Export of US Type Certificated Aircraft
by Jerry Mullins
(Menominee, Michigan USA)
If a US Type Certificated Aircraft is exported to Japan but not type certificated in Japan, therefore following section 3.2 of AC 21-2J, does an exception need to be entered in the exception block of the 8130-4 (Export Certificate of Airworthiness) stating the model aircraft is not Type Certificated in Japan. Ref: section 184.108.40.206 of Bilateral Agreement?
Note: Not all countries require the aircraft to meet their own approved type design. Many countries only require the aircraft to meet the type design of the country of manufacture (i.e., FAA or EASA Type Design).
ANSWER: The Japan authorities do require the aircraft to meet their own approved type design. So, if it is not approved, it is an exception to the special import requirements of Japan.
Before the export certificate of airworthiness could be issued, the Japan authorities would have to issue an acceptance letter. The JCAB may choose to review and approve the type design rather than issuing an accetance letter.
Having said that, if the JCAB did issue a letter validating the export with that exception listed then Yes it could be listed as an exception.
If that were the case, I would show a statement such as the one below:
“This U.S. type certificated aircraft is a first of type in Japan. Therefore, it does not currently comply with the special import requirements. The type design will have to be reviewed and approved by the JCAB prior to their airworthiness certification. Reference the JCAB validation letter dated April 17, 2010.”
AC 21.2J is general in nature, and may not include specific details of a foreign country's import procedures.
I would recommend that you or the foreign purchaser of the aircraft query the JCAB to see what their current procedures are regarding import of first of type aircraft and the issuance of airworthiness certificates.
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