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	Balloons and dirigibles; gliders, hang gliders and other non-powered aircraft	Balloons, gliders, hang gliders
8802.11–8802.40	Helicopters and aeroplanes (unmanned aircraft: heading 8806)	Complete aircraft
8807.10	Propellers and rotors, and parts thereof	Propeller blades, rotor hubs
8807.20	Undercarriages and parts thereof	Landing gear assemblies, shock absorbers, aircraft wheels
8807.30	Other parts of aeroplanes, helicopters or unmanned aircraft	Engine nacelles, flaps, tailplanes
8807.90	Other parts	Other parts of goods of heading 8801, 8802 or 8806 not covered above
8411	Turbojets, turbopropellers and other gas turbines	Aircraft turbine engines — Chapter 84, not Chapter 88

Practical note: Aircraft engines are classified by engine type in Chapter 84 — turbojets and turbopropellers under 8411, aircraft piston engines under 8407.10 — whether they are new or supplied as spares. Under Note 2 to Section XVII, engines, seals and gaskets, electrical equipment of Chapter 85 (e.g. connectors, avionics) and instruments of Chapter 90 are not "parts" of heading 8807 and are classified under their own headings; parts of turbojets or turbopropellers go under 8411.91. 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	YES for new parts, appliances, engines and propellers (TCA); for other releases check the EASA requirements
Maintenance organisation approval	UK CAA Part-145	EASA Part-145	Not addressed by the TCA provisions on design and production acceptance — check the EASA requirements
Type certificate	UK TC (Type Certificate)	EASA TC	Partially (TCA) — certificates valid on 31.12.2020 accepted; new CAA certificates subject to EASA validation
Production organisation approval	UK CAA POA	EASA POA	YES for product categories approved for production on 31.12.2020 (TCA)

Practical consequence: Under the EU–UK Trade and Cooperation Agreement, a UK CAA Form 1 is recognised for the export of new parts, appliances, engines and propellers to the EU. The CAA guidance refers to new products; for used or overhauled parts and releases after maintenance or repair, check the EASA requirements that apply to the installing organisation.

EU–UK aviation safety recognition — TCA and TIP

Aviation safety recognition between the EU and the UK is set out in the EU–UK Trade and Cooperation Agreement (Article AIRTRN.18 and Annex AVSAF-1), implemented by the Technical Implementation Procedures (TIP) signed by the UK CAA and EASA on 17 May 2021.

What the TCA covers: - Type certificates, supplemental type certificates, approvals for changes and repairs and ETSO authorisations valid on 31 December 2020 are accepted - Minor changes and minor repairs approved by the CAA are accepted by EASA; new CAA type certificates and major changes are subject to EASA technical validation - The EU recognises production approvals issued by the CAA for product categories approved for production on 31 December 2020 - A CAA Form 1 is recognised for the export of new parts, appliances, engines and propellers (CAA Form 52 for new complete aircraft)

Practice: According to the UK CAA, UK-based organisations do not need an EASA third-country production approval, and EASA has not issued any such approvals to UK organisations. For used parts and releases after maintenance, check the EASA requirements with the receiving MRO or operator.

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. The approval number of the issuing organisation shown on the Form 1 must be current with the authority that granted it (EASA or the competent authority of an EU Member State) 2. Part-specific limits — shelf life, life limits and remarks in Block 12 — determine whether the part can still be used; the form itself has no general expiry period

UK CAA Form 1: check that the issuing organisation's UK CAA approval is current with the UK CAA.

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, UK CAA Form 1 (new parts, under the TCA) 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 8807 — 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 a release certificate accepted under EU rules (EASA Form 1, or a UK CAA Form 1 for new parts under the TCA)

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).