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Aircraft Parts, aviation, Distribution, Export, FAA, International Trade, PMA, Uncategorized

New Agreement Confirms PMAs Are Accepted in Japan (without further showing)

The FAA and JCAB have announced a new revision to the Implementation Procedures for Airworthiness, or IPA.  The IPA is the agreement between the two authorities that explains how they will each accept aircraft and their components from the other.

The new IPA language confirms that Japan accepts FAA-PMA parts without any further showing.  First, the PMA are acceptable to JCAB as a minor design change, without the need for further validation:

3.3.1.5 PMA Parts: JCAB will directly accept all FAA PMA approvals, without further showing, for modification and/or replacement parts for installation on products certified or validated by the JCAB

The technical language is limited to PMA parts meant to be installed on “products certified or validated by the JCAB,” but certification or validation of products is necessary in order to be able to put such a product on the Japanese registry.  Thus, any aircraft that is on the Japanese registry has already been certified or validated by JCAB.

The IPA also confirms that PMA parts must be accompanied by an 8130-3 tag or equivalent.  The documentation should verify that the part conforms to FAA-approved design data.

The new revision will take effect on March 30, 2020.  Don’t worry about transactions in the interim!  PMA parts were acceptable under the old version of the JCAB-FAA IPA, as well.

About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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