Compliance Countdown

U.S.: Hydrofluorocarbons

The U.S. Environmental Protection Agency has issued regulations restricting the use of certain hydrofluorocarbon sprays and their transportation in specific sectors or subsectors of industry, potentially including airframe manufacturing, aircraft maintenance, and air transportation. The new regulations also establish a process for submitting technology transition petitions and describe the recordkeeping and reporting requirements; Compliance dates for these restrictions vary depending on the subsector ranging from Jan. 1, 2025, to Jan. 1, 2028.

U.S.: Designating a U.S. Agent

The FAA will require individuals with foreign addresses and no U.S. physical address on file with the agency who hold or apply for certain certificates, ratings, or authorizations to designate a U.S. agent for service of related documents. The U.S. agent will receive FAA document service on the certificate holder or applicant's behalf. According to the agency, “This rule facilitates the FAA's ability to accomplish prompt and cost-effective process and service of other safety-critical or time-sensitive documents to individuals abroad through their U.S. agents.” The compliance date is April 2, 2025, for certificate applicants and July 7, 2025, for certificate holders.

U.S.: Parts Approval Tags

The FAA has issued a draft revision of the instructions for completing FAR Part 21 component manufacturing Form 8130-3, used by PMA holders to authenticate quality assurance. According to the FAA, this revision is a “complete rewrite that focuses on reducing redundant information.” The 18-page revision replaces the current 74-page version. There is concern, however, that some of the language that was added to correct past problems “may have been removed from this draft,” said the Modification and Parts Replacement Association. ”With this in mind, we are especially interested in your comments about hazards and risks associated with the 8130-3 tag and instruction language that mitigates those risks.” Comments are due by April 21, 2025.

U.S.: Pilot Schools

FAA-sponsored virtual public meetings are scheduled on April 1, 2, and 3 to solicit input on the agency’s plan for proposing regulations intended to modernize FAR Part 141 pilot schools. Comments from these public meetings will be considered by the agency before any actual proposals are published. Written comments are requested no later than April 24, 2025. “Modernizing Part 141 would address challenges pertaining to certification, certification management, examining authority, and evolving technology and learning methods,” said the FAA.

U.S.: Airport Safety Management Systems

Certain air carrier airports certified under FAR Part 139 are required to submit an implementation plan for a safety management system (SMS) on the following deadlines: April 24, 2024, for airports designated as hubs; Oct. 24, 2024, for airports with 100,000 or more annual operations over the previous three years; and April 25, 2025, for airports classified as port of entry, landing rights, user fee, and international facilities

Europe: Electric/Hybrid Propulsion Systems

The European Union Aviation Safety Agency has further extended the consultation period for the proposed level 2 means of compliance (MOC) for certain elements of special conditions that apply to obtaining airworthiness certification of electric/hybrid propulsion systems intended for a new-technology generation of non-fossil fuel aircraft. Those proposed MOC elements are: endurance and durability demonstration (A), calibration assurance, and safety assessmentComments are due by April 30, 2025.

ICAO: CORSIA Reports

Airplane operators and state verification authorities must submit their 2024 CORSIA emissions data to ICAO no later than April 30, 2025. Some states recommend that the verified emissions reports be submitted as an Excel file to ensure that all information is readable and will facilitate consolidation of the data. State names used in the reports should be those recognized by ICAO. Operators whose emissions were below the CORSIA threshold should let their state authorities know that a report is not required and, therefore, will not be submitted.

Europe: Regulatory Compatibility

The European Commission has published a set of standardized rules of the air (SERA) to harmonize European requirements with International Civil Aviation Organization (ICAO) regulations and recommendations with the aim to enable a “high uniform level of aviation safety in Europe and globally.” Specifically, the new and revised rules “clarify, improve, and facilitate the implementation of SERA requirements, and bring operational and safety benefits also in the domains of air traffic management, air navigation services, and airport operations.” Compliance deadline is May 1, 2025.

U.S.: Dogs Entering the U.S.

The Centers for Disease Control (CDC) has extended existing air waybill waivers to May 1, 2025, pertaining to dogs entering and/or reentering the U.S. This extension only waives the CDC pre-arrival air waybill requirement. All other responsibilities outlined in the Aug. 1, 2024 final rule remain in effect, including: Ensuring dogs have proper documentation, making staff available in the arrival area until dogs are cleared and collected, and facilitating the prompt return of dogs denied entry within 72 hours. These regulations apply to all air carriers, charter operators, and private aircraft.

U.S.: Removing Aircraft/Personal Data

The FAA is seeking comments on the impacts of removing certain aircraft registration data from public display on agency websites, including through current search functions and published reports. The removal of this data is intended to satisfy a part of the FAA Reauthorization Act of 2024, requiring the removal of private aircraft owner or operator personally identifiable information from broad dissemination or display by the agency, including on publicly available FAA websites. As part of its ongoing evaluation, the agency is considering whether to automatically withhold personally identifiable information from the public aircraft registry by default while providing owners with a means to access their data when necessary. Comments are due by May 5, 2025.