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Registration of aircraft with no EASA type certificate

Hi everyone,

This is my first post on here, so please bear with me.
Background, I flew for 20 years while living in South Africa (PPL, LSA, GYRO) but stopped flying when moving to the Netherlands in 2017. I have now restarted my flying, unfortunately due to the elapsed time have to redo my PPL.

I have decided pretty soon that I would like to get my own plane again (owned several in South Africa), the LSA/MLA class appeals more to me but I needs some advice on the registration rules. If an aircraft does not have an EASA type certificate, is it possible to register it in an EU country? Some examples:
- I was interested in a Tecnam P2004 Bravo listed in Slovenia and on Microlight registration there, however was told by local CAA (NL) that the P2004 does not have an EASA type certificate and as such cannot be registered in the Netherlands, not even MLA.
- I see some JMB VL-3’s registered on the Dutch register yet cannot find an EASA type certificate for it on the EASA site. This seems to contradict above.

How does this work? If an aircraft is currently registered in an EU country on MLA, e.g. Czech Republic, Italy, Belgium, etc., what is the process to have the aircraft registered in the Netherlands. I don’t understand that an EU built aircraft which is commonly flown all over Europe cannot be registered in some countries.

Hope someone can point me in the right direction.

Regards,
Cobus

EHLE, Netherlands

@propkop You need to make a clear distinction between EASA-certified and UL aircraft. The former is pan-European, so all EASA countries accept their certification, and one can station any such aircraft with any EASA-member registration in any country. The latter are nationally regulated and so EASA does not ‘touch’ them.

Each county will certify UL types according to their own standards and adding national peculiarities. Examples: In Germany, no autopilot allowed. In France MTOM 525 kg rather than 600 (or 472) kg. It is of course difficult for an individual to enter into a process with a CAA of a country to get a type approved. Therefore, the manufacturer usually tries to obtain such a certification for the countries which he believe are worth his while. This may even result in slight modification of the type for a specific country. Often, smaller countries (the Netherlands) will follow (in aviation terms) bigger countries in certifying models, like Germany, Italy or the Cz Republic.

So you will see a VL3 on the Dutch (UL) registry without having an EASA certificate. For whatever reason, the Dutch CAA has not certified the Tecnam P2004B, but not because it has no EASA certificate.

It should be easy to check which UL types have been certified by the Dutch CAA. Also, you may want to check whether a foreign-reg UL can be stationed in the Netherlands. The rules vary by country..

In choosing between EASA-certified or UL, you of course need to factor in all kinds of things, like maintenance (self declared for UL in some countries), access to airspace (permits required for UL in various countries), UL being VFR only etc etc.

Last Edited by aart at 04 Mar 08:35
Son Alberti LEJF, Son Bonet LESB, Mallorca, Spain

A nice sum up by @Aart.

aart wrote:

You need to make a clear distinction between EASA-certified and UL aircraft

and

aart wrote:

In choosing between EASA-certified or UL, you of course need to factor in all kinds of things, like maintenance (self declared for UL in some countries), access to airspace (permits required for UL in various countries), UL being VFR only etc etc.

not only applies to ULs, but also for aircraft of the homebuilt category.

Dan
ain't the Destination, but the Journey
LSZF, Switzerland

@aart,

Thank you for your response and clear explanation. I might have worded my first post inaccurately, the local CAA official suggested looking at EASA certified types, so did not specifically say that the P2004 cannot be registered due to non-certification status under EASA.

The UL class offers a lot more options and flexibility for the recreational flyer but unfortunately also limited by regulation. Currently the weight limit for MLA in the Netherlands is 450kg, that leaves very little useful load on the typical UL aircraft with empty weights around 300 kg, they are almost by definition single seaters. I heard that this might be changed soon but at the moment severely limits the utility of aircraft in the UL class. (A good example is the P2002JF and P2002 Sierra, identical aircraft but the former is certified and latter not. The JF has a MTOW of 600kg and Sierra only 450kg, on an aircraft with empty weight of 330kg).

In the Netherlands UL registered aircraft are only allowed for 28 days, so keeping it on a foreign register is not an option.

Looks like I’ll have to do more research.
Regards,
Cobus

EHLE, Netherlands

Yes Dan, I should have mentioned Annex 1 rather than UL.

@propkop is your forum name Afrikaans in that it means ‘’prophead’ like ‘Motorhead’ for a car fanatic? I like it 😀

Son Alberti LEJF, Son Bonet LESB, Mallorca, Spain

I heard that this might be changed soon but at the moment severely limits the utility of aircraft in the UL class

Definitively worthwhile waiting a bit and ypu may want to go to Aero Friedrichshafen. Or not, because you’ll come back with choice anxiety, if that is a word..

Son Alberti LEJF, Son Bonet LESB, Mallorca, Spain

Dan wrote:


access to airspace (permits required for UL in various countries), UL being VFR only etc etc.
not only applies to ULs, but also for aircraft of the homebuilt category.

not necessarily. If the aircraft is registered in an ECAC state, there are no issues with access to the majority of european air spaces…. Spain is probably the only one which requires notification but I know a pilot who’s flown his homebuilt for decades around Spain from France without any issues…. he said “they don’t really care….”

EDL*, Germany

aart wrote:

@propkop is your forum name Afrikaans in that it means ‘’prophead’ like ‘Motorhead’ for a car fanatic? I like it 😀

Yes, it is Afrikaans and translation is correct

EHLE, Netherlands

aart wrote:

Definitively worthwhile waiting a bit and ypu may want to go to Aero Friedrichshafen. Or not, because you’ll come back with choice anxiety, if that is a word..

I am going there, but the limitation(s) remain, if the MTOW is limited to 450kg there is very few aircraft that can be flown legally with a pilot and passenger even before adding fuel. So it seems I have to look at certified versions :-(

EHLE, Netherlands

There are more options that you can see at first glance.

UL (or whatever local name for these aircraft) are specified by EASA. They are one very particular category in the much bigger Annex I bag of aircraft. MTOW is 450 kg, with an option to 600. The French ULMs have never been ULs according to EASA, but a special local French thing. Now, EASA only specify MTOW and a couple of other parameters (almost no specs at all), but where these are not followed, they are not per def ULs according to EASA.

All other countries follows EASA regarding ULs AFAIK.

For an arbitrary aircraft to be registered as UL will not work unless the specs are followed. It very seldom works unless the aircraft is designed as an UL from the start, due to weight in particular.

The other common option is to register it as an experimental aircraft. This may or may not work depending on country.

In later years a third option is also available. You can register it as a “national” aircraft. Then it will become like an “orphan” aircraft (in principle) as seen by EASA regarding operation (I think, but this is not much common as of today, so I don’t know for sure) This is what the French ULs actually are IMO, but everybody seems to pretend they are just ULs

The elephant is the circulation
ENVA ENOP ENMO, Norway
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