Are you thinking of exporting an aircraft or component? If so, you must deregister the aircraft. You may also need an export airworthiness certificate and approval of a temporary ferry fuel system modification.
First, it’s important to note that ‘export’ of an aircraft in this context relates to the removal of an aircraft from the New Zealand Register of Aircraft – known as ‘de-registration’ – and not when the aircraft physically leaves the country.
An aircraft on the New Zealand Register of Aircraft must comply with New Zealand’s Civil Aviation Rules, regardless of where in the world it’s located or operating.
An aircraft may be ‘exported’, ie, removed from the New Zealand Register of Aircraft, or de-registered, either while it’s still in New Zealand, or when it’s already positioned in another country.
Aircraft engines, propellers, and other aeronautical products may be exported separately.
In this case, ‘export’ does mean simply shipping the component from New Zealand to a foreign country.
It’s very important components are accompanied by the correct documentation to ensure they are acceptable to the importing country.
An export airworthiness certificate is designed to assist the official transfer of an aircraft from one national airworthiness authority to another. It’s primarily aimed at the authority of the importing country, to facilitate the transfer from the register of the exporting country. It’s not primarily intended for the use of the aircraft purchaser or importer.
The export airworthiness certificate says the aircraft conforms to the aircraft type certificate, including compliance with all airworthiness directives and maintenance requirements. It does not say the aircraft complies with any agreements or contracts between the vendor and purchaser; nor does it constitute authority to operate the aircraft.
The export airworthiness certificate is valid on the day it’s issued. It’s effectively a ‘snapshot’ of the aircraft and its supporting documentation on that day.
There’s no Civil Aviation Rule saying you must get an export airworthiness certificate to export an aircraft. Whether you need one or not is largely down to the requirements of the national airworthiness authority of the importing state and/or the intending foreign owner/operator.
But we strongly advise an exporter to obtain an export airworthiness certificate, as it should facilitate the entry of the aircraft onto the register of the country it’s being exported to.
As part of the issue of an export airworthiness certificate, we'll ensure the aircraft meets the requirements of the importing country, so the exporter would know in advance the aircraft is basically acceptable to the importing country.
In addition, in the case of aircraft being exported to the United States, the bilateral airworthiness agreement between the US and New Zealand requires aircraft being transferred between the two countries to be accompanied by an export airworthiness certificate.
Only aircraft which have been type-certificated or type-accepted in New Zealand are eligible for issue of an export airworthiness certificate. Amateur-built aircraft, warbird aircraft, or any other aircraft holding an airworthiness certificate in the Special category are not eligible.
That’s because an export airworthiness certificate certifies conformity to a type certificate, and only aircraft that have been type-certificated are eligible. If that type certificate was issued outside New Zealand, it must have been type-accepted in New Zealand.
An aircraft must be registered to be eligible for the issue of an export airworthiness certificate, and it must be available for inspection.
Only we can issue an export airworthiness certificate. The aircraft owner or their appointed agent applies to us for issue of an export airworthiness certificate.
An aircraft is eligible for issue of an export airworthiness certificate when the following requirements, as specified in CAR 21.331, have been met:
In practice, there are two largely separate CAA activities involved in the issue of an export airworthiness certificate.
Firstly, it determines the requirements of the importing state. If requested to by the applicant, we'll contact the authority of the importing state, on behalf of the applicant, to determine whether the basic aircraft type design is acceptable to them and whether they have any special requirements.
We maintain a database of aircraft types and countries, which have advised that the aircraft type is acceptable to them, to minimise the number of new enquiries that must be made. For aircraft being returned to their country of manufacture it can be assumed the basic type design is acceptable to that country.
Another requirement for acceptance by the importing country relates to exceptions. An exception is a discrepancy, which could consist of a non-conformity with the type design or a non-conformity to a New Zealand Civil Aviation Rule, which must be listed on the export airworthiness certificate. A ferry fuel system not fully meeting applicable airworthiness requirements would be a typical exception appearing on an export airworthiness certificate. If there are any exceptions, these need to be agreed to by the importing country before the issue of the certificate. It’s important therefore to identify any exceptions early, as obtaining acceptance of these can be time-consuming.
Secondly, we inspect the aircraft and its maintenance records. This inspection is basically the same as would occur if we were carrying out an inspection for initial issue of a New Zealand airworthiness certificate. We'll review all the aircraft maintenance records and inspect the aircraft to ensure the aircraft conforms to its basic type design, complies with all applicable rules, including airworthiness directives, and is in a condition for safe operation.
We'll give full details of this inspection at the time of application for issue of the export airworthiness certificate. In general, the we won't carry out the inspection until the requirements of the importing country are known.
As the export airworthiness certificate is valid only on the date of issue, the certificate must be issued very close to the actual date of inspection. If there are any delays between the inspection and the issue of the certificate, which could be caused by discrepancies found during the inspection, which requires either rectification or listing the discrepancy as an exception on the export airworthiness certificate, (which itself requires the acceptance of the CAA of the importing country), a further inspection may be required.
There’s no initial application fee but our standard per-hour fee applies. For a typical general aviation aircraft where there were no complications a typical time for the complete job would be between 8 and 12 hours. If the aircraft is a more complex type or there were exceptions on the export airworthiness certificate, which required additional liaison with the airworthiness authority of the importing country, this could increase the cost of the job.
It may be possible to obtain an export airworthiness certificate for an incomplete or otherwise non-airworthy aircraft, (such as an accident-damaged aircraft.) This will depend on the aviation authority of the importing country. Missing components, or any other reason for the aircraft not being airworthy, will have to be specified accurately as an exception on the export airworthiness certificate, and this exception would have to be accepted by the aviation authority of the importing country before issue of the certificate.
If you would like further details about the issue of an export airworthiness certificate, or an estimate of the cost of obtaining an export airworthiness certificate for your aircraft, contact our airworthiness unit.
As with aircraft, only aircraft engines or propellers which have been type-certificated are eligible for export documentation. There are two options in terms of export documentation for aircraft engines and propellers.
An export airworthiness certificate for an aircraft engine or propeller is issued in basically the same way as for a complete aircraft.
Ideally, the aircraft engine or propeller will be newly overhauled, or installed on an airworthy aircraft. If the aircraft engine or propeller is not currently installed on an airworthy aircraft, or newly overhauled, full details of the aircraft it was last installed on, and the reason for removal will be required.
An application using the same form as for export of an aircraft is made to us. The same two-stage process is involved, except it’s more likely the foreign aviation authority will not need to be contacted unless exceptions on the certificate are involved.
An inspection of the aircraft engine or propeller by us is required, but as it’s not always possible to determine the condition of an aircraft engine or propeller by inspection, the accuracy and completeness of the maintenance records are extremely important.
An authorised release certificate or CAA Form One, can be issued only by a Part 145-certificated maintenance organisation. The CAA Form One is equivalent to the FAA 8130-3, the JAA Form One, the Canadian TC24-0078 and the Australian CASA DA1.
If a used aircraft engine or propeller is to be exported using a CAA Form One, the advice of a Part 145-certificated maintenance organisation should be sought. The conformity of the aircraft engine or propeller to the approved type design and the fitness for return-to-service must be able to be determined. It’s likely that a Part 145-certificated maintenance organisation would be prepared to issue a CAA Form One only in respect of an aircraft engine or propeller which it had either newly overhauled, or carried out maintenance on, and for which it had issued a certificate of release-to-service.
The only products other than complete aircraft, engines, or propellers which are eligible for issue of export documentation are:
The export documentation for such products is also the authorised release certificate, or CAA Form One.
A CAA Form One can be issued only by a Part 148-certificated manufacturing organisation, in the case of newly manufactured parts, and by a Part 145-certificated maintenance organisation, in the case of used parts.
If used aircraft components are going to be exported, the advice of a Part 145-certificated maintenance organisation should be sought. The conformity of the component to the approved type design and the fitness for return-to-service must be able to be determined.
If the component is not newly overhauled, full details of the aircraft it was last installed on, and the reason for removal, will be required. If the component has a finite fatigue life specified, the complete service history of the component will be required, including the original delivery certification documentation.
Information on the issue and use of the CAA Form One is given in Advisory Circular AC00-5 Parts documentation – CAA Form One – authorised release certificate.
An aircraft can be registered in only one country at any one time. Another country will not register an aircraft until it has received official notification the aircraft has been removed from the register of the exporting country (de-registered). This is an ICAO requirement, which is specified in rule 47.51(b).
Therefore, at some stage during the export of an aircraft, it must be removed from the New Zealand Register of Aircraft (de-registered). Otherwise it remains a New Zealand aircraft and has effectively not been ‘exported’.
The timing of deregistration, however, can be very important. As part of the deregistration process, we revoke both the certificate of registration and, if one has been issued to the aircraft, the airworthiness certificate. For this reason, it’s very important that deregistration is requested at exactly the point desired by the registered owner.
To de-register an aircraft, use the de-registration of aircraft form. If the owner isn’t available to sign, use the form for de-registration of an aircraft with a statutory declaration included.
Once the aircraft has been de-registered, it cannot be flown until it has been registered in an ICAO state and issued with an appropriate flight authorisation document.
On de-registration, the airworthiness certificate is revoked. If the aircraft’s owners want to return it to the New Zealand Register of Aircraft, it would be treated as a completely new entry. That would involve paying the fees associated with registration, and our inspections.
Similarly, until the aircraft is de-registered, it must comply with all New Zealand requirements regarding operation, maintenance, and personnel licensing.
Once the aircraft has been de-registered and the certificate of registration and the airworthiness certificate, if issued, are revoked, both certificates should be returned to us.
Once the aircraft has been de-registered, the registration marks of that aircraft (eg, ZK-XYZ) become dormant for a period of 12 months before they are released for use on another aircraft. If an aircraft carries personalised markings, the owner will be given the option of reserving the marks again for their use.
For any questions on de-registration or personalised marks contact the aircraft registrar.