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Importing D reg into the UK, post Brexit

I presume this is a VAT event post Brexit, even if the aircraft is EU free circulation?

What about the process of converting to a G or N registry? Should the conversion to an N reg be carried out in Germany? A G reg conversion would practically be easier in the UK?

Germany has a different airframe and power plant log book convention?

Hoping some experienced voices join the thread but will post what I learn from Germany.

Oxford (EGTK)

Going EASA/Euro to N is like it always was: you need a US DAR and a few k. Some previous threads on DARs, including one who got removed by the FAA halfway through a job. I did this in 2005. This writeup is still mostly current, especially with the tactical advice which is really important.

Going D to G, I don’t know the current status. It used to be a CAA paper inspection exercise, during which the CAA would sometimes turn up stuff they didn’t like (reducing the value of one plane, won’t post details, to no more than 50%, as a result of a bodged STC done by one of the most “fanatically respected” companies on the mainland). But normally it went smoothly. Today, the process “should” be like going N to G, i.e. a can of worms, with a personal CAA inspection (like my plane had in 2002 when the CAA declared a KLN94 is VFR-only and demanded its IAPs disabled ) but I would not be surprised if the CAA is still being pragmatic about it. After all, they are accepting EASA pilot papers for 2 more years; something which Brussels has not reciprocated. I would be surprised to see recent data posted though; it is just 7 weeks since 31 Dec 2020, and most people don’t go public with their misfortunes.

No idea about German logbook procedures.

Not sure if this is relevant, since you plan to move it to G.

Administrator
Shoreham EGKA, United Kingdom

@Peter brilliant write up, I suspect going from D-reg to N-reg is quite painful and you could spend weeks chasing paperwork. Also N-reg aircraft can suffer a discount if they lived on a foreign register at some point.

A native born USA N-reg, ideally from zero humidity Nevada Arizona or New México, seems a better candidate.

Oxford (EGTK)

Anything to N should be the same process.

One exception is the Klinka letter but I don’t know whether this Export CofA avoidance process works for other makes. It should work for anything where you can get the manufacturer to state it met US requirements originally. The other Export CofA avoidance route is going onto 2-reg (Guernsey) but that has lots of problems; one mainland pilot I know did that and is tearing his hair out because 2 is demanding a 2-authorised engineer inspection at each Annual, etc.

Once N-reg, it doesn’t matter where is was before – VAT issues excepted, of course.

Administrator
Shoreham EGKA, United Kingdom

Feom our experience, going D to N is mich painfuller and more expensive than N to D. Especially with the TIP in place.

Remaining on the D Register isn’t an option?

mh
Aufwind GmbH
EKPB, Germany

Especially with the TIP in place.

How does that help, exactly?

Remaining on the D Register isn’t an option?

Not good for a UK licensed pilot, because Brussels has cancelled all UK license privileges (for EASA-reg usage) on 1st Jan 2021

You could license transfer (SOLI) to EASA (say Ireland) but then you have medical issues (EASA authorised UK AMEs only), and dealing with a D (LBA) maintenance regime, at a distance, different language, etc, finding EASA66 authorised mechanics in the UK (whose EASA-reg privileges were also cancelled by Brussels on 1st Jan 2021). In fact the last one could be a whole load of fun, since most EASA66 mechanics are full time employed.

For a UK pilot I would be either G-reg or N-reg, depending on A&P/IA availability and whether you have FAA papers (at least a 61.75 PPL and the Foreign Pilot Exam IR).

Administrator
Shoreham EGKA, United Kingdom

How does that help, exactly?

For the acceptance of FAA STC you pay a small fee for that an FAA DAR wouldn’t even pick up his phone.

For the rest, I see your point. Only, the UK pulled the plug, not the EU/EASA. That is a self-inflicted wound.

mh
Aufwind GmbH
EKPB, Germany

MH, you may recognise the following text (google translated)

The TIP recognizes minor changes (without changing the TC or STC). TIP allows the recognition of Basic STC without a technical review and that of Non-Basic STC in a streamlined process. This is much easier and cheaper than going through the entire approval process. This is not a one-way street either, the FAA does not recognize European STCs without an examination, and experience shows that it is not always easier or more flexible than the EASA.

and owner-manufactured parts,
Will be approved in Europe after 21.A.307 (c). Even if they weren’t built by the owner.

337 Are accepted (except for critical alternations) according to TIP 3.2.8.2.

This leaves plenty of areas where N has advantage, or where N to EASA (or N to G) would be a problem.

An FAA DAR is needed only to place a whole aircraft onto N. For mods, there are other routes.

Administrator
Shoreham EGKA, United Kingdom

What are they? Examples please.

mh
Aufwind GmbH
EKPB, Germany

It is what someone you know posted elsewhere on the internet, on a similar topic

Administrator
Shoreham EGKA, United Kingdom
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