ED Decision 2025/016/R
ORGANISATIONS THAT DESIGN MINOR CHANGES TO A TYPE CERTIFICATE (TC) OR A SUPPLEMENTAL TYPE CERTIFICATE (STC), AND MINOR REPAIRS TO PRODUCTS: CLASSIFICATION PROCEDURE
1. Content
The procedure should address the following points:
— the configuration control rules, especially the identification of changes to a TC, APU ETSO or to that part of the product covered by an STC, and repair designs;
— the classification in compliance with point 21.A.91 and considering GM 21.A.91 for changes and GM 21.A.435(a) for repairs;
— the justification of the decisions for the classification; and
— the acceptance of the classification by authorised signatories.
2. Identification of changes to a TC, APU ETSO or to that part of the product covered by an STC, and repair designs
The procedure should indicate how the following are identified:
— the items (consisting of areas, systems, parts, or appliances) to be affected by the change or repair as per the definitions provided in paragraph 3.9 of GM 21.A.101; these include the parts, appliances, systems or areas affected, and also the other TC constituents (see definitions in GM to 21.A.90A; for instance, operating limitations, OSD constituents, manuals, etc.);
— airworthiness directives which have, or might have, an impact on any of the identified items affected by the change or repair;
— the existing type-certification basis of the affected items containing, as applicable, the certification specifications, special conditions, deviations from the applicable certification specifications and the equivalent level of safety findings incorporated by reference in the TC of the product to be changed;
— the existing OSD certification basis;
— the definition of the change or repair to the affected items in accordance with the provisions of point 21.A.31;
—
the certification basis of the change or repair determined in
accordance with point 21.A.101
with the support of GM
21.A.101 (point 21.A.433 for repairs); this might lead
to preclassification of the change as ‘major significant’ as per
the associated definitions
(see paragraph 3 below).
3. Classification
The procedure should show how the effects on airworthiness, operational suitability and environmental compatibility are analysed, from the very beginning, by reference to the specific requirements applicable to the affected items.
If no specific CSs or environmental protection requirements are applicable to the affected items, the above review should be carried out at the level of the part or system where the affected items are integrated and where specific CSs or environmental protection requirements are applicable.
For repairs, the criteria used for the classification should be in compliance with point 21.A.435 and follow the guidelines provided in GM 21.A.435(a).
The procedure should define provisions to contact EASA in case of doubts regarding the classification.
4. Justification of the classification
All decisions on the classification of changes to a TC, APU ETSO or to that part of the product covered by an STC, and repair designs classified as ‘minor’, should be recorded, and, for those which are not straightforward, also justified according to the procedure and the criteria defined in paragraph 3 above.
These records should be easily accessible to EASA for sample checking.
The justification may be in the format of meeting notes or a register.
5. Acceptance of the classification by the authorised signatories
All classifications of changes to a TC, APU ETSO or to that part of the product covered by an STC, and repair designs should be accepted by an appropriately authorised signatory.
The procedure should indicate the authorised signatories for the various products listed in the terms of approval.
The final classification may be:
— minor changes to a TC or minor repairs where additional work is necessary for the demonstration of compliance with the certification basis, the operational suitability data certification basis (where applicable), and the environmental protection requirements; or
— minor changes to a TC or minor repairs that require no further demonstration of compliance.
AMC2 21.A.263(c)(1) outlines the classification procedure for minor changes to TCs/STCs and minor repairs, covering configuration control, classification criteria, justification, and authorised signatory acceptance.
* Summary by Aviation.Bot - Always consult the original document for the most accurate information.
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