UK leaving EU and EASA

The EU-exit transition period ends with effect from 11pm on the 31 Dec 20. The UK is no longer a part of the EU but has retained EU regulations including aviation regulations which continue to apply under UK law from 1 Jan 21. The UK and EU have adopted a ‘Trade and Co-operation agreement‘.

This webpage highlights changes relevant to gliding and will be updated as the facts become available.

*Updated 18 Jan to include Home Office/HMRC interpretation of travelling to the EU with a sailplane, and VAT on imports to the UK.*

General

The UK is retaining EU regulation that is in force prior to 1st Jan 21. Therefore the EASA Sailplane Flight Crew Licensing, Medical, Training, Operations, Airworthiness and Maintenance rules will apply in the UK and on the timescale as previously planned and notified.

From 1st Jan 2021, retained EASA rules are described as UK rules, eg ‘UK-SFCL’, and EASA aircraft are described under those UK rules as ‘Part-21 aircraft’. In due course, the UK versions of these rules will be published by the UK CAA.

Pilot Licensing & medical

A UK issued SPL is ICAO compliant where a class 2 medical certificate is held.

LAPL medical certificates issued in the UK may not be recognised in EU countries after 1st Jan 2021.

The UK CAA intends to introduce a UK-only medical self-certification process for SPL holders – the Pilot Medical Declaration (PMD) – during January 2021.

Airworthiness & maintenance

A UK issued C of A and ARC is ICAO compliant.

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.

Acceptance of the EASA Form 1 by the CAA

To minimise disruption to the UK Industry, the UK CAA has agreed to allow new or used aircraft components, released to service using an EASA Form 1, to be installed on UK aircraft. This therefore satisfies the requirements of Regulation (EU) 1321/2014, Annex I (Part M), Annex II (Part 145)  and Annex Vb (PART ML) . The related ORS4 General Exemptions can be viewed here ORS4 No.1451 and 1452.

EASA Permit to Fly

The CAA has published a temporary exemption relating to EASA Permits to Fly

Tranferring aircraft in and out of the UK

The exporting Party’s forms are:

(a) when the exporting Party is the United Kingdom, CAA Form 52 for new aircraft, export certificate of airworthiness for used aircraft, and CAA Form 1 for other new products; and

(b) when the exporting Party is the Union, EASA Form 52 for new aircraft, export certificate of airworthiness for used aircraft, and EASA Form 1 for other new products.

Travelling to the EU by car

Additional requirements may apply in respect of insurance for trailers and health insurance. Please check the Gov.uk website.

Temporary UK-export of a sailplane, eg for a gliding holiday or competition

The content of a trailer, eg a sailplane, is likely to need an ATA Carnet and bond. The Gov.uk website provides guidance. The BGA is currently engaged with Govt agencies on this issue and will report details as and when they become available.

The BGA has secured an arrangement with the Greater Birmingham Chambers of Commerce (GBCC) for BGA club members of an ATA Carnet fixed price processing/arrangement fee of £240+VAT. This is discounted from the standard fee of £330+VAT. For details on applying for an ATA Carnet via the GBCC, please see here.

VAT on UK-imported used aircraft

A used/secondhand aircraft being imported into the UK from the EU by someone who did not own it before the 1st January 2021 is subject to UK VAT. The Gov.uk website provides guidance. The BGA is currently engaged with Govt agencies on this issue and will report details as and when they become available.

Other links

CAA EU/EASA exit microsite

CAA EU/EASA-exit webinars on a range of aviation topics including GA

CAA Official Record Series exemptions

Gov.uk website