Flying and owning an OK-registered ultralight with Polish PPL(A) licence

Sales people talk sales talk None of these are certified as far as I can see. They are all UL or LSA. They may very well have “certified instruments”, meaning TSO/ETSO’d. But also keep in mind that there is no way not to buy non ETSO’d aircraft radio or transponder in an aircraft. It has nothing to do with aircraft needing certified instruments, but simply a result that telecommunication bureaus require a certain performance standard for radio equipment.

Even ULs have certified radio and transponder.

ULs can be built according to any standard, but they are never certified.
EASA LSA is built according to CS-LSA. They are also never certified.
EASA CS-23 is the standard “normal” aircraft are built after. All these are certified.

It’s a bit of a jungle really. The Savannah is designed, built and delivered according to both the German UL standard and ASTM [some number] (the US LSA standard). Every Savannah sold (unless as a kit) will simultaneously be both a European UL and a US LSA with appropriate documentation, stamps etc. Which is very neat. This is is not possible with CS-LSA. An aircraft (one serial number) cannot simultaneously be CS-LSA and UL. EASA doesn’t allow it.

ULs can be built according to any standard, but they are never certified.
EASA LSA is built according to CS-LSA. They are also never certified.
EASA CS-23 is the standard “normal” aircraft are built after. All these are certified.

AIUI, CS23 has a sub-set called CS-LSA and CS-VLA. Both types are EASA-certified with a MTOM of 600kg and 750kg respectively. That matches with the third line above. Example: the Bristell B23: EASA/ CS23-VLA

But according to the second line above there is something like a EASA-LSA non-certified category? Or are these aircraft with a Restricted Type Certificate? I’m confused..

AIUI EASA-LSA no longer exists. AFAIK it was put in place because manufacturers were building light sports aircraft for ULM and USA market, but there was not at the time a certification system in place for these aircraft. EASA agreed to sort of certify them under EASA LSA so they could be marketed and flown while CS23 was being put in place for them.
What tended to happen is that the agent for a particular aircraft would have an agreement with the manufacturer to carry out the work that was necessary to meet ULM regulations and to meet the air worthiness necessary. At the time MTOW in France was 450kg +.25kg for the parachute now it’s 525kg including chute.This was then certified by a national authority on behalf of the NAA. In France this responsibility rested and still rests with OSAC.
In the UK it was and perhaps is the LAA.
To fly a French ULM you need a ULM licence. In the early days of ULM, if you held a PPL you simply had to go your the DGAC and they gave you a ULM licence by equivalence. That is no longer the case and now you have to pass a test with an instructor.
So you can have a EASA certified CS23 aircraft which might well have been a EASA-LSA until EASA got its certification process in place. Eg IIRC the Eurostar. This same aircraft may well also have been adapted as a ULM.
All 450kg MTOW ULM can be updated to a 500kg MTOW ULM but it has to be entered in the paperwork IIUC through OSAC and/or the DGAC.
Some countries can now have the ULM MTOW uprated to 600kg but it is not a ULM in France and needs special permit to enter French airspace. Rumour has it that this might soon change,and 600kg MTOW ULMs may well become a separate category of ULM with different rules, as I wrote in an different thread. But this is all the ULM framework and regulated by NAAs whereas the certified CS23 aircraft come under EASA.
It is possible for eg a pilot who has a PPL and a ULM licence to fly a 3 axis ULM and record it as hours flown as s/he would for the PPL. These hours will then count towards the 12 hours in the second 12 months of a 24 month period towards revalidating the PPL. But only AIUI for revalidations.
So you can see even if an aircraft meets both CS23 and ULM rules you can only register as one or the other not both and it depends on your NAA and EASA whether you would be allowed to re register in the other category at a later date.
The experimental category in France only exists as an experimental aircraft not as a homebuilt or ex military etc which all fall under different categories which is why a 600kg MTOW category under ULM may well be possible, here, in the near future.

aart wrote:

AIUI, CS23 has a sub-set called CS-LSA and CS-VLA

Not to my knowledge. CS-LSA is is nothing but a modified ASTM F2245 (the US-LSA specs). There’s several minor modifications, but the largest are probably no max speed and it allows variable speed prop and retracts.

CS-VLA is more of a stand-alone and stripped version of CS-23. Kind of CS-23 light.

LeSving wrote:

Neither CS-LSA or UL (any kind of UL standards, there are many) are certified standard,

What are you talking about? CS-LSA aircraft are certified. They have an EASA TC and an ICAO-compliant CofA.

EASA LSA can only be flown in EASA-land without explicit permission.

That I have never heard before. Please tell me why an aircraft with an ICAO-compliant CofA can’t be flown outside EASA-land?

As an example, I attach the CofA of a CS-LSA aircraft. Note that it states that it is issued “pursuant to the ICAO convention”.
CofA_pdf