Bridging UK-EU regulation differences
The UK is a ‘third country’ that has retained EU regulations including aviation regulations which continue to apply under UK law from 1 Jan 21. Those retained EU rules are changing; for example UK Part-SFCL.
This webpage highlights interactions between UK and EU as related to gliding..
Glossary
ANO is the Air Navigation Order.
EASA is the European Aviation Safety Agency.
ICAO is the International Civil Aviation Organisation.
Part-FCL is the Flight Crew Licensing rules.
Part-SFCL is the Sailplane Flight Crew Licensing rules.
Part-21 aeroplane – formerly known as an EASA aeroplane, eg a Robin DR400.
Part-21 sailplane – formerly known as an EASA sailplane, eg a Discus, DG400 (a self-launcher) or a Grob109b (a TMG).
Permission to travel
The EU has brought in new changes at the border, which will affect any UK travellers visiting countries in the European Schengen area. These changes, which are called the ‘entry-exit system’ (EES) will begin from 12 October 2025. The new checks will be introduced in all 29 Schengen countries, including popular holiday destinations Spain, France and Italy. This does not include Ireland or Cyprus.
EES will affect all non-EU passport holders, including those who hold British passports. But if you have an EU passport, the EES rules will not apply to you. From the end of 2026, the Etias visa waiver will also be launched, meaning the cost of entry to Europe will be €20 (£17).
Pilot licencing
Please refer to the BGA Pilot Licensing information.
Trailer licensing
All trailers (whether commercial use or non-commercial) of more than 750kg gross weight MUST be registered if travelling to Europe (except Ireland, Cyprus, Malta and Spain). DfT guidance is here.
Moving aircraft into and out of the UK
Temporarily moving a glider or other gliding equipment into the EU, eg for expeditions, competitions, etc. Where a privately owned glider is moved across the UK/EU border in a trailer towed by a private vehicle and the intent is to return the glider across the EU/UK border (for example visiting the EU for a holiday, competition, etc), the temporary export and subsequent re-import may be declared by conduct, where the act of crossing the border counts as your declaration. You do not need to fill out any forms.
There is a significant amount of experience of crossing the EU border from the UK using declaration by conduct, ie crossing and returning.
Eire customs has described the requirement for crossing from the UK into the EU with a glider towed by a car as an oral declaration accompanied by an inventory to support the oral declaration. The C108 form provides an inventory should that be required. Users should check if the port of arrival/departure allows for an oral declaration.
There is experience of a Spanish port, Santander, demanding a Carnet (which is for most prohibitively expensive). The Istanbul Convention (signed by the UK and EU countries inc Spain) Annex C, Chapter III Miscellaneous provisions, Article 5 and 6 identifies why a means of transport (a sailplane and a trailer) shall be granted with temporary admission without a customs document or security being required.
Temporarily moving a glider into the EU for repair
– The background
The UK-EU Trade and Co-operation Agreement (TCA) allows goods to temporarily move between GB and the EU for repair without incurring customs duty on import, regardless of their origin.
Outward Processing is a procedure that allows goods to be temporarily exported from the UK for repair or processing, and then re-imported to the UK without payment of UK customs duty or import VAT. Further info on Outward Processing and the conditions that need to be met for the relief can be found at:
https://www.gov.uk/guidance/using-outward-processing-to-process-or-repair-your-goods
https://www.gov.uk/guidance/apply-to-pay-less-duty-on-goods-you-export-to-process-or-repair
– Practical guidance
Practical guidance based on experience of refinishing a UK-based glider in the EU is available here.
VAT on used aircraft imported into the UK by a private owner. When purchasing goods in EU (for later import to GB) from a private user of the same goods, the EU seller is likely to have incurred irrecoverable VAT. For the later sale, no VAT would be due on a private sale in the EU, but (now we have left the single market) import VAT will be due on arrival to GB, subject to any import reliefs that may apply.
In a similar scenario but where the goods were bought from a VAT registered business in the EU, a purchaser intending to import those goods to GB would be advised to check if the seller is zero-rating the supply to them, as an export from the EU. Import VAT would be due in GB, on the same basis as described above.
Goods in free circulation in N Ireland at 31 December 2020 are classified as being in free circulation in EU and not in GB. Goods being moved from Ireland to GB are imports.
Maintenance or repair by organisations without a UK CAA approval
Following the UK’s exit from the EU and EASA, maintained, repaired or overhauled parts with EASA Form 1’s from maintenance companies that do not hold UK approvals are not approved for use on UK registered aircraft.
The UK CAA has decided to continue to allow maintained components released using an EASA Form 1 to be fitted on UK registered aircraft if that aircraft falls within the scope of Part ML, if the component has been maintained by its original manufacturer and if the component cannot be obtained from alternative acceptable sources. Examples include Tost release hooks.
The CAA exemption can be viewed here.
Continued acceptance of EASA references on aircraft documents
The CAA will continue to accept references, including EASA form numbers, to any EU regulation which are cited on documents carried by UK-registered aircraft. This includes Certificates of Airworthiness (CofA), Airworthiness Review Certificates (ARC) and Noise Certificates. These will remain valid until they are renewed, whereby they will be replaced with CAA references and form numbers.
Other links
CAA Official Record Series exemptions
– Back to Laws and Rules webpage