GM 21.A.265(h) Designation of data and information issued under the authority of a design organisation approval (DOA) holder

• ED Decision 2021/007/R found in: Initial Airworthiness and Environmental Protection (748/2012) Part-21 Part-21L (Jul 2024)
• ED Decision 2025/016/R found in: Initial Airworthiness and Environmental Protection (748/2012) (Nov 2025)

GM 21.A.265(h) Designation of data and information issued under the authority of a design organisation approval (DOA) holder ED Decision 2021/007/R 1.       INTENT This GM provides guidance for complying with the obligation of [21.A.265](#_DxCrossRefBm1649096943)(h), and addresses the various aspects that the DOA holder should cover in order to have a comprehensive procedure for the designation of data and information. 2.       SCOPE The term ‘data and information’ as used in point [21.A.265](#_DxCrossRefBm1649096943)(h) also includes instructions. Data and information referred to in point [21.A.265](#_DxCrossRefBm1649096943)(h) are issued by a DOA holder and cover the following: — embodiment instructions for design changes or repairs (usually in the form of a service bulletin, a modification bulletin, repair instructions or engineering order, etc.); — manuals required by Part 21 or the applicable CSs (such as the aircraft flight manual (AFM), rotorcraft flight manual, instructions for continuing airworthiness (ICAs), etc.); — operation suitability data (OSD); — continued-airworthiness instructions (usually in the form of service bulletins) which may be covered by airworthiness directives (ADs); — additional data to be defined by the DOA holder (e.g. alternative maintenance instructions that are not, per se, ICAs). Note: This data and information may be issued in a digital or paper format. The obligation does not apply to, and the statement provided with the data and information should not be used on, the following documents: — certification documents (e.g. the certification programme, compliance checklist, etc.); — compliance documents; — design data transferred to production organisations; and — production deviations (also referred to as ‘unintended deviations’ or ‘concessions’). 3.       RATIONALE The purpose of this obligation is to give certainty to the end users about the approval status of the data and information issued by the DOA holder. 4.       PROCEDURE For the information and instructions issued under point [21.A.265](#_DxCrossRefBm1649096943)(h), the DOA holder should establish a procedure that addresses the following aspects: — their preparation; — verification of their technical consistency with the corresponding approved change(s), repair(s) or approved data, including their effectivity, description, effects on airworthiness and environmental protection, especially when limitations are changed; — verification of their feasibility in practical applications, when relevant and feasible; — the authorised signatories. The procedure should include the information or the instructions prepared by suppliers, and declared applicable to its products by the DOA holder. 5.       STATEMENT The statement provided with the data and information should also cover those items prepared by subcontractors or vendors that the DOA holder has declared as applicable to their products. The technical content of the statement is related to the type certificate data and information. The approval included in the statement means that: — the type certificate data has been appropriately approved; and — the information contains practical and well-defined installation or inspection methods, and, when those methods are implemented, the product is in conformity with the approved type certificate data. Note: Data and information related to the measures required by point [21.A.3B](#_DxCrossRefBm1649096905)(b) (airworthiness directives (ADs)) are submitted to EASA to ensure their compatibility with the content of an AD (see point [21.A.265](#_DxCrossRefBm1649096943)(e)), and contain a statement that they are, or will be, subject to an AD issued by EASA. ##### GM 21.A.265(h) Designation of data and information issued under the authority of a design organisation approval (DOA) holder *ED Decision 2025/016/R* 1. INTENT This GM provides guidance for complying with the obligation of [21.A.265](#_DxCrossRefBm485230434)(h), and addresses the various aspects that the DOA holder should cover in order to have a comprehensive procedure for the designation of data and information. 2. SCOPE The term ‘data and information’ as used in point [21.A.265](#_DxCrossRefBm485230434)(h) also includes instructions. Data and information referred to in point [21.A.265](#_DxCrossRefBm485230434)(h) are issued by a DOA holder and cover the following: — embodiment instructions for design changes or repairs (usually in the form of a service bulletin, a modification bulletin, repair instructions or engineering order, etc.); — manuals required by Part 21 or the applicable CSs (such as the aircraft flight manual (AFM), rotorcraft flight manual, instructions for continuing airworthiness (ICAs), etc.); — operation suitability data (OSD); — continued-airworthiness instructions (usually in the form of service bulletins) which may be covered by airworthiness directives (ADs); — additional data to be defined by the DOA holder (e.g. alternative maintenance instructions that are not, per se, ICAs). Note: This data and information may be issued in a digital or paper format. The obligation does not apply to, and the statement provided with the data and information should not be used on, the following documents: — certification documents (e.g. the certification programme, compliance checklist, etc.); — compliance documents; — design data transferred to production organisations; and — production deviations (also referred to as ‘unintended deviations’ or ‘concessions’). 3. RATIONALE The purpose of this obligation is to give certainty to the end users about the approval status of the data and information issued by the DOA holder. 4. PROCEDURE For the information and instructions issued under point [21.A.265](#_DxCrossRefBm485230434)(h), the DOA holder should establish a procedure that addresses the following aspects: — their preparation; — verification of their technical consistency with the corresponding approved change(s), repair(s) or approved data, including their effectivity, description, effects on airworthiness and environmental compatibility, especially when limitations are changed; — verification of their feasibility in practical applications, when relevant and feasible; — the authorised signatories. The procedure should include the information or the instructions prepared by suppliers, and declared applicable to its products by the DOA holder. 5. STATEMENT The statement provided with the data and information should also cover those items prepared by subcontractors or vendors that the DOA holder has declared as applicable to their products. The technical content of the statement is related to the type certificate data and information. The approval included in the statement means that: — the type certificate data has been appropriately approved; and — the information contains practical and well-defined installation or inspection methods, and, when those methods are implemented, the product is in conformity with the approved type certificate data. Note: Data and information related to the measures required by point [21.A.3B](#_DxCrossRefBm485230396)(b) (airworthiness directives (ADs)) are submitted to EASA to ensure their compatibility with the content of an AD (see point [21.A.265](#_DxCrossRefBm485230434)(e)), and contain a statement that they are, or will be, subject to an AD issued by EASA.