Direct Answer — Export Airworthiness Approvals
14 CFR Part 21 Subpart L (§21.321 through §21.335) governs export airworthiness approvals. A complete aircraft is exported under an export certificate of airworthiness (§21.329) — historically issued by the FAA on Form 8130-4 — and §21.325(a) is explicit that this certificate does not authorize operation. An engine, propeller, or article is exported under an export airworthiness approval issued in the form and manner the FAA prescribes (§21.325(b), §21.331) — in practice an 8130-3 Authorized Release Certificate with the export block completed. For engines, propellers, and articles the substantive test is that the item conforms to its approved design and is in a condition for safe operation (§21.331). Either path can list exceptions where the importing country or jurisdiction accepts a deviation in writing (§21.329(b), §21.331(b)). The exporter then has continuing duties under §21.335 — forward the documents the importing authority specifies, preserve and package against corrosion and damage, restore the approved configuration, and obtain foreign clearances. The form numbers come from FAA guidance, not the CFR text, so confirm current blocks with the issuing office.
The CFR does not name the form numbers — guidance does
14 CFR §21.325 says only that an aircraft approval is an export certificate of airworthiness and that the FAA determines the form and manner for engines, propellers, and articles. The 8130-4 and 8130-3 designations, the export-block wording, and bilateral acceptance conditions live in FAA guidance and bilateral procedures — describe them as agency practice, and confirm the current form revision with your FSDO or the issuing office before you build the package.
Two Documents, Two Rules: 8130-4 for Aircraft, 8130-3 for Articles
The single most common error in an export records file is treating the export airworthiness approval as one document. It is not. Subpart L splits cleanly: a complete aircraft is handled by §21.329 and gets an export certificate of airworthiness; an engine, propeller, or article is handled by §21.331 and gets an export airworthiness approval issued in the form and manner the FAA prescribes. The CFR uses those words; the form numbers (8130-4 and 8130-3) come from FAA guidance.
Document
Export Certificate of Airworthiness (FAA Form 8130-4, per FAA practice)
Rule
§21.329 — new aircraft meet the standard (or applicable special) airworthiness certificate requirements; used aircraft already hold a valid one. §21.325(a): does not authorize operation.
Deviations
§21.329(b): importing authority accepts the deviation in writing; the certificate lists each difference from type design as an exception.
Document
Export Airworthiness Approval / Authorized Release Certificate (FAA Form 8130-3, per FAA practice)
Rule
§21.331 — the item conforms to its approved design and is in a condition for safe operation (applies to both new and used items).
Deviations
§21.331(b): for new products, the importing country accepts the deviation and the approval documents the differences from the approved design.
Why this matters for records: an aircraft sale almost always carries both kinds of document. The airframe goes on the export certificate of airworthiness, while the engines, propellers, and any separately tracked articles installed or shipped with it ride on 8130-3 release tags. If the buyer's authority is reconciling the aircraft against an inventory of serial-numbered components, a missing or mismatched 8130-3 on an engine can stall acceptance of the whole aircraft. The clean export file links each component's release tag back to the airframe and to the maintenance history that proves it conforms and is in a condition for safe operation.
The component side of this overlaps directly with the parts-traceability work covered in the 8130-3 PMA parts traceability guide and the life-limited parts records requirements, both of which feed the same conformity story an importing authority wants to see.
Part 21 Subpart L, Section by Section
Subpart L is short — six sections — but each one carries a recordkeeping consequence. Here is what each section establishes and what it puts in your file. All section titles and the substantive tests below were checked against the current rule text.
Applicability
Subpart L prescribes the procedural requirements for issuing export airworthiness approvals and the rules governing the holders of those approvals. It is the scope statement — it tells you that everything that follows is about how an approval is issued and what the holder must do afterward.
Export airworthiness approvals
The framing section. §21.325(a): an export airworthiness approval for an aircraft is issued as an export certificate of airworthiness, and that certificate does not authorize operation of the aircraft. §21.325(b): the FAA determines the form and manner for an engine, propeller, or article. §21.325(c): the FAA may issue an approval for a product or article located outside the US if it finds no undue burden in administering the requirements.
Application
Who applies and how. A US-registered aircraft owner (or the owner’s agent) may apply for an export certificate of airworthiness; any person may apply for an export airworthiness approval for an engine, propeller, or article; and each applicant applies in a form and manner prescribed by the FAA. The detailed submission content lives in the FAA-prescribed form and guidance, not in this section.
Issuance of export certificates of airworthiness
The aircraft path. A new aircraft produced under the applicable production approval must meet the requirements for a standard airworthiness certificate (or the applicable special airworthiness certificate); a used aircraft must already hold a valid one. §21.329(b) is the deviation route: where the importing country or jurisdiction accepts a deviation in a form and manner acceptable to the FAA, the certificate may issue and must list as an exception any difference between the aircraft and its type design.
Issuance of export airworthiness approvals for aircraft engines, propellers, and articles
The component path. A new (§21.331(a)) or used (§21.331(c)) engine, propeller, or article qualifies when it conforms to its approved design and is in a condition for safe operation. §21.331(b) lets a new product deviate where the importing country accepts the deviation and the approval documents the differences from the approved design.
Responsibilities of exporters
The continuing duties of the holder. Unless the importing authority otherwise agrees, the exporter forwards all documents the importing country or jurisdiction specifies; preserves and packages products and articles against corrosion and damage during transit or storage (and identifies the preservation duration); removes any temporary export-delivery installation and restores the approved configuration; and secures proper foreign entry clearances for sales demonstrations or delivery flights.
The export certificate is an attestation, not a license to fly
Because §21.325(a) says the export certificate of airworthiness does not authorize operation, the buyer cannot fly on it. Operating authority comes from the importing authority issuing its own certificate of airworthiness and registration — which is exactly why the importing authority will want your underlying maintenance, AD status, weight-and-balance, and configuration records. The export certificate opens the door; the records package is what gets the aircraft through it.
The deregistration half of the transaction is governed separately. Under 14 CFR §47.41 a US Certificate of Aircraft Registration expires on events that include the aircraft becoming registered under the laws of a foreign country, and the marking rules in 14 CFR §45.33 govern changing or removing the US nationality and registration marks. See the Part 47 aircraft registration records guide for how cancellation is documented.
Related Aviation Compliance Guides
The Export Records Package — What Buyers and Foreign Authorities Ask For
The export certificate or release tag is the cover sheet. Underneath it sits the evidence that lets the FAA issue the document in the first place and lets the importing authority accept it. The conformity standard in §21.331 — and the airworthiness-certificate status in §21.329 — both have to be provable from records. Here is the package that consistently appears in a clean aircraft export, and the rule or document it ties back to.
| Record | Why the export needs it |
|---|---|
| Export certificate of airworthiness (8130-4) with any §21.329(b) exceptions listed | The aircraft-level approval; exceptions must match the importing authority’s written acceptance |
| 8130-3 release tags for installed/shipped engines, propellers, articles | Establishes each serial-numbered item conforms to approved design and is in a condition for safe operation (§21.331) |
| Complete airframe, engine, and propeller maintenance records / logbooks | Substantiates conformity and condition; the importing authority issues its own C of A from these |
| Airworthiness Directive status list | Open recurring and one-time AD status is a first-order question for any importing authority |
| Current weight and balance and equipment list | Defines the approved configuration the aircraft must be restored to before delivery (§21.335) |
| Importing country / jurisdiction acceptance of any deviation | Backs the exceptions on the export certificate; without it the exceptions are unsupported (§21.329(b)) |
| Preservation and packaging record with stated duration | Required exporter duty under §21.335 for products and articles in transit or storage |
| US registration cancellation request / N-number removal certification | Closes out the US registration (§47.41) and marks (§45.33) so the importing authority can register |
A clean export file
- Links every 8130-3 component tag to the airframe and its history
- Matches each export-certificate exception to a written importing-authority acceptance
- Shows the aircraft restored to its approved configuration before delivery
- Includes the preservation duration and packaging record
- Documents the US deregistration request and mark-removal certification
What stalls a closing
- Engine 8130-3 serial number does not match the installed engine
- Export certificate lists an exception with no importing-authority acceptance on file
- Temporary ferry/export equipment never removed or never documented as restored
- AD status list incomplete or inconsistent with the logbooks
- Deregistration not sequenced — importing authority cannot register over a live US record
The maintenance-records backbone here is the same one covered in the Part 135 records overview, the AD compliance records guide, the weight-and-balance records requirements, and the aviation records retention schedule. For the airframe-level identity documents, see the ARROW documents explainer.
Exporter Duties Under §21.335 — Each One Is a Record
14 CFR §21.335 lists the exporter's continuing obligations — and unless the importing authority otherwise agrees, each generates a document that belongs in the file. Treating them as paperwork-after-the-fact is how exporters end up reconstructing the package under time pressure at delivery.
§21.335(a) — Forward the importing country’s specified documents
The exporter forwards to the importing country or jurisdiction all documents that country or jurisdiction specifies. That specified list is shaped by the importing authority’s national rules and, where one applies, the bilateral relationship with the FAA. Capture the list itself as a record — it is the checklist the rest of the package is measured against, and it changes by destination.
§21.335(b) — Preserve and package against corrosion and damage
The exporter preserves and packages products and articles as necessary to protect them against corrosion and damage during transit or storage, and identifies the duration of that preservation. The stated preservation duration is a record the receiving party relies on — it tells them how long the protection is valid and when re-preservation may be required.
§21.335(c) — Remove temporary export installations, restore approved configuration
The exporter removes (or causes to be removed) any temporary installation incorporated on an aircraft for export delivery and restores the aircraft to the approved configuration. Ferry tanks, test equipment, or temporary instrumentation added for the delivery flight must come back out, and the restoration should be documented against the weight-and-balance and equipment list so the aircraft the buyer receives matches the approved configuration.
§21.335(d) — Secure foreign entry clearances for demos and delivery flights
The exporter secures all proper foreign entry clearances from the countries or jurisdictions involved when conducting sales demonstrations or delivery flights. These clearances are operational, transaction-specific records — keep them with the export file so the delivery flight’s legality is documented end to end.
Bilateral agreements shape the document list — but they are not CFR
Most exports to a major aviation jurisdiction run through a bilateral aviation safety relationship between the FAA and the importing authority — for example, the US–EU bilateral and its Technical Implementation Procedures, which describe how an 8130-3 is recognized and what additional national conditions an EASA member state may attach. These are bilateral and agency procedures, not Title 14 CFR sections, and should be described that way rather than cited as a regulation.
The CFR anchor stays §21.335(a): the exporter forwards whatever documents the importing country or jurisdiction specifies. The bilateral simply determines what that list contains for a given destination — which export blocks must be completed, which additional national requirements attach, and what acceptance the importing authority needs. Export-control regimes (for example, EAR/ITAR licensing where applicable) are a separate legal track entirely from airworthiness and must be cleared with qualified counsel — they are not part of Part 21.
FileFlo as the Export Records Layer
FileFlo is a compliance document intelligence platform — a read-only proof layer that organizes the records behind an export. It does not issue export certificates, prepare 8130-3 or 8130-4 forms, perform conformity inspections, hold any certificate, or replace your IA, repair station, or the FAA issuing office. What it does is classify, index, and surface the documents that the export certificate and the importing authority depend on.
- Classifies uploaded logbook entries, work orders, and release tags against the governing reference (the specific 14 CFR section, the AD, the form type)
- Indexes 8130-3 component release tags and links them to the airframe and its maintenance history
- Tracks AD status and surfaces open recurring/one-time items an importing authority will ask about
- Assembles a destination-specific document checklist from the importing authority’s specified list (§21.335(a)) and flags what is missing
- Keeps the preservation-duration record, configuration-restoration evidence, and deregistration paperwork together in one indexed file
FileFlo classifies 600+ aviation document types and manages records across Part 91, Part 135, and Part 145 operators in a single platform. Pricing: Starter $89/mo, Professional $299/mo. 5-day free trial, no credit card required. FileFlo does not provide or run a safety management system (SMS), dispatch system, or flight operations system — it keeps the documents that prove compliance audit-ready.
New vs. Used, and Who Can Apply
Subpart L treats new and used differently in one respect and the same in another. For aircraft under §21.329, a new aircraft produced under the applicable production approval must meet the requirements for a standard (or applicable special) airworthiness certificate, while a used aircraft must already hold a valid one. For engines, propellers, and articles under §21.331, both new (§21.331(a)) and used (§21.331(c)) items face the same substantive test: conform to the approved design and be in a condition for safe operation.
On the application side, §21.327 draws a line: only a US-registered aircraft owner (or the owner's agent) may apply for an export certificate of airworthiness, whereas any person may apply for an export airworthiness approval for an engine, propeller, or article. Each applies in the form and manner the FAA prescribes. That difference matters when a broker or parts distributor — not the registered owner — is moving the hardware: they can pursue the component approval, but the aircraft-level export certificate runs through the registered owner.
"Condition for safe operation" is a records claim about a specific serial number
The §21.331 standard is not satisfied by a model-level statement. The approval attaches to a serial-numbered engine, propeller, or article, and the conformity-and-condition determination has to be supported by that unit's traceability and maintenance history. A release tag whose serial number cannot be reconciled to the records behind it is the most common reason a component approval is questioned at the receiving end.
Frequently Asked Questions
What is the difference between FAA Form 8130-4 and Form 8130-3 in an export?
They cover two different things. An export airworthiness approval for a complete aircraft is issued as an export certificate of airworthiness, which the FAA has historically documented on FAA Form 8130-4 (Export Certificate of Airworthiness) under 14 CFR §21.329. An export airworthiness approval for an aircraft engine, propeller, or article is issued in a form and manner the FAA prescribes under §21.331, and in practice that is FAA Form 8130-3 (Authorized Release Certificate, Airworthiness Approval Tag) with the appropriate export block completed. The CFR itself does not name the form numbers in the rule text — §21.325(a) simply says the approval for an aircraft is an export certificate of airworthiness, and §21.325(b) says the FAA determines the form and manner for engines, propellers, and articles. The form numbers come from FAA guidance and practice, so when you build the records package, treat the 8130-4 as the aircraft-level document and the 8130-3 as the component/article-level release, and confirm the current form and block requirements with your FSDO or the issuing office.
Does an FAA export certificate of airworthiness let the buyer operate the aircraft?
No. 14 CFR §21.325(a) states that an export airworthiness approval for an aircraft is issued as an export certificate of airworthiness, and that this certificate does not authorize operation of the aircraft. It is an attestation, at the point of export, about the airworthiness condition and conformity status of the aircraft relative to its type design and any conditions the importing authority has accepted. Authority to operate comes from the importing country issuing its own certificate of airworthiness and registration under its own rules. This is why an export certificate is a records-and-handover document, not an operating document — and why the importing authority almost always requires the underlying maintenance, AD status, and configuration records to issue its own certificate.
What does 14 CFR §21.329 require before the FAA issues an export certificate of airworthiness for an aircraft?
Section 21.329 ties the export certificate to airworthiness status. Broadly, a new aircraft produced under the relevant production approval must meet the requirements for a standard airworthiness certificate (or the applicable special airworthiness certificate, such as primary or restricted category), and a used aircraft must already hold a valid standard or applicable special airworthiness certificate. Section 21.329(b) is the deviation path: if the importing country or jurisdiction accepts, in a form and manner acceptable to the FAA, a deviation from a requirement, the FAA may issue the certificate provided it lists as an exception any difference between the aircraft and its type design. From a records standpoint, that means the exceptions written on the export certificate must be backed by the importing authority's written acceptance — and your file needs both the certificate and that acceptance to be coherent.
What conditions must an engine, propeller, or article meet under 14 CFR §21.331?
Section 21.331 sets a two-part substantive standard: the engine, propeller, or article must conform to its approved design and be in a condition for safe operation. That standard applies to both new items (§21.331(a)) and used items (§21.331(c)). Section 21.331(b) is the deviation provision for new products — the importing country can accept a deviation, and the approval documents the differences from the approved design. The conformity-and-safe-condition language is the same substantive test that underlies a domestic airworthiness approval, which is why an 8130-3 export tag is only as good as the traceability behind it: the records have to show that the specific serial-numbered item conforms to its approved design and that its condition was established by an appropriately authorized person.
What are the exporter’s responsibilities under 14 CFR §21.335?
Unless the importing country or jurisdiction otherwise agrees, §21.335 requires the exporter to: forward to the importing country or jurisdiction all documents that country or jurisdiction specifies; preserve and package products and articles to protect them against corrosion and damage during transit or storage, and identify the duration of that preservation; remove (or cause to be removed) any temporary installation incorporated on an aircraft for export delivery and restore the aircraft to its approved configuration; and secure all proper foreign entry clearances from the countries or jurisdictions involved when conducting sales demonstrations or delivery flights. These are continuing obligations of the approval holder, and several of them are document-producing events: the special/additional importing-country requirements, the preservation duration, and the configuration restoration all generate records that belong in the export file.
What happens to the US registration and airworthiness certificate when the aircraft is sold abroad?
When ownership transfers to a foreign buyer, the US Certificate of Aircraft Registration is wound down. Under 14 CFR §47.41, a Certificate of Aircraft Registration expires on events including the aircraft becoming registered under the laws of a foreign country, and the holder must notify the FAA and return the certificate as required. In connection with export delivery, the exporter typically requests cancellation of the US registration and standard airworthiness certificate, returns them to the FAA, and — where the US identification (N-number) and registration marks are removed — provides certification consistent with the marking rules in 14 CFR §45.33. Sequencing matters: many importing authorities want evidence that the US registration has been or will be canceled before they finalize their own registration, so coordinate the deregistration request, the export certificate, and the importing-country filing rather than treating them as independent steps.
Can the FAA issue an export approval for a product located outside the United States?
Yes, subject to a burden test. 14 CFR §21.325(c) allows the FAA to issue an export airworthiness approval for a product or article located outside the United States if the FAA finds no undue burden in administering the applicable requirements. Practically, that situation arises with aircraft or components already positioned overseas that are being re-exported or transferred between foreign jurisdictions. The records implication is the same as for any export: the file must still establish conformity and condition (for engines, propellers, and articles under §21.331) or airworthiness-certificate status and any listed exceptions (for aircraft under §21.329), and you should expect to substantiate that to the issuing office even though the hardware is not physically in the US.
How do bilateral agreements affect what records the importing country accepts?
Many exports run through a bilateral aviation safety relationship between the FAA and the importing authority — for example, the US–EU bilateral and its Technical Implementation Procedures, which describe how an FAA Form 8130-3 is recognized and what additional conditions an EASA member state may impose. These bilateral arrangements and their implementation procedures are FAA and partner-authority guidance, not Title 14 CFR sections, so they should be described as bilateral/agency practice rather than cited as a regulation. The CFR anchor is still §21.335(a): the exporter forwards whatever documents the importing country or jurisdiction specifies. The bilateral simply shapes that specified list — which 8130 blocks must be completed, which additional national requirements attach, and what acceptance statement the importing authority needs to issue its own certificate.
Related FileFlo Aviation Records Guides
Export records sit on top of the same maintenance, airworthiness, and identity records every operator already keeps. These guides cover the documents an export package draws from:
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Also related: Aviation Compliance Hub · ARROW Documents · 8130-3 Parts Traceability · Records Retention Schedule
Written by Chad Griffith, Founder, FileFlo — compliance document intelligence. Reviewed June 13, 2026. FileFlo is a compliance document intelligence platform — not legal counsel, export-control advisers, or an A&P. Verify all export airworthiness determinations, current form requirements, and importing-country conditions with the issuing FAA office, a certificated IA or repair station, and qualified counsel.