I would definitely double check national regulation I recall while ago that flights from UK to Netherlands for both EASA & non-EASA aircraft required ELT not PLB as other way for compliance (also ModeS not ModeC, and two radios 8.33+8.33 not 8.33+25), that was well after NCO was introduced…
Yes; these generate a requirement for ELT or PLB carriage, but the topic is whether the owner can replace the battery or fly with an out of date battery (the battery expiry being, by definition, the date stated on the outside label, which can be completely fictitious relative to the actual battery state).
One has to ask the question “are you capable of changing the battery?” Apparently in some equipment its not just a case of old one out, new one in
Or so I am led to believe. Some describe it as being like that little flat battery in a computer that is rarely changed, but when it is you need all the bios etc (please forgive lack of IT knowledge) or you cock it up, as I found out to my cost.
Others say its more like changing the batteries on your tv remote which the instructions say that must be limited to less than 30seconds.
Then there is the paperwork to prove that you’ve done it. (DOH)
Where do these explanations come from?
Maintenance people who make money out of the annual change of ELT and PLB batteries🙂
Legal requirement question met with a shoulder shrug and the following answers.
1 depends on Aircraft type, registration, and maintenance regime.
2 don’t think there is a regulation for under 2T
3 if it’s used in the school it must be done by at least a part66 engineer.
4 what does it say on the manufacturer’s instruction sheet it came with?
I do not have a clue which if any of these is accurate but the school plane always has it changed as part of the annual.
So being pragmatic:
1. I should probably leave changing the battery to the mechanic
2. Practically speaking I could fly to the next annual before changing, since no one will be checking the battery state before then. I’m curious if “on condition” for an ELT battery is ok if mentioned in the AMP. My preference would be to delay such things to the next applicable annual/100 hrs to avoid random visits to the shop.
In reality I’ve ordered the battery and will have it replaced within days of expiry and plan to have it replaced by a shop I want to check out for an engine monitor installation quote. But I was curious about the legalities.
gallois wrote:
One has to ask the question “are you capable of changing the battery?”
Unless it requires special tooling or “secret techniques”, I am confident in my ability to swap a battery in any device (including said laptop).
May I ask for more details on the question? I got my ELT registered in the UK and the registration is bound to the ELT battery expiration date, so the day my battery expires, the ELT registration is void anyways. To get it renewed I have to send the paperworks of the new battery and a picture of the revised label on the ELT to authorities. They never asked me whether I did the change by myself, so I guess it is part of the maintenance program and they don’t care. If I remember correct, they also sent me the information that a non-registered ELT, i.e. battery expired, qualifies as ‘no ELT’, so flying into ELT mandatory airspace is prohibited with expired battery. Isn’t that the usual procedure, so maybe changing register to something else may solve some problems?
Are ELTs “registered” at all, like PLBs?
Yes, they are. They are even programmed with a code that is tied to the airframe, one of:
Technically, they can also be programmed with just serial number, but I’m not sure what operator/airframe in what country is allowed to actually program them that way.
I wouldn’t call that a registration, in the same way as PLBs are registered, but OK.
Found this: https://beaconregistration.noaa.gov/RGDB/resources/forms/elt.pdf
Never had anything to do with that in my AC. These registrations do not seem to expire in the US.
They don’t expire but nowadays NOAA mail a letter every year or two to ELT owners outside the US, checking they are still alive 
They are registered and additionally to that registration, they are programmed with a code tied to the airframe. Some authorities (e.g. Bahamas, Israel) allow registration directly on https://406registration.com/, others (e.g. Luxembourg, Germany) require registration with their CAA or (e.g. USA) other state-run organisation.
The list of contact points for registration is at https://406registration.com/countriessupported.aspx
