Annual Inspection Requirement for Export C of A

by Allan
(Slidell, LA, USA)

A question similar to the one about Belize: I own an aircraft in the U.S. which is due an annual this month (October).

Is it still necessary to have a recent annual (less than 30 days) prior to getting an Export C of A?

The airplane is going to Brazil.

ANSWER: The requirement for a recent annual inspection was removed from FAR 21 Subpart L when that regulation was revised in April 2010.

However, the revised rule says you must meet the requirements for a standard certificate of airworthiness before an export certificate of airworthiness can be issued, unless of course you get a letter from the Brazilian authorities accepting the aircraft without meeting that requirement.

There are two ways of looking at this:

1. Meeting the requirements for the issuance of a Standard Certificate of Airworthiness.

Even though an annual inspection is no longer required per FAR 21 Subpart L, in order to meet the requirements for the issuance of a standard certificate of airworthiness you need to perform a 100-hour type inspection. The 100-hour and annual inspections are the same in scope and detail per FAR 43 Appendix D.

Our DAR guidance material still refers to the 100-hour inspection being performed within 30 days of making application for the Standard Airworthiness Certificate.

2. Meeting the requirements for continued validity of a Standard Certificate of Airworthiness.

The annual inspection is a regulatory requirement. The terms and conditions spelled out on your airworthiness certificate say in part:

“this airworthiness certificate is effective as long as the maintenance, preventive maintenance, and alterations are performed in accordance with Parts 21, 43 and 91 of the Federal Aviation Regulations as appropriate”

In order to meet the requirements of your Standard Airworthiness Certificate you need to perform the annual inspection.

So, to answer your question, yes you need to perform a 100hr/annual inspection prior to making application for an export certificate of airworthiness. You should also make the application within 30 days from the date the inspection was signed off.