Exporting an Aircraft From the U.S.: Deregistration, Export Airworthiness and Customs, Step by Step

To export an aircraft from the U.S., four things have to happen, mostly in parallel. The airplane needs an FAA Export Certificate of Airworthiness that meets the importing country’s requirements. Its U.S. registration has to be cancelled for export. The export has to be reported to U.S. Customs and cleared against export controls. And the airplane has to physically reach its new country with the right paperwork, radio licensing and equipment coding on board.

None of these steps is especially hard. Most export problems come from doing them in the wrong order, or from finding out late that the destination country wants something the airplane does not have. This guide walks through each track, the order that works and the mistakes that cost buyers and sellers the most time. The examples are Cirrus aircraft, from the SR20, SR22 and SR22T to the Vision Jet, but the process applies to most U.S.-built airplanes.

The Process at a Glance

Start With the Importing Country, Not the Export Inspection

The FAA does not export airplanes to a generic standard. An Export Certificate of Airworthiness certifies that the airplane meets the requirements of the specific country importing it. The FAA publishes those requirements country by country in Appendix 2 of Advisory Circular 21-2, “Special Requirements of Importing Authorities.” Where the U.S. has a bilateral agreement with the importing country, the agreement and its implementation procedures take precedence over the appendix.

The differences between destinations are real. Two examples:

• European Union. Under the EU-U.S. Technical Implementation Procedures, the FAA certifies that the airplane conforms to its type design as modified by STCs and design changes that EASA has validated or accepted, and that it complies with all applicable EASA airworthiness directives, not just FAA ADs. The airplane also needs its approved flight manual with all supplements, a current weight and balance report, an equipment list and noise certification information.
• Australia. Australia’s published requirements accept the FAA Form 8130-4, require compliance with all applicable FAA ADs before it is issued, with the next due point shown for recurring ADs, and require any flight manual supplement associated with an STC.

The single most common surprise is a modification the destination authority has not accepted. A factory-equipped Cirrus is usually straightforward because the type design and factory options are validated in the major markets. Aftermarket STCs are where problems start. Before the export inspection, list every STC and Form 337 alteration on the airplane and confirm each one is accepted by the importing authority. Under the EU procedures, many simpler STCs can be validated for a single airplane through a streamlined process, but that takes time and should be started early, not discovered at the inspection.

The Export Certificate of Airworthiness

The exporter, normally the seller or an authorized representative, applies on FAA Form 8130-1, and the FAA or an FAA designee inspects the airplane and its records. In practice, most used-aircraft export certificates are handled by Designated Airworthiness Representatives, because they can schedule the inspection around the airplane rather than the other way around. The rules are in 14 CFR Part 21, Subpart L.

The inspection is not a pre-buy, and it is not an annual. It answers narrower questions:

• Does the airplane conform to its type design and to every STC and alteration installed?
• Is it in condition for safe operation, with every AD required by the importing country complied with?
• Do the records support the airplane’s status, including overhauls, major alterations and major repairs?
• Are the flight manual and supplements, weight and balance, equipment list and any other documents the destination requires on hand?

If the airplane does not fully meet a requirement, the FAA can list it as an exception on the certificate, but only with the importing authority’s written acceptance obtained in advance. Plan to fix discrepancies rather than export them.

Two points trip people up. First, the Form 8130-4 does not authorize flight. While the airplane is still N-registered, it flies on its U.S. standard airworthiness certificate. Second, that standard certificate is only effective while the airplane remains registered in the United States. Cancel the registration too early and the airplane cannot legally be ferried on it.

Budget for the designee’s fee, which is typically in the low thousands of dollars plus travel, and for the time and cost of correcting whatever the inspection finds. A clean annual and a thorough pre-buy, both done shortly before the export inspection, make it much faster. Our aircraft pre-buy inspection checklist covers what that inspection should include.

Cancelling the U.S. Registration for Export

The FAA Aircraft Registry cancels a registration for export on a written request. The request can come from the last registered owner, from the foreign purchaser with evidence of ownership or, for aircraft covered by the Cape Town Convention, from a party holding a registered IDERA. It must include:

• The registration number, manufacturer, model and serial number.
• The reason, stated as cancellation for export, and the name of the destination country.
• The requester’s signature and title. A pilot or agent signing for the owner needs a power of attorney.
• A release, or a consent to export, for every recorded security interest, and for any recorded lease of six months or more.

The Registry processes exports on a priority basis and asks that the request and envelope be marked “Export” in red. It then notifies the importing country of the cancellation.

The lien requirement is where exports stall. Many airplanes have an old loan that was paid off years ago but never released at the Registry. The aircraft cannot be cancelled for export until the original lender, or its successor after a bank merger, signs a release. A title search at the start of the transaction finds these, and an escrow company can usually obtain the release while the rest of the export proceeds.

Timing. Most airplanes that are ferried are deregistered after they arrive, because they need their U.S. registration and airworthiness certificate to fly there. Many importing authorities will not complete registration until they have confirmation of the U.S. cancellation, so the two have to be coordinated. Ask the importing authority, or your import agent, what evidence it needs and in what order before the airplane departs.

Vision Jet owners: a Cirrus SR-series airframe is too small to fall under the Cape Town Convention, but the Williams FJ33 engine on the SF50 exceeds the Convention’s thrust threshold for aircraft engines. Have the escrow company search the International Registry as well as the FAA Registry, and discharge any registered interests before export.

Customs Filing and Export Controls

A permanent export, meaning a sale to a foreign buyer with the airplane leaving the country, has to be reported through the Automated Export System as Electronic Export Information. That applies whether the airplane is shipped or flown out under its own power. The filing is normally the responsibility of the U.S. principal party in interest, usually the seller, and is often handled by a customs broker. It must be filed before the airplane departs, and the resulting Internal Transaction Number goes on the export paperwork. The Foreign Trade Regulations set the details. A temporary trip abroad, where the airplane comes back and no ownership or operational control changes, does not require a filing.

On export controls, most civil piston airplanes are classified under ECCN 9A991.b and can be exported to most countries without a license. The exceptions are the important part. Exports to embargoed or sanctioned countries, to people or companies on U.S. restricted-party lists, or for prohibited end uses are not allowed. Screen the buyer, the beneficial owner and the intended operator before title transfers. Evasiveness about who will own or operate the airplane, or a request to ship to a third country, is a red flag worth stopping for.

Penalties for getting this wrong include fines and, in serious cases, seizure of the aircraft. The purchase agreement should say which party is responsible for each export filing and who pays for it.

Registration Marks, Radios and Beacons

A change of country also changes how the airplane identifies itself:

• Mode S and ADS-B. The transponder’s 24-bit aircraft address is assigned by the state of registry. When the airplane is registered in its new country, it receives a new address, and the transponder and ADS-B equipment must be reprogrammed to match the new registration.
• 406 MHz ELT. A 406 MHz beacon is coded for a country and registered in that country’s beacon database. Plan to recode and re-register it for the new registry.
• Radio licensing for the ferry. A U.S.-registered aircraft flying to another country needs an FCC aircraft radio station license, and the pilot needs an FCC restricted radiotelephone operator permit. AOPA’s summary explains both.
• Destination equipment. Some regions require equipment the U.S. does not, such as 8.33 kHz radio channel spacing in much of Europe. Confirm the airplane’s installed equipment against the destination’s requirements before purchase, not after arrival.

What the Purchase Agreement Should Cover

A domestic purchase agreement is not enough for an export. Add clear answers to these questions:

• Where does delivery take place, and when do title and risk of loss pass to the buyer?
• Who orders and pays for the Export Certificate of Airworthiness, and who pays to correct what it finds?
• Who is responsible for the customs filing and export-control screening?
• Who requests the registration cancellation, and when?
• Which documents are delivered with the airplane: records, flight manual, supplements, keys, software and database subscriptions?

Sales tax depends on the state where delivery takes place. Many states exempt or reduce tax on aircraft that leave the state promptly after purchase, including for export, but the conditions vary widely. Choose the delivery location with a tax advisor, before the agreement is signed. Our article on aircraft broker vs. private sale covers why escrow and transaction management matter even more when the buyer is overseas.

How Long Exporting Takes

A well-prepared export of a piston single typically takes two to six weeks from signed agreement to departure. The variables are almost always the same:

• Unreleased liens can add weeks if the original lender is hard to reach.
• STC acceptance at the destination can add weeks or months if a modification needs validation.
• Inspection findings add whatever time the repair takes.
• Delivery by ferry flight usually takes days to a couple of weeks depending on route and weather; container shipping takes longer.

Common Export Mistakes

Cancelling the registration before the ferry flight. The airplane loses its U.S. airworthiness certificate with its registration.

Inspecting to FAA standards only. The destination’s ADs and STC acceptance rules decide whether the airplane can be imported.

Ignoring old liens. A release from a lender that no longer exists under its old name can take longer than everything else combined.

Treating the customs filing as optional because the airplane is flying out rather than being shipped.

Assuming the records are complete. Importing authorities want proof of overhauls, major alterations and major repairs. Missing Form 337s and incomplete AD records are easier to fix in the U.S. than after the airplane has left.

Frequently Asked Questions

Do I need an export license to sell my airplane to a foreign buyer?

Usually not. Most civil piston aircraft are classified under ECCN 9A991.b and can be exported to most countries without a license. Exports to sanctioned countries or restricted parties are the exception, so screen the buyer and end user before closing.

Can an aircraft fly on its Export Certificate of Airworthiness?

No. FAA Form 8130-4 does not authorize operation. A ferried airplane normally flies on its U.S. registration and standard airworthiness certificate, which is why the registration is usually cancelled after arrival.

Who files the export paperwork with U.S. Customs?

The U.S. principal party in interest, usually the seller, or a customs broker acting for it, files Electronic Export Information through the Automated Export System before departure. The purchase agreement should say who is responsible.

How long does it take to export an aircraft from the U.S.?

Typically two to six weeks for a well-prepared piston airplane, longer if old liens must be released, an STC needs validation in the destination country or the export inspection finds significant discrepancies.

The Bottom Line

Exporting an aircraft from the U.S. is a sequence of ordinary steps that only becomes difficult when they are done out of order. Confirm the destination’s requirements first, clear title early, inspect to the importing country’s standard, file the customs paperwork, and keep the airplane registered until it no longer needs to fly on its U.S. certificate.

Aerista works on both sides of international sales, finding airplanes for buyers abroad and selling U.S. airplanes to foreign buyers, and can guide you through the export steps alongside the specialists who handle them. If you are buying or selling across a border, contact us and we can walk through your situation.