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Aviation Compliance — 14 CFR §21.183, §21.181, Part 47

Importing an Aircraft into the US: The Standard Airworthiness Certificate and the Records a Foreign Import Needs

What 14 CFR §21.183 actually requires to put a US standard airworthiness certificate on an imported aircraft — the registration eligibility gate that comes first, the difference between the import path in §21.183(c) and the used-aircraft path in §21.183(d), how a bilateral agreement makes the exporting country's certification acceptable to the FAA, and the records a foreign used import has to assemble before anyone signs.

Chad Griffith, Founder & CEO, FileFloReviewed: June 13, 202613 min read

Compliance document management perspective, not legal, customs, export-control, or airworthiness certification advice. Verify every import airworthiness determination, registration eligibility question, bilateral acceptance condition, and inspection requirement with the FAA Aircraft Certification office or your FSDO, a certificated IA or repair station, and qualified counsel before acting on any specific transaction.

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Direct Answer — Importing an Aircraft

To put an imported aircraft into US service you clear two gates in order. First, registration eligibility: under 14 CFR §47.3 an aircraft may be registered only if it is not registered under the laws of a foreign country and is owned by a US citizen, a resident alien, a qualifying US corporation, or a government entity — so the foreign registry has to be released and a qualifying US owner has to hold title. Second, the standard airworthiness certificate under 14 CFR §21.183. Paragraph (c) “Import aircraft” applies when the aircraft is type certificated under §21.21 or §21.29 and produced under another State of Manufacture: that State certifies, under the export provisions of an agreement with the United States, that the aircraft conforms to the type design and is in a condition for safe operation, and the FAA also so finds. Paragraph (d) “Used aircraft and surplus aircraft of the U.S. Armed Forces” is the route many used imports travel: the applicant presents evidence of conformity to type design (including airworthiness directives) and the aircraft is inspected under the §43.15 performance rules. Once issued, the certificate stays effective per §21.181(a) as long as the aircraft is maintained under parts 43 and 91 and remains US-registered. The bilateral agreement that makes the exporting authority's certification acceptable is FAA practice, not a CFR section — confirm it with the FAA Aircraft Certification office.

§47.3
Registration gate — not registered abroad + owned by a US citizen, resident alien, or qualifying US corp
14 CFR §47.3, §47.7
§21.183(c)
Import aircraft — State of Manufacture certifies per an agreement; FAA finds conformity + safe condition
14 CFR §21.183(c)
§21.183(d)
Used aircraft — conformity-to-type evidence (incl. ADs) + §43.15 inspection
14 CFR §21.183(d), §43.15

The CFR does not name the bilateral agreement — it points to it

14 CFR §21.183(c)(2) says the State of Manufacture certifies conformity “in accordance with the export provisions of an agreement with the United States.” The names BASA, BAA, and the Implementation Procedures for Airworthiness, and which countries have one, come from FAA and partner-authority arrangements — not the CFR. Describe the bilateral as the mechanism that makes the foreign certification acceptable, and confirm the current agreement and its terms with the FAA Aircraft Certification office before relying on it.

First Gate: Registration Eligibility (Part 47)

Before the FAA will issue a standard airworthiness certificate, the aircraft has to be eligible to be a US aircraft. That is a registration question, and it is the first thing an import transaction has to solve. Under 14 CFR §47.3(a), an aircraft may be registered under 49 U.S.C. 44103 only when it is not registered under the laws of a foreign country and is owned by one of a defined set of eligible owners.

Who may register (§47.3(a))

  • A citizen of the United States
  • An individual foreign citizen lawfully admitted for permanent residence (resident alien)
  • A non-citizen US corporation organized and doing business under US law, where the aircraft is based and primarily used in the United States
  • A US, state, territorial, or local government entity

The condition that trips up imports

§47.3(a) requires that the aircraft is not registered under the laws of a foreign country. A used import is almost always still on a foreign registry at the moment of sale, so the foreign deregistration has to be obtained and sequenced — the US registration cannot complete over a live foreign record.

§47.7 then sets the citizenship and resident-alien evidence the applicant must certify or furnish on the registration application.

Foreign individuals: a US corporation or owner trust is the usual structure

Because a non-resident foreign individual is not an eligible owner under §47.3(a), foreign-connected buyers commonly register through a qualifying non-citizen US corporation (with the based-and-primarily-used-in-the-US condition) or a US owner trust whose trustee meets the citizenship rules. These structures carry their own documentation and §47.7 evidence requirements — work them out with counsel and confirm the current FAA Registry requirements before you assume eligibility. The full mechanics live in the Part 47 aircraft registration records guide.

Two Paragraphs of §21.183: (c) Import Aircraft vs. (d) Used Aircraft

The most common confusion in an import file is which paragraph of 14 CFR §21.183 the aircraft is being certificated under. The section lists several routes to a standard airworthiness certificate; two of them matter for imports, and a used foreign aircraft frequently has to satisfy both the import framing and the used-aircraft evidence.

§21.183(c) — Import aircraft

What it covers

An aircraft type certificated under §21.21 or §21.29 and produced under the authority of another State of Manufacture.

The three findings

  • (c)(1) Type certificated under §21.21 or §21.29 and produced under another State of Manufacture
  • (c)(2) That State certifies, under the export provisions of an agreement with the US, that the aircraft conforms to type design and is in a condition for safe operation
  • (c)(3) The FAA finds that the aircraft conforms to type design and is in a condition for safe operation
§21.183(d) — Used & surplus aircraft

What it covers

Used aircraft and surplus aircraft of the US Armed Forces — the route many used imports actually travel.

What the applicant shows

  • (d)(1) Evidence that the aircraft conforms to a type design and to applicable airworthiness directives
  • (d)(2) The aircraft is inspected and found airworthy under the performance rules for 100-hour inspections in §43.15, by an appropriately authorized person

The practical takeaway: (c) is about the type-design pedigree and the exporting authority's certification under an agreement, while (d) is about proving this specific used airframe conforms and is airworthy right now, with a hands-on §43.15 inspection. A used aircraft coming in from a bilateral-partner country typically needs the agreement-backed export certification contemplated by (c)(2) and the conformity evidence and inspection of (d). Treat them as complementary, not alternatives, and confirm with your FSDO which paragraph governs your aircraft.

The type-certificate question comes before everything else

§21.183(c)(1) presumes the aircraft model holds a US type certificate (issued under §21.21) or was type certificated under the import provisions of §21.29. If the specific model and configuration are not covered by a US type certificate, you have a type-certification problem to solve before any airworthiness-certificate paperwork is meaningful. Establishing the type-design basis is the foundation the whole import file sits on.

The §43.15 inspection that §21.183(d)(2) requires connects to the broader maintenance-records framework covered in the Part 91.409 annual inspection guide and the §43.9 maintenance record entry requirements; the AD-conformity evidence in (d)(1) is the subject of the airworthiness directive compliance records guide.

The Bilateral Path — What §21.183(c)(2) Points To

The phrase that does the real work in the import path is in §21.183(c)(2): the State of Manufacture certifies conformity and safe-operation condition “in accordance with the export provisions of an agreement with the United States.” That agreement is the bilateral. The CFR points to it without naming it — which is exactly why you should describe it as the mechanism that makes a foreign authority's certification acceptable, not as a regulation with a section number.

Bilateral agreements are FAA practice, not Title 14 CFR

Historically the US entered Bilateral Airworthiness Agreements (BAAs); the modern instruments are Bilateral Aviation Safety Agreements (BASAs) with associated Implementation Procedures for Airworthiness (IPA). These describe how the FAA and a partner authority accept each other's airworthiness findings, what export documentation each requires, and any additional conditions that attach. None of these names — BASA, BAA, IPA — appears in the CFR text. They are agency and partner-authority arrangements.

The CFR anchor stays §21.183(c)(2): the State of Manufacture's certification has to be made under the export provisions of an agreement with the US. Whether such an agreement exists for the country your aircraft is coming from, and what its provisions require, is something to confirm with the FAA Aircraft Certification office — not something to assert from a CFR cite. If no qualifying agreement covers the aircraft, the import path under (c) does not run cleanly, and the certification has to be approached differently.

The foreign export certificate is an input, not US operating authority

The export certificate of airworthiness issued by the country of export attests to the aircraft's conformity and condition at the point of export. It feeds the FAA's §21.183(c)(3) and §21.183(d) determinations, but it does not by itself authorize US operation — that comes from US registration and the US airworthiness certificate. This is the mirror image of the export side, where a US export certificate under §21.325(a) likewise does not authorize operation. The companion guide walks the outbound direction: export airworthiness approvals (Form 8130-4 / 8130-3).

For installed engines, propellers, and accessories that travel with the imported airframe, the component-level acceptance runs on a release document — in practice an FAA Form 8130-3 or a bilateral-equivalent release — showing the item conforms to its approved design and is in a condition for safe operation. That traceability is covered in the 8130-3 PMA parts traceability guide and the life-limited parts records requirements.

The Import Records Package — What the FAA and Your Inspector Will Want

The airworthiness certificate is the output. Underneath it sits the evidence that lets the FAA find conformity and safe condition under §21.183(c)(3) and §21.183(d), and that lets your IA or repair station complete the §43.15 inspection. Here is the package that consistently appears in a clean used-import certification, and the rule or document it ties back to.

RecordWhy the import needs it
Foreign-registry deregistration / cancellation evidenceEligibility condition — the aircraft cannot be US-registered while registered under foreign law (§47.3(a))
US Aircraft Registration Application with citizenship certificationEstablishes a qualifying US owner and registration eligibility (§47.3, §47.7)
Evidence the model holds a US type certificate / §21.29 import type designThe type-design basis the whole certification sits on (§21.183(c)(1))
Export certificate of airworthiness from the country of exportThe State-of-Manufacture / exporting-authority attestation contemplated by (c)(2)
Conformity-to-type-design evidence including AD compliance statusRequired showing for a used aircraft (§21.183(d)(1))
§43.15 conformity inspection record by an authorized personThe hands-on airworthiness finding for a used aircraft (§21.183(d)(2))
Complete airframe, engine, and propeller maintenance records / logbooksSubstantiates conformity and condition; foreign records must reconcile to the US framework
8130-3 (or bilateral-equivalent) release tags for installed componentsEach serial-numbered item conforms to approved design and is in a condition for safe operation
Current weight and balance and equipment listDefines the configuration the aircraft is certificated in

A clean import file

  • Sequences foreign deregistration before US registration
  • Establishes the US type-design basis up front (§21.21 / §21.29)
  • Reconciles foreign maintenance records to the US logbook and AD framework
  • Carries a complete AD-status list backing the (d)(1) conformity evidence
  • Has the §43.15 inspection signed by an appropriately authorized person

What stalls a certification

  • Aircraft still on a foreign registry at the time of the US registration filing
  • Model not covered by a US type certificate — a type-design problem, not a paperwork one
  • No qualifying bilateral agreement covering the exporting country
  • Foreign maintenance records that cannot be reconciled to US AD status
  • §43.15 inspection scoped or signed by someone not authorized for it

The maintenance-records backbone here is the same one covered in the Part 91 aircraft records requirements, the weight-and-balance records requirements, the aviation records retention schedule, and the engine and propeller overhaul time tracking guide. For the airframe-level identity documents the aircraft must carry once certificated, see the ARROW documents explainer.

After the Certificate Issues: Duration and the Records That Keep It Effective

A US standard airworthiness certificate does not expire on a calendar. Under 14 CFR §21.181(a), an airworthiness certificate is effective as long as the maintenance, preventive maintenance, and alterations are performed in accordance with parts 43 and 91, the aircraft remains registered in the United States, and the certificate is not surrendered, suspended, revoked, or given a termination date by the FAA. There is no annual renewal of the certificate document itself.

For an import, that has two consequences worth planning for. First, the registration condition is continuing — if the US registration later lapses or the aircraft is re-registered abroad, the airworthiness certificate's effectiveness is affected. Second, the records you built to get the certificate are the same records that prove it stays effective: the maintenance program, the recurring inspections, and the AD-status tracking that supported the §21.183(d) conformity finding don't stop at issuance — they roll forward.

If the aircraft goes into commercial service, more rules attach

The §21.183 certificate makes the aircraft airworthy. Putting it into commercial service — for example on-demand charter — adds an entire operating-rule layer: Part 135 conformity, the operator's approved maintenance program, required records, and crew qualifications. Those are separate from the import certification and are covered in the adding an aircraft to a Part 135 certificate (conformity) guide and the Part 135 records overview.

FileFlo as the Import Records Layer

FileFlo is a compliance document intelligence platform — a read-only proof layer that organizes the records behind an aircraft import. It does not issue airworthiness certificates, register aircraft, perform §43.15 conformity inspections, validate a type design, hold any certificate, or replace your IA, repair station, customs broker, or the FAA Aircraft Certification office. What it does is classify, index, and surface the documents the certification depends on.

  • Classifies uploaded logbook entries, work orders, and release tags against the governing reference (the specific 14 CFR section, the AD, the form type)
  • Reconciles foreign maintenance records against the US logbook and AD framework, and flags gaps before the inspection
  • Tracks AD status to support the §21.183(d)(1) conformity-to-type-design evidence
  • Keeps the deregistration evidence, export certificate, type-design basis, and §43.15 inspection record together in one indexed file
  • Indexes 8130-3 component release tags and links them to the airframe and its maintenance history

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.

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Sequencing a Used Import — Why Order Matters

Most stalled imports are not stalled on a missing rule — they are stalled on order of operations. These steps interlock, and doing them out of sequence forces rework. Each one is also a record that belongs in the file.

Establish the type-design basis (§21.21 / §21.29)

Before anything else, confirm the specific model and configuration is covered by a US type certificate or was type certificated under the import provisions of §21.29. If it is not, you have a type-certification project, not a paperwork task — and the rest of the timeline depends on resolving it first.

Confirm the bilateral agreement covers the exporting country

Verify with the FAA Aircraft Certification office that an agreement with the United States exists for the State of Manufacture / country of export, so the exporting authority’s certification (§21.183(c)(2)) is acceptable. This is FAA practice, not a CFR cite — and it shapes what export documentation you can rely on.

Obtain the export certificate and reconcile the records

Secure the export certificate of airworthiness from the country of export and begin reconciling the foreign maintenance records, AD status, and component release tags to the US framework. Foreign records are often organized differently and sometimes in another language — this is the most time-consuming step, and starting it early de-risks the whole timeline.

Deregister abroad, register in the US, then certificate

Sequence the foreign deregistration so the aircraft is no longer registered under foreign law (§47.3(a)), file the US registration with the citizenship evidence (§47.7), then pursue the §21.183 airworthiness certificate — including the §43.15 conformity inspection for a used aircraft. The airworthiness finding cannot stand on a registration that has not been established.

Customs and export-control are separate tracks from airworthiness

Importing the aircraft as goods (customs entry, duties) and any export-control considerations from the country of origin are legal and regulatory tracks of their own — they are not part of 14 CFR Part 21 airworthiness certification, and must be handled with a customs broker and qualified counsel. The airworthiness certificate makes the aircraft legal to fly as a US aircraft; it does not resolve the import-as-merchandise questions.

Frequently Asked Questions

Which paragraph of 14 CFR §21.183 covers importing an aircraft into the US?

It depends on whether the aircraft is new or used, and how the records run. 14 CFR §21.183(c) is titled “Import aircraft” and sets the path for an aircraft type certificated under §21.21 or §21.29 and produced under the authority of another State of Manufacture: the State of Manufacture certifies, under the export provisions of an agreement with the United States, that the aircraft conforms to the type design and is in a condition for safe operation, and the FAA also finds that it conforms and is in a condition for safe operation. Separately, §21.183(d) is titled “Used aircraft and surplus aircraft of the U.S. Armed Forces,” and it is the route many used imports actually travel: the applicant presents evidence that the aircraft conforms to a type design (including applicable airworthiness directives) and the aircraft is inspected under the performance rules of §43.15. A used foreign aircraft frequently has to satisfy the conformity evidence and inspection of §21.183(d) on top of the import framing in §21.183(c), so identify which paragraph your specific aircraft is being certificated under before you build the file.

Can a foreign citizen register an imported aircraft in the United States?

Generally no, not as an individual foreign citizen. 14 CFR §47.3(a) allows an aircraft to be registered under 49 U.S.C. 44103 only when it is not registered under the laws of a foreign country and is owned by a citizen of the United States, by an individual citizen of a foreign country lawfully admitted for permanent residence (a resident alien), by a corporation that is not a US citizen but is organized and doing business under US law where the aircraft is based and primarily used in the United States, or by a US, state, or local government entity. So a non-resident foreign individual cannot directly register a US aircraft. In practice, foreign-connected buyers often use a qualifying US corporation or an owner trust, and §47.7 sets out the citizenship certification and resident-alien evidence the applicant must provide. Registration eligibility is the gate that comes before the airworthiness certificate — confirm it first.

Does the foreign export certificate of airworthiness let me fly the aircraft in the US?

No. The export certificate of airworthiness issued by the country of export is an attestation about the aircraft’s conformity and condition at the point of export — it is an input to the US certification process, not US operating authority. Authority to operate in the US flows from a US Certificate of Aircraft Registration under part 47 and a US airworthiness certificate issued under part 21 (for a standard certificate, §21.183). The FAA still has to find that the aircraft conforms to its type design and is in a condition for safe operation. This mirrors the export side: as the companion guide explains, a US export certificate of airworthiness under §21.325(a) likewise does not authorize operation — the importing authority issues its own certificate. The records the foreign authority relied on are exactly the records the FAA and your inspector will want to see.

What is a “bilateral airworthiness agreement” and is it part of the CFR?

A bilateral aviation safety relationship is an agreement between the United States and another country that allows each authority to accept aspects of the other’s airworthiness findings — historically a Bilateral Airworthiness Agreement (BAA), and today more commonly a Bilateral Aviation Safety Agreement (BASA) with associated Implementation Procedures for Airworthiness. The CFR text itself does not name BASA, BAA, or any specific country agreement. What §21.183(c)(2) actually says is that the State of Manufacture certifies conformity and safe-operation condition “in accordance with the export provisions of an agreement with the United States” — the existence and terms of that agreement are FAA and partner-authority arrangements, not Title 14 sections. So describe the bilateral as the mechanism that makes the exporting authority’s certification acceptable to the FAA, and confirm the current agreement and its implementation procedures with the FAA Aircraft Certification office rather than citing a CFR section for the agreement itself.

What inspection does a used imported aircraft need under §21.183(d)?

Under 14 CFR §21.183(d), the applicant presents evidence to the FAA that the aircraft conforms to a type design and to applicable airworthiness directives, and the aircraft is inspected and found airworthy in accordance with the performance rules for 100-hour inspections in §43.15. That inspection is performed by an appropriately authorized person — the rule frames it around §43.15, which ties back to the persons authorized to perform and approve such inspections (for example, an appropriately rated mechanic or repair station, or another person the rule allows). For an aircraft last registered in a foreign country, the FAA’s rule contemplates that the conformity evidence and inspection be current relative to the application. Because the exact authorized-person list and timing details turn on the specific aircraft and how it is being certificated, have a certificated IA or repair station scope the §43.15 inspection and confirm the current requirements with your FSDO before you commit to a date.

How long does the US airworthiness certificate last once it is issued?

A standard airworthiness certificate has effectively unlimited duration as long as the aircraft stays eligible. 14 CFR §21.181(a) provides that an airworthiness certificate is effective as long as the maintenance, preventive maintenance, and alterations are performed in accordance with parts 43 and 91, the aircraft remains registered in the United States, and the certificate is not surrendered, suspended, revoked, or given a termination date by the FAA. There is no annual renewal of the certificate document itself — but the privilege is conditioned on ongoing compliance and current registration. That is why the records you build at import are not a one-time package: the same maintenance, AD-status, and inspection records that get the certificate issued are what keep it effective afterward.

What records does an imported aircraft need that a domestically built one may not?

On top of the standard maintenance, AD-status, weight-and-balance, and equipment records every aircraft keeps, an import file typically adds: the export certificate of airworthiness (or export authorization) from the country of export; evidence that the aircraft is type certificated under §21.21 or §21.29 (a US type certificate or validation of the foreign type design); the State-of-Manufacture conformity certification tied to the agreement with the US (§21.183(c)(2)); conformity-to-type-design evidence including AD compliance (§21.183(d)(1)); the §43.15 conformity inspection record (§21.183(d)(2)); and the foreign-registry deregistration evidence so the aircraft is no longer registered under foreign law (a §47.3 eligibility condition). The challenge is usually that foreign maintenance records are organized differently, sometimes in another language, and have to be reconciled to the US logbook and AD framework before the FAA and your inspector will sign.

Is importing an aircraft the same as importing an engine or part?

No — they run on different rules, just like on the export side. A complete aircraft is certificated for US operation through registration (part 47) and an airworthiness certificate under §21.183. An imported engine, propeller, or article is approved on the strength of a release document showing it conforms to its approved design and is in a condition for safe operation — in practice an FAA Form 8130-3 (Authorized Release Certificate) or an equivalent release the FAA accepts under a bilateral arrangement. The standard import certificate of airworthiness under §21.183(c) is the aircraft-level counterpart to the import standard for products and articles; the component-level traceability behind any installed engine, propeller, or accessory still has to hold up on its own. The companion export guide covers the mirror image — how a US aircraft and its components leave the country on an export certificate and 8130-3 tags.

Related FileFlo Aviation Records Guides

An import certification draws on the same maintenance, airworthiness, registration, and identity records every operator already keeps. These guides cover the documents an import package depends on:

Build the import records package before the inspection, not during it

FileFlo classifies every uploaded logbook entry, work order, and release tag against its governing 14 CFR reference, reconciles foreign maintenance records to the US AD framework, tracks AD status for the §21.183(d) conformity evidence, and keeps the deregistration paperwork, export certificate, type-design basis, and §43.15 inspection record together in one indexed file. Starter plan $89/mo. Professional $299/mo. 5-day free trial — no credit card required.

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Written by Chad Griffith, Founder, FileFlo — compliance document intelligence. Reviewed June 13, 2026. FileFlo is a compliance document intelligence platform — not legal counsel, customs brokers, export-control advisers, or an A&P. Verify all import airworthiness determinations, registration eligibility questions, bilateral acceptance conditions, and current form and inspection requirements with the FAA Aircraft Certification office or your FSDO, a certificated IA or repair station, and qualified counsel.

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