FAA 8130-3 on EASA planes

This was already published in a previous version of Part 21.

However a Part 145 organisation can only make use of 21.a.307.c if approved within its own manual. A part-66 engineer outside an organization is free to use it with owner approval.

This is a widespread issue, because most US “airframe component” sellers, and the well known distis like Aircraft Spruce (and their German distributor Sandelving) either don’t supply an 8130-3 at all or resist doing so or charge extra $100 for it etc etc.

This is one route, whereby a German firm issues an EASA-1. What their part-145 scope is I don’t know but if they can functionally test a Sandel EHSI and generate the form, they can probably do it for almost anything… Looking on Ebay recently, they have been doing these forms for US avionics shops who want to sell a used item on Ebay but don’t want to pay the Sandel price because that involves a mandatory refurbishment of the display system (polarisers etc) and a clean-up. And Sandel is appaently the only firm authorised to issue an 8130-3. Not suggesting any illegality of course, but it’s quite funny that human ingenuity knows few bounds especially when it comes to regulatory compliance

AFAIK, a 8130-3 in the US was originally used for the documentation of repairs and was not meant for new parts. In the past there were times were even a normal 8130-3 was not accepted by European AAs, it had to be a dual release form. No wonder the US vendors think of us as nuts and many refuse to further even think of European market. They simply don’t want to deal with strange things they don’t understand (many we neither). But, hope is around and yes, it is connected to EASA regulations. Any time I had questions or problems with parts, I so far always found a way together with the involved authorities (not against). There is no general path, as there are so many variations in demand. I doubt also there will be any much freedom, as not all eggs in the basket are fine, some breed crocodiles instead of the meant ducks, and quite some environments in Europe tend to stretch freedom immediately into darkness. But, message, if you have one problem this way, it is very likely you can solve it.

Where this form is required, and only 8130-3 is available, it still has to be a dual release 8130-3 if the part is “used” and the aircraft is EASA-reg.

Note that “used” includes a part you bought new, and later removed it from the aircraft.

To all posters,
this thread discusses exactly all aspects of my current situation

• a part of which there are just very few left, and which I can only get from the US,
• it’s a landing gear actuator rebuilt by LASAR, which comes with an FAA form 8130-3
• and which needs to be installed on a EASA registered Mooney.

So everything discussed here seems to apply (release form, part w/o serial number, not (?) primary structure (I guess), etc. etc.)
I did already read Peter’s pamphlet on part imports, the EASA CM 21.A, and a few other threads. Problem is, everything I find, including the thread
here above is quite old. Is anybody able to tell me, whether the situation (and the EASA winds) have changed ?

I am not aware that anything has changed for “major” parts i.e. for a part which is not NEW you need either an EASA-1 or an 8130-3 from an EASA approved FAA Repair Station.

There is also usually a process possible whereby an EASA145 company with the right scope can “inspect” the part and issue an EASA-1 form, for a fee. I was once offered this on a propeller, for GBP 600 or so

There are definitely people here who know, but actual practice varies a lot between countries and between companies.

I wonder if @KevinC is around; he may know the current situation.

Things like screws (as mentioned by Sebastian above) have always been a “special case” where people don’t look too closely. A major aviation distributor will normally buy these in bulk from the US and get an 8130-3 form covering the entire quantity, and when resold in smaller batches they will be accompanied by a Certificate of Conformity which “should” reference something in the distributor’s system which enables traceability back to the original 8130-3 form. But in practice most maintenance companies have boxes and boxes of screws and just pick what they need. In theory this is wrong because even the last washer should be traceable and the work pack should have an entry for that item. One hopes nobody would do this for things like wing attachment bolts… but then those cost so much that few companies will just keep them on the shelf.

Also a lot of smaller items have an “interesting” history in that they came from another company’s old stock; examples here. This practice (a distributor buying up old stock from a company which closed down) goes on a lot because the stock is worth a lot of money and if the paperwork is right then the part must be good

Can anybody help me in the next process: Customer required FAA 8130-3 for component removed serviceable from aircraft registered in EASA. I cannot find in the FAA or EASA regulation possibility for issuing without sending component on the component shop maintenance under component rating (if component is on the EASA & FAA capabilities).

@NikolaSRB post moved to existing thread (several identical-topic threads merged).

See posts above for the requirements. The 8130-3, for a used component, needs to be a dual release one i.e. the FAA145 company also needs to have EASA approval.

However there are exceptions – it depends on the type of component and the type of aircraft – see e.g. here.

I know this isn’t an answer to your question, but perhaps they can make it work without a 8130-3 / Form1 – see this thread and specifically this and this and finally this post.