In short: EASA accepts FAA Parts Manufacturer Approval (PMA) parts directly — “without further showing” — under paragraph 3.3.4 of the FAA–EASA Technical Implementation Procedures (TIP), which supersedes the old EASA Executive Director Decision 2007/003/C. But regulatory acceptance is only half the story. Most aircraft lease agreements still restrict or prohibit PMA parts, so even a part EASA happily accepts can become a redelivery liability. This article explains the policy, the three acceptance cases, and the governance an operator and CAMO must put in place.
Disclaimer. This article reflects the information available at the time of writing and is provided for general information and educational purposes only. It does not constitute technical, legal, or professional advice and must not be relied upon as such. Regulations, bilateral arrangements, and contractual practices change; always verify against the current FAA–EASA TIP, the applicable regulations, and your own approval and lease documents, and obtain qualified advice for your specific circumstances.
What Is a PMA (Parts Manufacturer Approval)?
A Parts Manufacturer Approval (PMA) is the FAA approval that allows a company — one that does not hold the type certificate for the complete product — to produce and supply modification and replacement parts for installation on type-certificated products. It is the standard route by which approved replacement and modification parts reach the market.
The single most important sub-classification is whether a PMA part is a “critical component,” because that is what determines how EASA accepts it.
Critical component — a part identified as critical by the Design Approval Holder (DAH) during the product certification process, or otherwise by the Authority for the State of Design. Typically these are parts for which a replacement time, inspection interval, or related procedure is specified in the Airworthiness Limitations Section, the certification maintenance requirements, or the Instructions for Continued Airworthiness (ICA).
Rule of thumb: if a part carries a life limit or a mandatory inspection in the Airworthiness Limitations Section (ALS), the certification maintenance requirements (CMRs), or the ICA, treat it as a critical component and apply the harder acceptance route below.
From Decision 2007/003/C to the FAA–EASA TIP
When EASA was established, several EU member states already held long-standing bilateral arrangements with the United States that accepted FAA-PMA parts. EU law, however, requires EASA to issue approvals for the design of parts and for their installation. To resolve this without choking established trade, EASA issued Executive Director Decision No. 2007/003/C of 16 July 2007, “on the acceptance of certification findings made by the FAA for parts designed in the United States under the PMA system.” That decision pre-approved FAA-PMA parts meeting one of three criteria, with the rule that non-critical parts were approved automatically on issue of the FAA PMA, without a separate EASA application.
Decision 2007/003/C is now superseded. EASA’s acceptance of FAA PMA parts is today governed by the FAA–EASA Technical Implementation Procedures (TIP), paragraph 3.3.4 (current at Revision 7 & 7.1), issued under the EU–US Bilateral Aviation Safety Agreement (BASA). The substance is continuous — the three-criteria logic of the 2007 decision is exactly what became §3.3.4.1, §3.3.4.2, and §3.3.4.3 — but the legal vehicle, terminology, and references have moved on. If your exposition, work instructions, or training material still cite 2007/003/C as the live reference, that is your first correction.
A subtle but useful point: under the EU framework the parts are not merely tolerated. Historically the 2007 decision issued an EASA approval for qualifying PMA designs, and the TIP achieves the same outcome by directing EASA to directly accept the FAA approval. Either way the effect is automatic recognition with no separate EASA application.
The Three Acceptance Cases under TIP §3.3.4
The governing sentence of §3.3.4 is that EASA shall directly accept all FAA PMA approvals, without further showing, for modification and/or replacement parts for installation on products certified or validated by EASA — in the following cases.
§3.3.4.1 — Non-critical parts
If the PMA part is not a critical component, EASA accepts it directly where the PMA design was approved by either:
- identicality without a licensing agreement, per 14 CFR §21.303; or
- test reports and computations, per 14 CFR §21.303.
For the overwhelming majority of PMA parts — expendables and non-critical hardware — this is the route, and nothing further is required. In practice EASA asks that the statement “This PMA part is not a critical component” be entered in Block 13 (the Remarks block) of the FAA Form 8130-3. Your incoming inspection should look for it.
§3.3.4.2 — Licensing-agreement parts
Where the PMA part conforms to design data obtained under a licensing agreement from the TC or STC holder (again under 14 CFR §21.303), EASA accepts it provided the underlying TC or STC has itself been validated by EASA. The gate here is the validated certificate, not the criticality of the part.
§3.3.4.3 — Critical components
If the PMA part is a critical component, the §21.303 design basis alone is not enough. EASA accepts it only where an STC underpins the approval, by one of three routes:
- an FAA-issued STC that EASA has validated; or
- identicality without a licensing agreement (§21.303) plus an EASA-issued equivalent STC; or
- test reports and computations (§21.303) plus an EASA-issued equivalent STC.
The takeaway is simple and worth memorising: non-critical PMA flows through on the §21.303 basis; critical PMA always needs an STC bridge.
Regulatory Acceptance ≠ Contractual Acceptance: The Aircraft Lease Trap
Here is the trap that catches operators and CAMOs who stop reading at the regulation. A part that EASA accepts is not necessarily a part your lessor accepts.
With roughly 60% of the global fleet on lease, this is not an edge case. Lessors generally insist on OEM parts and avoid PMA, because the presence of non-OEM components can deflate the asset’s value, delay redelivery, and restrict the aircraft’s transferability to the next operator. Many lease agreements therefore carry an explicit clause to the effect that no PMA part shall be installed on the aircraft — frequently with stricter wording for the engines, APU, and landing gear, where residual value is most sensitive.
The consequence for continuing airworthiness management is concrete:
You may legally install a PMA part mid-lease, yet still be contractually obliged to remove it before redelivery. The most heavily negotiated section of any lease is the return (redelivery) conditions, which dictate the configuration in which the aircraft must be handed back. Where the lease permits PMA during the term, lessees typically use it for the cost and availability benefits and then remove and replace those parts with OEM during the pre-redelivery heavy check — or settle a buyout with the lessor for parts left installed.
The lessor will look. At lease return, records and physical surveys are scrutinised for installed PMA — particularly on the airframe, engines, and landing gear — and become a point of negotiation.
- The position is evolving, but the contract still governs. Some major carriers refuse to sign a lease that does not permit PMA, and lessors increasingly waive “no-PMA” clauses as PMA’s track record matures. None of that helps you if your specific lease is silent or restrictive: the time to settle PMA rights is during lease negotiation, not at goods-in.
In other words: EASA acceptance answers “may I fly it?” The lease answers “may I keep it on the aircraft when I give it back?” You must satisfy both.
Governance: Put Your PMA Policy in the CAME, the MOE — and Your Maintenance Contracts
Because two regimes apply at once — airworthiness and contract — your PMA policy must be written down and pushed out to everyone who can install a part.
- Define the PMA acceptance policy in the CAME. Your Continuing Airworthiness Management Exposition should state how PMA parts are evaluated and accepted (or restricted), how the critical/non-critical determination is made, how lease conditions are checked before installation, and how PMA installations are recorded and tracked.
- Mirror it in the MOE. The Part-145 Maintenance Organisation Exposition should carry the corresponding procedure for the workshop and the line: incoming-inspection checks, the 8130-3 Block 13 statement, eligibility verification, and a hold/route for any part the controlling lease prohibits.
- Transpose the policy into your maintenance contracts. A subcontracted MRO will fit what its own procedures allow unless your contract says otherwise. Build the PMA position into the contract scope and the work order so the policy survives outsourcing — and so a contractor cannot quietly install a PMA part that your lessor will later charge you to remove.
- Maintain a live PMA register for traceability. For every PMA installation, record part number, serial number, position/effectivity, the FAA Form 8130-3 reference, and the controlling lease’s stance. This register is what lets you plan removals before redelivery instead of discovering them during the return check.
This is precisely where good stores and incoming-inspection discipline pays for itself: the cheapest place to catch a non-conforming or contractually-prohibited PMA part is at goods-in, before it is ever issued to a job.
