3 Major Obstacles to Switching Jurisdictions

3 Major Obstacles to Switching Jurisdictions

If you live in a European country and are buying an aircraft from the United States (or vice versa), you will have to register the aircraft in the country where you live or where your AOC is located.
Moving an aircraft between different jurisdictions, such as FAA in the USA to EASA in Europe, can get very complicated because each jurisdiction has different rules. Some countries have adopted the United States’ FAA standards, but the European aviation authority, EASA, has kept its own certifications very separate. Before an aircraft can be registered in a country, it must meet the standards of that country to be allowed in. Below are a few items that will need to be investigated and addressed in an international import or export.

 

Manufacturer Conversion Processes
Manufacturers will often make you go through a conversion process if you are bringing an aircraft from one jurisdiction to another. Some of these bulletins can take very little time to implement and minimal costs, while other types have no costs involved and no modifications to be made. However, certain models have a very lengthy and expensive process they must go through. For example, the Embraer Legacy 600 and 650 have to go through a conversion bulletin before they can switch jurisdictions that takes 90-180 days to write, another 10 plus days to implement and around 200,000-250,000 dollars. Speak to your broker about this as it is worth knowing at the beginning of your aircraft search how you could be affected by this.

Avionics
EASA has certain requirements for aircraft with over 12,500 lbs max take-off weight. This is basically any mid-size jet and larger (Citation Excel series, Lear 45, Hawker 800 and 900 series). A flight data recorder and TCAS II version 7.1 are two of the main requirements that EASA mandates for this size aircraft. These are not a requirement in the USA. If you live in Europe and are considering a USA based aircraft, you need to ensure that the avionics equipment meets your country’s requirements. TCAS II version 7.1 can be retrofitted without too much complication, although it is quite pricey. A flight data recorder however is much more complicated and requires a re-wiring of the whole aircraft to install sensors that record certain parameters of different components of the aircraft. This is a very expensive avionics addition and when purchasing a mid-size jet, installing a FDR is not economical.

STC’s
An STC, Supplemental Type Certificate, is a document issued on an aircraft after a modification has been made to it. FAA STCs are not always accepted by EASA. If you are considering buying an aircraft in America or where FAA standards are held, you must ensure that the aircraft’s STCs are also certified with EASA. Some modifications are done using non-STC documentation which is almost never accepted by EASA. Getting foreign STCs approved by EASA, or for EASA to approve foreign non-STC modifications, is very time consuming and costly.
Some manufacturers build their aircraft “green”, meaning without the interior, and will install the interior with STCs. The Bombardier Challenger series and the Gulfstream G200s are two examples of this. If the interior was installed for an American buyer with FAA STCs, a European buyer will have to ensure they have the right approvals to be able to bring the aircraft over and register it in their country. In general, the FAA will more readily accept most EASA work while EASA will most likely not automatically accept the work and will require a recertification.

 

As a buyer make sure your broker knows which registry you plan on enrolling your aircraft on once you’ve purchased it. This will ensure that you are looking at the most appropriate aircraft to meet your needs that will easily transfer over to your registry. While there may seem to be a large number of a certain type of jet for sale, only a few may be able to go onto your registry. This is definitely a key aspect when under EASA jurisdiction and with the majority of aircraft on the market being USA registered. As your broker researches specific aircraft, be aware that certain items may come up that pose problems such as STCs or an expensive conversion process. It may mean expanding your search to include different models than you had originally planned that can more easily and economically be yours.