The FAA has released for comment Draft Order 8110.103C. This is an update to the Alternative Methods of Compliance (“AMOC”) guidance. AMOC are typically used when an airworthiness directive (“AD”) provides one resolution to a safety problem, but the AMOC applicant has another approach that achieves the same level of safety. One example would be … Continue reading
Importing sub-components or raw materials for inclusion in your PMA Parts? Continue reading
The requirement to file beneficial ownership information introduced under the Corporate Transparency Act (CTA) has bounced around like a ping-pong ball for the past few months, with the on-again-off-again requirement being subject to both court action and executive action requiring it, suspending it, and making a mess of the efforts to determine how to comply.. … Continue reading
MARPA members need to be concerned about the affect of tariffs on their international business. Tariffs may affect inbound supplies and reciprocal tariffs from our trading partners may affect PMA sales as well. If you pull up the HTSUS today, it is not yet updated with the new tariffs, so we’ve summarized the upcoming tariffs … Continue reading
If you are obtaining any goods from Canada, Mexico or China, then you are no doubt avidly following the tariff threats to better assess your import duty obligations. As I am writing this, the President has issued executive orders acknowledging deals with Canada and Mexico; each provides for a 30-day suspension of the tariffs on … Continue reading
MARPA has published a white paper explaining the intellectual property ramifications of sharing a page from an illustrated parts catalog in support of an FAA-PMA application. In order to produce an aircraft part in the United States, the producer typically needs to obtain design and production approval from the Federal Aviation Administration (FAA). A parts … Continue reading
You may be required to file your company’s ownership/control information with the federal government. This has been added to the law to help support compliance obligations. For some MARPA members, a large business exception may apply (see below). In 2021, Congress enacted the Corporate Transparency Act (CTA). This law requires many companies doing business in … Continue reading
The deadline for Safety Management Systems (SMS) comments is coming soon. One key question asked in the FAA proposal is whether the SMS rules should be applied to PMA holders. Continue reading
A court recently held that a manufacturer who rebuilds a general aviation aircraft part becomes immune from accident-related civil suits 18 years after the original delivery date of the aircraft or the installation date of the part (if the part was not original equipment). This is important because the statute of repose does not get … Continue reading
We have received several inquiries from MARPA members asking about the effect of last week’s opinion out of the U.S. Court of Appeals for the Fifth Circuit, Jarkesy v. SEC, and what that opinion might mean for Department of Transportation Administrative Law Judges (ALJs) that companies and persons regulated by the FAA interact with from … Continue reading
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