How an FAA Repair Station may obtain an EASA Part-145 Certification

Introduction

In today’s global aviation market, having both FAA approval and EASA Part‑145 Certification is critical for repair stations that want to serve European Union customers. For an FAA‐approved repair station based in the US to obtain EASA Part‑145 Certification, it must navigate a detailed process governed by the bilateral agreement between the United States and the European Union. This certification not only confirms that the repair station complies with FAA requirements under 14 CFR Part 145, but it also demonstrates adherence to additional European Union regulatory standards as specified in the Maintenance Annex Guidance (MAG) . In this article, we explain the complete process—from the initial application to ongoing surveillance—in a step-by-step manner. Before proceeding further one must emphasize that this process is only applicable to FAA Approved Repair Station based in the US. The EU has bilateral agreements with other regions in the world and when an Aircraft Maintenance Organisation is based in a territory outside the EU subject to a different bilateral agreement than the process described in that bilateral agreement with that specific region applies and where no bilateral agreement is in place, a separate much more rigorous process applies. 

Understanding the Regulatory Background

FAA and EASA: A Bilateral Relationship

The bilateral agreement between the FAA and EASA is at the heart of this process. It allows a repair station that already holds an FAA Part‑145 certificate to pursue an EASA Part‑145 Certification. Under this agreement, the repair station must comply with the FAA regulations as well as additional EASA-specific requirements documented in the MAG. This dual oversight ensures that repair stations can operate globally, issuing maintenance releases for both U.S. and European markets.

Key Documents and Terminology

Several documents and terms are central to the process:

• EASA Supplement: An amendment to the Repair Station Manual (RSM) or Quality Control Manual (QCM) that aligns U.S. procedures with EASA requirements. This document must be customized to reflect the repair station’s operations .
• EASA Form 16: The application form that the repair station must complete to initiate the certification process. This form collects details on the organization’s structure, history, and operational capability .
• FAA Form 9: The FAA’s recommendation form, used to document the FAA’s evaluation and recommendation regarding the repair station’s compliance with EASA standards. Each line station must be included on a separate Form 9 during initial certification .
• MAG (Maintenance Annex Guidance): The guidance document that outlines the special conditions, procedures, and detailed requirements for an FAA repair station seeking EASA approval.

The Initial Certification Process

Applicant's Request and Documentation

A. Evidence of Need

For an FAA‐approved repair station to qualify for EASA Part‑145 Certification, the first requirement is to demonstrate the need for such approval. This is done by providing written evidence—such as a Letter of Intent (LOI), a work order, or a contract—from an EU-based customer (an AMO, operator, distributor, or lessor) . This evidence supports the business case for obtaining EASA certification.

B. Completion of EASA Form 16

Once the need is established, the repair station must complete the EASA Form 16. This form requires detailed information about:

• The repair station’s FAA certificate number.
• Facility addresses and contact details.
• A summary of the organization’s history, work capabilities, and line station locations.
• The identity of the Accountable Manager who is responsible for ensuring compliance with EASA standards .

It is crucial that the completed Form 16 is forwarded to the appropriate FAA Flight Standards Office (FSO) at least 60 days before the date when initial EASA approval is required.

C. Customized EASA Supplement

Parallel to the Form 16, the repair station must prepare an EASA Supplement. This document is essentially an addendum to the existing RSM/QCM that demonstrates how the organization’s quality system meets the EASA Special Conditions. The supplement should:

• Mirror the sample provided in Appendix 1 of the MAG.
• Be tailored to reflect specific operational procedures.
• Include detailed information about any line stations (known as “Line Maintenance Authorizations” in FAA terminology) , .

D. Submitting the Application Package

The application package includes:

• EASA Form 16.
• The customized EASA Supplement.
• A copy of the Air Agency Certificate and associated FAA OpSpecs.
• Evidence of need (LOI, work order, or contract).

These documents must be submitted to the FAA FSO well in advance of the intended approval date (typically at least 60 days prior) so that the FAA can conduct a preliminary review.

FAA's Review and Recommendation

Internal FAA Review Process

Once the application package is submitted, the FAA takes several steps to ensure the repair station meets both FAA and EASA requirements:

A. Review of the Documentation

An FAA Aviation Safety Inspector (ASI) reviews the EASA Form 16 for completeness and accuracy. In parallel, the ASI examines the EASA Supplement to verify that it aligns with the latest version of the MAG and accurately reflects the repair station’s procedures. Any discrepancies must be resolved before moving forward .

B. Audit/Inspection

The FAA conducts an on-site audit or inspection to verify compliance with both FAA regulations and the EASA Special Conditions as set out in the MAG. This audit focuses on:

• The repair station’s facilities and equipment.
• The quality assurance processes.
• Personnel training records.
• Maintenance procedures and the integrity of the documentation system.

Any findings or discrepancies discovered during the audit must be corrected within a prescribed period (typically not exceeding six months). Failure to resolve these issues can result in termination of the application process .

C. FAA Form 9 Recommendation

Once the documentation and inspection results are satisfactory, the FAA prepares a recommendation package that includes:

• A completed FAA Form 9, which details the repair station’s compliance with EASA requirements.
• A copy of the repair station profile that includes ratings, personnel details, and any outstanding investigations.
• Confirmation that the repair station’s quality system covers both the maintenance facility and any line stations.

This package is forwarded to EASA via email (typically to ) along with the other required documents .

EASA's Role and Certification Issuance

EASA's Review and Approval

After the FAA submits its recommendation package, EASA undertakes the following steps:

A. Application Review and Invoice Issuance

EASA reviews the complete application package for compliance with the Agreement between the FAA and EASA. The review includes a detailed check of the submitted FAA Form 16, EASA Supplement, Air Agency Certificate, and FAA Form 9. Upon satisfactory review, EASA issues an invoice in accordance with its fees and charges regulation .

B. Certificate Issuance

After payment is received, EASA issues an EASA Form 3 approval certificate. This certificate is valid for two years and serves as the formal EASA Part‑145 Certification. A copy of the certificate is sent to the FAA ASI, and the approved repair station is then listed on the EASA website for public verification .

C. Integration with FAA Oversight

Post-certification, the FAA ASI is required to enter into the system (SAS) that the repair station is both FAA-certificated and EASA-approved. The EASA Special Conditions are incorporated into all future FAA oversight audits, ensuring continued compliance with both U.S. and European standards.

Renewal and Amendment Procedures

Renewal Process

EASA Part‑145 Certification is subject to renewal every two years. The renewal process is designed to ensure ongoing compliance and continued operational safety:

A. Renewal Package Submission

At least 90 days before the current certificate expires, the repair station must prepare a renewal package. This package should include:

• An updated EASA Form 16.
• A review of the EASA Supplement to confirm it reflects current operations.
• A copy of the Air Agency Certificate and FAA OpSpecs.
• Evidence of the ongoing need for EASA certification (such as contracts with EU customers).

B. FAA and EASA Review

The FAA conducts a similar audit and review for the renewal package as in the initial certification. Provided all conditions are met, the FAA issues a recommendation using an updated FAA Form 9. EASA then reviews the renewal submission, issues a revised EASA Form 3 certificate with a new renewal date, and updates the web listing accordingly 

Change and Amendment Process

If there are changes in the repair station’s operations—such as a change in name, address (other than mailing address), or modifications to the scope of services—an amendment process must be initiated:

A. Submission of Amendments

The repair station must complete a new EASA Form 16 and update the EASA Supplement to reflect the changes. The updated documents must be sent to the FAA FSO concurrently with any FAA certificate amendments.

B. FAA Notification and EASA Update

The FAA is required to notify EASA of any proposed changes within 10 business days. Following a successful audit of the amended procedures, the FAA recommends acceptance via a completed FAA Form 9, and EASA subsequently issues a revised certificate, updating their public records accordingly .

Key Considerations and Best Practices

Importance of a Customized EASA Supplement

One of the most critical aspects of the process is the EASA Supplement. While the MAG provides a sample and guidelines, it is essential that the supplement is customized to accurately reflect the repair station’s operations. It must reference the relevant sections of the RSM/QCM and include detailed procedures for:

• Line station oversight.
• Work orders and contractor maintenance.
• Quality Assurance Systems (QAS) audits.
• Release and acceptance of components.

This customization not only ensures compliance with EASA Special Conditions but also aids in smoother FAA audits and fewer corrective actions post-inspection 

Documentation and Timelines

Strict adherence to documentation requirements and submission timelines is paramount. Key points include:

• Sending the complete application package (including Form 16, supplement, and FAA documentation) at least 60 days prior to the required approval date.
• Submitting the renewal package 90 days before the certificate expiration.
• Notifying the FAA immediately upon any operational or administrative changes that affect the certification status.

Proper documentation minimizes delays, prevents enforcement actions, and ensures that both FAA and EASA have up-to-date records for ongoing surveillance audits. 

Corrective Action and Continuous Improvement

Both the FAA and EASA processes emphasize the need for corrective actions when discrepancies or deficiencies are noted during audits. The repair station must address any findings promptly—typically within six months—and notify the FAA in writing once all issues are resolved. This continuous improvement cycle not only keeps the certification valid but also enhances overall safety and operational efficiency.

Training and Quality Assurance

To fully comply with both FAA and EASA standards, the repair station’s quality system must incorporate:

• Regular training programs (including human factors training tailored to the organization’s operations).
• Robust Quality Assurance Systems that cover both procedural and product audits.
• Detailed documentation and record-keeping that support the compliance claims made in the EASA Supplement and the RSM/QCM.

Ensuring that personnel are well trained and that quality systems are robust can significantly reduce non-compliance issues during both initial and renewal audits.

Ongoing Compliance and Surveillance

Future Audits and Continuous Oversight

Once certified, the repair station is subject to ongoing FAA oversight and periodic EASA audits. Key aspects include:

• The FAA ASI incorporating EASA Special Conditions into all future FAA oversight audits.
• Regular audits (both internal and external) to monitor compliance with the approved EASA Supplement.
• Timely corrective actions in response to audit findings, ensuring that the organization remains in good standing with both authorities.

Handling Work Away from a Fixed Location

For repair stations that perform maintenance away from their fixed facility (for example, on EU-registered aircraft during urgent defect rectification or Aircraft on Ground (AOG) scenarios), there are additional procedural requirements. The repair station must:

• Apply in advance for work away from the fixed location if not holding an OpSpec D100 Authorization.
• Provide detailed documentation of the work to be performed, including customer information and dates.
• Notify both FAA and EASA prior to commencing work outside the base facility.

This flexibility allows repair stations to serve EU customers even when work must be carried out off-site, but it requires strict adherence to both FAA and EASA procedural guidelines.

Conclusion

Achieving EASA Part‑145 Certification as an FAA‑approved repair station is a complex yet essential process for those aiming to operate in the European market. The process involves:

1. Demonstrating the need for EASA approval through written evidence.
2. Completing and submitting key documents such as EASA Form 16 and a customized EASA Supplement.
3. Undergoing thorough documentation review and on-site audits by the FAA.
4. Receiving a formal recommendation via FAA Form 9 and subsequent approval by EASA.
5. Adhering to renewal and amendment procedures to maintain ongoing compliance.

By carefully following the detailed steps set out in the MAG, repair stations not only secure access to a broader market but also ensure that they meet the high safety and quality standards demanded by both U.S. and European aviation authorities. This dual certification stands as a testament to the repair station’s commitment to excellence, safety, and international regulatory compliance.

For repair stations planning to expand their global reach, investing in the rigorous processes and quality systems required for EASA Part‑145 Certification is a strategic move. With meticulous preparation and continuous improvement, an FAA‑approved repair station can successfully navigate the certification process and remain competitive in today’s dynamic aviation industry.

Whether you are in the early stages of preparing your documentation or planning for your next renewal cycle, understanding each step in this certification journey is key to long‐term success and regulatory compliance in both the U.S. and European markets.

Further reading: EU-USA Bilateral Agreement