IATA Aircraft Lease Guidance

Annex IX: Components Guidelines
FAA Order 8130.21H provides procedures for completion and use of Form 8130-3. This document indicates
that for a newly built part, the originator of the 8130-3 should retain the certificate for no less than 5 years in
case of products and articles, and 10 years for critical parts. If this form is used as an approval for return to
service, this period is reduced to a minimum period of two years, unless the work is repeated or superseded.
For the operator itself the retention period for component certificates is provided in FAR 121.380, which
indicates that records must be retained until the work is repeated or superseded by other work, or for one
year after the work is performed. For components which require an overhaul, the FAA requires monitoring the
time since last overhaul, but no additional record keeping requirements are mentioned for these HT
components.
In a separate chapter, Order 8130.21H also provides guidance on the acceptance and use of electronic
exchange of 8130-3s by the use of ATA Spec-2000.
3. Component File Overview
Regulatory requirements mandate that component records need to be maintained for a period of one (FAA)
or three (EASA) years. Only the EASA specifically mentions additional requirements for HT components
mandating that the records should be retained until the maintenance event is superseded. Nevertheless, one
should be aware that the requirements from the lease are often more stringent, as there is a commercial
aspect involved.
The lease regularly mentions a, for example, 110% (or other percentage) rule. If incorporated, this rule
prohibits installation of any component which has accumulated over 110% of the operational life of the
airframe. As it is not a requirement by the regulators to record the total hours and cycles of the component on
the certificate, it should be noted that the operator is required to have a system in place to trace the total
hours and cycles of these components. This is not taken into consideration for the standard component file
as presented in this annex. Operators should be aware that if they don’t have sufficient system in place to
properly track these parts, meeting this contract obligation might be challenging. These restrictions are up
for negotiation between the Lessor and the Lessee.
Another item to be considered with respect to on condition components is the requirement to have
compliance certificates of all installed components, meaning it is a requirement to retain the release
certificate of all components for as long as the parts are installed on the aircraft.
The component file should provide a clear overview of all components installed on the aircraft, including the
installation date, hours, and cycles. As there are separate regulatory requirements for on condition
components and HT components, two separate files will be considered.
3.1 On Condition component file
The On Condition file should ideally consist of two sections, a summary file and the compliance data, all
sorted by ATA chapter.
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