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aviation, EASA, International Trade, Manufacturing

EASA SMS Rules Around the Corner for Manufacturers

The part 21 SMS requirements will likely be published by the European Commission in the first quarter of 2022.  This rule is expected to apply SMS requirements to manufacturers holding EASA Part 21 certificates.

The EASA SMS rule is expected to be applicable 20 days after the publication date (that’s when compliance is permitted).  Compliance with the EASA SMS rule is expected to be required one year later (385 days after the publication date).  The initial one-year period will be for initial implementing of SMS programs.

After initial implementation, the applicable authorities will audit and provide feedback to help get the manufacturers to full compliance. Each EASA Part 21 organization will have a two-year period for implementing missing elements with the help of the authorities (e.g. for implementing corrective action in response to authority findings). 

This is a new program so we expect that there will be findings issued against the implementers by the authorities.  The two-year transition period is meant to be a period during which all of the authority findings should be closed.

By the first quarter of 2025 the European Community expects that all EASA Part 21 organizations should be in full compliance with SMS.

We also expect to see an EASA Part 145 SMS rule and this may be issued before the end of 2021.

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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