to 21.B.80, for a TC the certification basis should ensure compliance to the essential requirements in annex II of the basic regulation. While for restricted TC it is sufficient that the A/C certification basis provides a level of safety adequate with regard to the intended use, through the use of restrictions.

Based on the above I try to answer your question:

  1. Some (all !?) CS-VLA aircraft have an EASA "Restricted " Type Certificate. What is “Restricted” here?
    There are several aircraft for which a restricted type certificate has been issued. The reason is not the same and the corresponding restrictions change accordingly (Depending on the essential requirements that have not been met). Some examples are agricultural aircraft, aircraft used for special missions. Another typical example of aircraft for which a restricted TC has been issued in the past is aircraft whose engine does not have its own TC. Before the recent amendment of part 21, in such case the aircraft could obtain only a restricted TC. But this is not any more necessary with the basic regulation EU 2018/1139 and with the recent amendment of part 21 EU 2019/897.
  2. Is the TC not ICAO-compliant?
    No, the TC is not ICAO compliant;
  3. Is it the restriction to VFR or even day VFR?
    The restriction changes case by case and Each TCDS should states what is the restriction. Just be aware that in the case explained above of A/C without engine TC, the restricted TC was issued with no operational restriction.

The answer to question 2 is interesting. That should mean that aircraft with restricted type certificates can’t fly outside EASA-land without permits, just like experimentals and other Permit to Fly aircraft.

Last Edited by Airborne_Again at 20 Feb 19:27
ESKC (Uppsala/Sundbro), Sweden
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