Changes after EU and EASA exit
The UK is no longer a part of the EU. It is a ‘third country’ that has retained EU regulations including aviation regulations which continue to apply under UK law from 1 Jan 21.
This webpage highlights changes relevant to gliding and will be updated as facts become available.
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 now retained under UK law.
Part-SFCL is the Sailplane Flight Crew Licensing rules now retained under UK law.
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 (update June 2023)
Rules of travel into the EU has changed. From 2025, people from visa-exempt countries (including the UK) are required to have a European Travel Information and Authorisation System permission (known as an ETIAS) to enter most European countries. There is an application fee of 7 Euros.
The UK is implementing an equivalent system. From 2025, people from visa-exempt countries are required to have an Electronic Travel Authorisation (known as an ETA) to enter the UK. There is an application fee of £10.
Pilot licencing
The UK’s exit from the EU and EASA has changed Flight Crew Licensing requirements, particularly in relation to what licences need to be held in order to fly certain aircraft.
Non-UK licence holders flying in the UK
Visiting licence holders flying in the UK – please read this CAA information, which explains that for VFR recreational flying, an ICAO compliant licence is valid for recreational flying of any aircraft in UK airspace.
Flying outside the UK using a UK issued SPL
The UK SPL + Class 2 medical certificate is ICAO compliant. That means pilots holding a UK SPL + Class 2 medical certificate may fly UK registered gliders in the EU.
UK issued flight crew licence holders should be aware that since 1 January 2021, they have no privileges to operate aircraft on the register of an EASA Member State. EU regulation requires validation of a UK SPL to fly an EASA state registered sailplane in the EU.
Validation guidance based on experience:
France:
The French DGAC is responsible for issuing SPL validations. When a third country SPL holding pilot is flying a French/EU registered glider, an SPL validation is required. The French DGAC validation form is available here. The fee is 80 Euros. In that case, UK CAA advises that the DGAC will contact CAA to confirm that the UK issued SPL is valid etc. To enable UK CAA to release the information to the DGAC, the SPL holder will need to complete SRG1160. The DGAC turn around the initial application within 48 hours. The minimum turnaround time at CAA from receipt of the SRG1160 is 10 working days. The BGA recommends that pilots who need to validate their UK SPL give themselves a month to complete the process.
Germany:
The German federal state aviation authorities are responsible for issuing SPL validations. LBA recent advice to the BGA is that pilots should contact the aviation authority of the federal state in which they intend to operate. The contact addresses of the state aviation authorities can be found under the following link: https://www.lba.de/DE/Presse/Landesluftfahrtbehoerden/Landesluftfahrtbeh%C3%B6rden_node.html
Spain:
The validation of a UK SPL with the Spanish authority (AESA) requires a min. experience of 100 hours PIC and is valid for a maximum of 28 days within the calendar year. A Spanish gliding club can act as an intermediary. The steps are:
– Complete form F-DLA-VAL-05P
– Pay a fee (currently €190.33) to the AESA
– Provide copies of passport, Class 2 medical and logbook
Instructing in third countries
It is recommended that a UK issued SPL holder intending to instruct in a third country confirms that instructing is permitted with the licence and privileges held by the pilot.
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 BGA is working with the CAA to establish a compliant way forward that addresses an imminent shortage of certified parts that are maintained, repaired or overhauled by non-UK organisations, eg release hooks maintained by Tost. As an interim measure, the CAA has published a temporary exemption to approve components released on an EASA Form 1 to be installed in an ELA1 aircraft. Part 21 sailplanes are of course ELA1 aircraft.
It should be noted that this exemption only applies to maintained, repaired or overhauled components sourced from non-UK maintenance organisations. Newly manufactured components from non-UK production organisations are covered by the aviation safety section of the EU/UK Trade and Cooperation Agreement (TCA). EASA Form 1s issued by EU approved production organisations can be accepted and recognised in the UK on an ongoing basis and are therefore do not need to be covered by this general exemption.
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
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