Importing aviation parts and aerospace components from the UK – EASA, certificates and compliance

Importing aviation and aerospace components from the United Kingdom to Poland is one of the most complex and tightly regulated areas of international trade. The British aerospace industry — centred on companies such as Rolls-Royce, BAE Systems, GKN Aerospace and Meggitt — generates component exports to Europe worth more than USD 121 million per year (HS 88). Since Brexit, the regulatory relationship between UK CAA (Civil Aviation Authority) and EASA (European Union Aviation Safety Agency) has changed fundamentally — certificates issued by one authority are no longer automatically recognised by the other. For Polish importers, MRO organisations (Maintenance, Repair and Overhaul) and aviation operators, this means that the documentation for every imported part must be carefully checked before a customs declaration is submitted. This article explains what changed after Brexit, how to correctly classify aerospace components under the customs tariff, which certificates are required, and how customs clearance for UK aerospace parts works in practice.

Tariff classification of aerospace components – HS Chapter 88

Chapter 88 of the Combined Nomenclature (CN) covers aircraft, spacecraft and their parts. Correct classification is critical — a wrong code can result in an incorrect duty rate or problems with dual-use controls.

HS Code	Description	Examples
8801	Gliders, hang gliders and other non-powered aircraft	Gliders, hang gliders, paragliders
8802.11–8802.40	Helicopters, aeroplanes, unmanned aerial vehicles	Complete aircraft
8803.10	Propellers and rotors, and parts thereof	Propeller blades, rotor hubs
8803.20	Undercarriages and parts thereof	Landing gear assemblies, shock absorbers, aircraft wheels
8803.30	Other parts of aeroplanes or helicopters	Engine nacelles, flaps, tailplanes, avionics
8803.90	Other parts	Minor components, aviation seals, connectors
8411	Turbojet and turbopropeller engines	Turbojet and turboshaft engines — separate classification!

Practical note: Aircraft engines may be classified under 8411 (turbojets) or 8803 (aircraft parts) depending on the context of delivery. If an engine is imported as a spare part for a specific aircraft it is generally 8803.30. If imported as a new engine for installation during manufacture it is 8411. It is advisable to obtain written classification confirmation from a customs broker before importing.

Brexit and aviation certification — UK CAA vs EASA

This is the most important area of change for importers of aviation parts from the UK since Brexit.

Before Brexit (up to 31.12.2020): The United Kingdom was part of the EASA system. Certificates issued by UK CAA were de facto EASA certificates — mutually recognised throughout the EU with no additional formalities.

After Brexit (from 1.01.2021): UK CAA became an independent aviation regulator. EASA and UK CAA are now two separate authorities with their own certification systems:

Document	UK system	EU/EASA system	Mutual recognition?
Airworthiness certificate	UK CAA Form 1	EASA Form 1	NO (automatically)
Maintenance organisation approval	UK CAA Part-145	EASA Part-145	NO (automatically)
Type certificate	UK TC (Type Certificate)	EASA TC	Partially — via BASA
Production organisation approval	UK CAA POA	EASA POA	NO (automatically)

Practical consequence: An aviation part manufactured and certified in the UK with a UK CAA Form 1 cannot be directly installed on an aircraft operating in the EU under EASA oversight — unless a relevant bilateral agreement exists or the part has undergone a certification conversion procedure.

BASA — Bilateral Airworthiness Safety Agreement UK–EU

The BASA (Bilateral Airworthiness Safety Agreement) between the EU and the UK has been concluded, but its scope is limited and differs from the US–EU agreements (BASA FAA–EASA).

What the UK–EU BASA covers: - Mutual recognition of type certificates (Type Certificates) for new designs — with reservations - Certain simplified procedures for large OEM (Original Equipment Manufacturer) producers

What the UK–EU BASA does NOT cover: - Automatic recognition of a UK CAA Form 1 as equivalent to an EASA Form 1 for spare parts - Full mutual recognition of maintenance organisation approvals (Part-145)

Market practice in 2026: Most MRO organisations in the EU importing parts from the UK require that the supplier holds an EASA Part-21G (Production Organisation Approval) or that the part carries an EASA Form 1 issued by an EASA-approved organisation. Many UK manufacturers obtained such approvals after Brexit specifically to maintain exports to the EU.

EASA Form 1 vs UK CAA Form 1 — how to verify a certificate

EASA Form 1 (Authorised Release Certificate) is a document confirming that an aviation part: - Originates from an approved production or maintenance source - Is fit for installation on an aircraft registered in the EU - Meets EASA regulatory requirements

How to verify validity: 1. EASA SRIS (Safety Regulatory Information System) — database of EASA organisation approvals: https://www.easa.europa.eu/en/acceptable-means-compliance-and-guidance-material-group/part-145-maintenance-organisation-approvals 2. The approval number on the Form 1 must be active in the EASA database 3. The issue date of the Form 1 — validity is limited (typically 12 months from the date of issue for storage purposes)

UK CAA Form 1 can be verified in the CAA SRIS (UK) database: it contains a list of UK CAA Part-145 and Part-21 approvals.

8130-3 (FAA Release Certificate): This applies to parts manufactured in the USA and imported via the UK to the EU. Aerospace supply chains frequently include US-origin components carrying an FAA 8130-3 certificate — for use in the EU, conversion to an EASA Form 1 is required.

Customs clearance documents for aviation parts

A complete document set for aerospace imports from the UK:

Mandatory: - Commercial invoice with HS code, value and technical description of the part (Part Number, Serial Number) - Transport documents (CMR, AWB for air freight, B/L for sea freight) - UK origin declaration (for 0% TCA rate)

Conformity and airworthiness certificates: - EASA Form 1 or equivalent document (FAA 8130-3 with conversion) - Certificate of Conformance (CoC) from the OEM manufacturer - Traceability Documentation — part origin, repair and overhaul history

Documents for dual-use goods: - Some aerospace components (e.g. avionics, navigation systems, engines) may be subject to export controls as dual-use goods. In the UK — Export Control Order 2008. The exporter should attach a statement confirming that no export licence is required, or a copy of the licence.

Duty rates and TCA for aviation components

Category	MFN rate	TCA rate (UK origin)
HS 8803 — aircraft parts	0%	0%
HS 8411 — turbojet engines	0%	0%
HS 8801 — gliders	0%	0%

Good news for aerospace importers: most aviation components carry a zero MFN (Most Favoured Nation) duty rate — irrespective of TCA. Customs duty is generally not a problem. The challenges lie in certification and export control, not in duty rates.

Import VAT (23%) is payable, but VAT-registered businesses may reclaim it.

Who can import aviation parts — approved organisations

Unlike many other goods, aviation parts have restricted import channels for aviation safety reasons:

• EASA Part-145 MRO — maintenance organisations holding an EASA approval may import and install EASA-compliant parts
• EASA Part-21G POA — production organisations may import components for their own manufacturing
• Aviation operators — may import spare parts, but must use approved suppliers and have an approved continuing airworthiness management system (CAMO)
• Distributors — may trade in parts, but for installation on EU-registered aircraft must supply an EASA Form 1

Note: A private individual may technically complete customs clearance for an aviation part — but installing that part on an aircraft without the appropriate EASA documentation is unlawful and compromises flight safety.

Dual-use — export controls on aerospace components

Some aerospace components are subject to dual-use regulations (civilian-military dual application). In the EU — Regulation 2021/821. In the UK — Export Control Order 2008.

Categories requiring particular attention: - Inertial Measurement Units (IMU) — ML and dual-use category - Turbojet engines with thrust >44 kN — export control - Avionic software for military purposes - Unmanned aerial vehicle systems (UAV/UAS) — increasing regulation

When importing from the UK, customs may ask about dual-use classification. If the goods are on control lists, a UK export licence from the Department for Business and Trade is required, and an import licence in Poland may also be needed (from MSWiA or MON, depending on category).