As quality maintainance has emerged to a key issue in the manufacturing & procurement of materials and products over the years, various certificates are used which are issued by various entities (such as manufacturers or regulatory bodies) and demanded by the buyers as part of their orders. Although this article, by no means, intends to be an exhaustive presentation of all certificates and other documents supporting quality of supplied materials & products, it can be helpful in understanding the serving purpose and differences of some frequently demanded certificates related to aerospace, military and industrial componenets and parts.
Certificate of Compliance and Certificate of Conformance
Although these two certificates are termed similarly and sometimes their terms are used interchangeably, they serve distinct purposes, issued by different bodies, and carry different implications. The first (Certificate of Compliance, abbreviated as CoC), is a regulatory compliance document, typically issued by a regulatory authority or authorized third party, and focuses on regulatory compliance, verifying that a product meets legal or industry-specific requirements. It attests that the product complies with applicable laws, regulations, or industry standards, ensuring safety, quality, and environmental sustainability. The second (Certificate of Conformance, abbreviated as CoCf)) is a declaration issued by a manufacturer confirming that a product has been produced in accordance with specified requirements and standards. It serves a quality assurance purpose, namely as evidence of the adherence of a material or product to agreed-upon specifications, quality standards, and contractual obligations. When a statement such as "OEM CoC is required" in a RFQ or tender document, it actually refers to a Certificate of Conformance of their manufacurer that has to be supplied with demanded parts.
However, both certificates have vital roles in the manufacturing ecosystem, demonstrating compliance of respective materials & products with standards and regulations, and enhance their competitiveness and access in the global marketplace. Although these two certificates are common certification requirements for practically every industry, some notable examples are provided below.
Aerospace & Defence. CoC and CoCf verify adherence to specifications, ensuring reliability and safety in critical applications. Other airworthiness cetificates like the US FAA 8130-3 and European EASA Form 1 (whenever applicable) are also used (see below).
Oil and Gas. The hazardous nature of operations in the oil and gas industry require compliance with safety and environmental standards. CoC and CoCf provide evidence of adherence to applicable standards & regulations.
Food and Beverage & Medical Devices and Pharmaceuticals. CoC and CoCf are used as assurance that materials and products meet regulatory requirements set by regulatory bodies such as the U.S. FDA (Food and Drug Administration) and respective organisations in different countries around the world.
Construction and Building Materials: Manufacturers of construction materials and equipment often need certificates to demonstrate compliance with building codes and standards for safety and performance.
Airworthiness Certificates
Two of the most common airworthiness certificates (the US FAA 8130-3 and the European EASA Form 1) issued for aviation products and parts are briefly discussed below responding to frequently asked questions from their prospective buyers regarding their installation on aircraft.
It is important to clarify from the begining that both FAA 8130-3 Form and EASA Form 1 are airworthiness approval forms for products and parts and their issue does not automatically imply the approval of respective products/parts for their installation on a particular aircraft. Furthermore, in most cases, their issue bears an additional cost and customers should understand whether they need these forms or not.
In addition, NOT ALL OF OUR OFFERED PRODUCTS or PARTS are eligible for the issue of such a certificate. Typical examples of eligible items include OEM products/parts, those with a FAA Technical Standard Order (TSO) approval or the approval of the European equivalent (EASA European Technical Standard Order (ETSO) or a FAA Parts Manufacturer Approval (PMA). For these products/parts, a FAA 8130-3 or EASA Form 1 is issued NOT ONLY in the case of their initial procurement but also whenever an export, maintenance, repair and overhaul (MRO) process is involved.
Following an agreement between EASA and the FAA, from the 2nd March 2016, each organisation now mutually recognises TSO/ETSO approvals for certain aircraft products. In Europe there is no longer a requirement for a manufacturer to separately approve a product/part that holds a FAA TSO. This can be installed and used as if it has the corresponding EASA approval. A typical example of such products is VHF radio communications equipment. Further details on the scheme are on the EASA website.
Furthermore, even in the case of an eligible product/part for which a certificate can be issued, this is NOT REQUIRED FOR ALL APPLICATIONS/USES. Indicatively, aircraft such as ultra lights, experimentals or others in which such products/parts can be installed without a FAA/EASA certificate. ΟΕΜ Certificate of Conformance issued by the manufacturer is in most cases sufficient. In other cases, when intended installations relate to light piston engine aircraft, business jets, airliners, or other certified aircraft, the issue of a certificate is mandatory.
When a FAA 8130-3 Form or an EASA Form 1 is required, this must be requested at the time of the order placement. It CANNOT BE ISSUED during our order processing or AFTER the delivery of ordered items. These forms must be requested to the respective manufacturer/service facility before a product/part leaves their quality control system. They cannot be issued afterwards.The END USER and INTENDED APPLICATION details MUST be available at the time of request for the issue of the certificate.
Upon receipt of such a request from a customer, we inform the customer of any additional cost (as required) and pass such information to our co-operating suppliers for required actions. After the issue of the certificate we check the correctness of the contained information. In ceratin cases a certificate can be re-issued for the following reasons:
Loss: If the end-user loses the certificate, a request for a new copy can be placed.
Correction: If the end-user receives a form with an error, a request for a corrected copy can be placed. The request must be in writing and must identify the errors on the original form.
In both cases, the form originators honor such requests but a handling fee may be applied.
In our brief presentation below we try to provide an overview of FAA 8130-3 Form and EASA Form 1 for a better understanding of their purpose or use.
FAA 8130 Form / EASA Form 1 Certification
As stated above, both are airworthiness approval forms. For a smooth operation of global aviation system and maintainance of essential standards, the EU and U.S. have reached a bilateral agreement. Under this agreement, products/parts that are exported or imported to either country must have a dual release form for domestic and international use provided that the product/part in question is assessed and approved under both regulations. This applies to both FAA Form 8130-3 and the EU equivalent, the European Union Aviation Safety Agency (EASA) Form 1.
The EASA Form 1 serves the same functions as the 8130 form, acting as the EU’s airworthiness approval form. EASA Form 1 is often considered as the analog of FAA 8130-3 Form in an attempt for harmonization/homogenization of regulations at both sides of the Atlantic.To use the FAA 8130-3 Form for dual release, the form must be marked appropriately and contain a statement regarding its utility as a dual release. This is required in the following circumstances:
Exporting aircraft products/parts for use in the EU
Sending a product/part to an EASA repair station within the U.S.
Returning a product/part to service for use in an EU-registered aircraft
To receive a dual release form, it must be specifically requested from an approved issuer. For the past few decades, the standard has been to complete all 8130 forms as dual releases. However, all FAA Part 145 Repair Stations are now required to default to single release forms unless the end user provides written request for a dual release.
Under the FAA Code of Federal Regulations (CFR), the 8130-3 form is required as an airworthiness certificate, certifying that an aircraft product/part is in good enough condition to operate safely within the U.S. and its global partners. Within this scope, this form serves two primary purposes:
- to approve or certify that new and used products/parts meet conformity requirements for airworthiness.
- to approve or certify that products/parts may return to service following maintenance.
The form itself is utilized differently for these two purposes, so it is essential to understand these uses.
The FAA 8130 Form refers to the following product classes:
Class I product: A Class I product is defined as a complete aircraft, aircraft engine or propeller. To meet Class I requirements, the product type must be certified under applicable FAA or international civil aviation authority regulations.
Class II product: A Class II product is defined as a major component of a Class I product that, if it were to fail, would jeopardize the safety of the Class I product. This includes wings, landing gears, power transmissions, controls and other critical systems.
Class III product: A Class III product is any part that is not a Class I or Class II product. This includes all standard parts for aircraft and safety and survival equipment like fire safety and oxygen systems.
Newly overhauled: “Newly overhauled” is a term used to describe a product that has not been operated since it was overhauled and approved for return to service, with the exception of applicable functional testing during the inspection process.
Originally, the FAA 8130 form was only used for exporting Class II and III new and newly overhauled products. However, the form properly modified in the 1990s can also accommodate return to service purposes.
FAA 8130 Certificate Intended & Non Intended Uses
An FAA 8130-3 Form is used for the following purposes:
New products: The form may be used as a statement from the FAA that a new Class I or Class II product conforms to its design and is safe for operation.
Newly overhauled parts: The form may be used as a certification that a newly overhauled product is approved for return to service.
International use: The form may be used when exporting a new or newly overhauled product or shipping a prototype to another country that has a bilateral agreement with the United States.
Across these purposes, the form is used to improve the identification and traceability of aviation products across the global system.
An FAA 8130-3 Form CANNOT BE USED for certain functions like the following:
Administrative purposes: The FAA Form 8130-3 should not be used for administrative purposes between two parties, including as a delivery or shipping document.
Aircraft release: The FAA Form 8130-3 is only applicable to aircraft parts and should not be used as an aircraft release form.
Installation approval: The 8130 form only serves as a confirmation of a part’s airworthiness — it does not function as an approval to install a product or part on a particular aircraft.
In addtion, proper filling of the form is essential. For example, while the form can be used for multiple products, it cannot be used to approve a mixture of production- and maintenance-released products.
Issue of FAA 8130 Form
The form cannot be issued by organizations other than those authorized by the FAA to do so. The following entities may issue an 8130 form:
ASI: An FAA Aviation Safety Inspector (ASI) can sign an 8130 form as a Certificate of Airworthiness or Conformity Certification.
DMIR: A DMIR is a Designated Manufacturing Inspection Representative and is allowed to issue FAA 8130 forms for domestic or export parts.
DAR-F: Designated Airworthiness Representatives for Manufacturing (DAR-Fs) may issue the form for domestic shipments.
ODA: Some organizations may have an Organization Designation Authorization (ODA) unit, which can issue the form for products the organization produces. The ODA unit must inspect the product after the it has gone through the producer’s quality assurance program, at which point the ODA unit determines the product’s compliance with CFR requirements.
Air carrier: Appropriately certified air agencies and air carriers with approved airworthiness maintenance programs can issue the 8130 certificates for approval to return to service.
PAH: A Production Approval Holder (PAH) can issue the form for approval to return to service for domestic products, though this purpose is optional.