Importing an Aircraft From the U.S. Into the EU: EASA Registration, Airworthiness and VAT

Buyers in Europe import U.S. aircraft for a simple reason: the U.S. market offers far more choice, particularly for popular types such as the Cessna 182, Piper PA-28, Beechcraft Bonanza and Cirrus SR22. To import an aircraft from the USA to Europe, though, you deal with two regulatory systems and a tax system at once. The airplane has to leave the FAA register with an export certificate that satisfies EASA. It has to clear customs and import VAT in an EU member state. And it has to be registered and certified by that member state’s aviation authority before it can fly on its new registration.

This guide explains who does what, the order that works, what VAT does to the total cost and where imports most often get stuck. It covers EU member states. The UK and Switzerland have their own processes. Importing is also not the only route: many European owners keep the airplane on the U.S. register through an owner trust instead, as explained below.

Who Does What in the EU

• EASA sets the common rules and approves designs, including the validation of U.S. type certificates and STCs. It does not register aircraft.
• The national aviation authority of the member state where the airplane will be registered, such as the LBA in Germany or the DGAC in France, registers the airplane and issues its certificate of airworthiness and noise certificate.
• A continuing airworthiness organization, a CAMO or CAO approved for the type, performs the airworthiness review for an imported used airplane and recommends the certificates. For light aircraft such as the SR22, the continuing airworthiness rules are in Part-ML.
• Customs in the member state where the airplane is declared for import collects import VAT and handles any duty.

Before You Buy: Confirm the Airplane Can Be Imported

Three checks prevent most problems:

Modifications. Under the EU-U.S. Technical Implementation Procedures, the airplane must conform to its type design as modified by STCs and design changes that EASA has validated or accepted. Factory configurations of common types, from a Cessna 172 to a Cirrus SR22, are generally straightforward. For aftermarket STCs, check whether EASA has already validated each one. Simpler STCs can often be validated for a single airplane through a streamlined process, but it takes time and is best started before purchase.

Airworthiness directives. The FAA export certificate must certify compliance with all applicable EASA ADs, not just FAA ADs. Ask your CAMO or CAO to compare the airplane’s AD records with the EASA list before you commit.

Equipment. Confirm the radios support 8.33 kHz channel spacing, which EU rules have required of VHF voice radios since the end of 2017, with limited national exceptions, that the transponder is Mode S, and that the ELT is a 406 MHz unit that can be recoded. On any make, the age of the panel is the best guide to what needs attention. Using the Cirrus SR20, SR22 and SR22T as an example:

Our equipment check by Cirrus generation covers each era in more detail.

Our guide to buying an aircraft in the U.S. from overseas covers the purchase itself: records review, the pre-buy and escrow.

Step by Step

1. Choose the member state and the CAMO or CAO

Decide where the airplane will be registered and which continuing airworthiness organization will manage the import. The organization will tell you what it needs to see and will normally work with the U.S. shop doing the pre-buy and export inspection.

2. Obtain the FAA Export Certificate of Airworthiness

The U.S. side inspects the airplane to the EU’s requirements and issues FAA Form 8130-4. Under the Technical Implementation Procedures, the airplane must also come with its approved flight manual and all supplements, placards, a current weight and balance report, an equipment list, its instructions for continued airworthiness and noise certification information. Any exception noted on the export certificate requires the importing authority’s written acceptance in advance. Our guide to exporting an aircraft from the U.S. covers this step and the FAA deregistration.

3. Deliver the airplane

Most piston singles bound for Europe are ferried across the North Atlantic on their U.S. registration. See our guide to ferrying or shipping an aircraft overseas.

4. Clear customs and pay import VAT

The airplane is declared for release into free circulation in the member state where it enters the EU, normally through a customs agent. Civil aircraft can generally be imported free of customs duty under the EU’s civil aircraft relief, which the agent claims with the aircraft’s registration certificate. Import VAT is a different matter: on an airplane imported for private use, it is due at the rate of the member state of import.

5. Register the airplane

The national authority registers the airplane once it has evidence of ownership, evidence that the FAA registration has been cancelled for export and the other documents it requires, which commonly include proof of insurance. Under EU Regulation 785/2004, an airplane with a maximum takeoff mass under 2,700 kg, which includes most single-engine piston airplanes such as a Cessna 182, a Bonanza or an SR22, needs third-party liability insurance of at least 3 million SDR. The airplane receives its new registration marks and, with them, a new Mode S address.

6. Airworthiness review, certificate of airworthiness and ARC

For a used airplane imported from outside the EU, the owner applies to the national authority for a new certificate of airworthiness and has an airworthiness review carried out by an approved organization, with all maintenance done to the airplane’s maintenance program. The organization sends its recommendation to the authority, which may attend the review. The authority then issues the certificate of airworthiness and an airworthiness review certificate, the ARC, normally valid for one year. A noise certificate is issued as well.

7. Recode, license and fly

Reprogram the transponder and ADS-B equipment with the new Mode S address, recode and register the ELT in the new country, obtain the aircraft radio license from the national telecommunications authority and update navigation databases to the European coverage region.

Importing a Vision Jet Into the EU

A Cirrus SF50 Vision Jet follows the same import steps, but under EU rules any airplane with a turbojet engine is a complex motor-powered aircraft, whatever its weight. That brings three additional requirements:

• Part-NCC. A private operator of a complex airplane must declare the operation to its national authority under Part-NCC, with an operations manual, a training program, a management system proportionate to the operation and an approved minimum equipment list.
• A CAMO. The lighter Part-ML continuing airworthiness rules do not apply to complex airplanes, so the airplane is managed by a continuing airworthiness management organization.
• Type rating. Pilots need the Vision Jet type rating on their EASA license.

Plan these with your CAMO and national authority before purchase, alongside the export and VAT steps. Confirm too how the airplane’s JetStream and engine program coverage will be supported in Europe.

Import VAT: The Largest Line in the Budget

For a private buyer, import VAT is usually the largest single cost after the airplane itself. It is calculated on the customs value, which generally includes the price plus transport and insurance costs to the point where the airplane enters the EU. Standard VAT rates in some of the larger European markets:

VAT-registered businesses that use the airplane for taxable business activity may be able to recover import VAT, and some structures are designed around that. These are tax questions specific to your country and situation, so take advice before the airplane arrives, because the import declaration fixes who the importer is.

A Landed-Cost Example

An illustrative example for a private buyer importing a used SR22T into Germany, in U.S. dollars. These are not quotes. Replace each line with your own figures.

That landed cost, not the U.S. price, is the number to compare with VAT-paid airplanes already in Europe. Sometimes the U.S. airplane is clearly better value. Sometimes a European airplane with VAT already paid is the better buy, even at a higher asking price. Ask exactly what “VAT paid” means on a listing: since Brexit, EU VAT-paid and UK VAT-paid are separate statuses, and an airplane moving between the UK and the EU is normally treated as a new import.

Running costs change too. On an EASA register, the airplane needs a maintenance programme and an annual airworthiness review. Private owners of airplanes such as a Cessna 182, a Bonanza or an SR22 can manage this themselves under Part-ML, but most contract a CAMO or CAO to do it, which is a recurring cost to include in the budget.

Keeping the Airplane on the U.S. Register Instead

Some European owners keep their airplanes N-registered, usually through an owner trust. It avoids the EASA import process but not EU rules on pilot licensing for residents, and it does not change VAT, which is due on import whatever the registration. Maintenance must then be done to FAA standards by appropriately certificated mechanics, which narrows the choice of shops in some countries, though the airplane does not need the Part-ML programme and airworthiness review of an EASA-registered one. It is a legitimate option with real trade-offs, best decided with a specialist before purchase.

Where EU Imports Get Stuck

An STC EASA has not validated, discovered after purchase.

EASA ADs that differ from FAA ADs and were not checked before the export inspection.

Records that do not support the airplane’s status to the standard the airworthiness review requires.

VAT surprises, from not budgeting for it to declaring the import in the wrong name or country.

Timing: deregistering in the U.S. before the airplane has arrived, or arriving before the CAMO and authority are ready.

Frequently Asked Questions

Do you pay VAT when importing an aircraft into the EU?

Yes. Import VAT is due at the rate of the member state of import, calculated on the customs value, which generally includes transport and insurance to the EU border. VAT-registered businesses may be able to recover it. Civil aircraft can generally be imported free of customs duty.

Who issues the certificate of airworthiness for an imported aircraft in the EU?

The national aviation authority of the member state of registry, after an airworthiness review by an approved continuing airworthiness organization. It also issues the airworthiness review certificate, normally valid for one year.

Can any U.S. aircraft be imported into the EU?

Only if its type design and every installed STC and design change are validated or accepted by EASA, and it complies with all applicable EASA airworthiness directives. Popular factory configurations, such as standard Cessnas, Pipers, Bonanzas and Cirrus SR22s, are generally straightforward. Aftermarket modifications should be checked before purchase.

How long does it take to import an aircraft into the EU from the USA?

For a well-prepared airplane, commonly six to twelve weeks from purchase to flying on European registration, including export, ferry, customs, registration and the airworthiness review. Unvalidated modifications and record gaps add time.

The Bottom Line

Importing an aircraft from the USA to Europe works smoothly when the European side is involved from the start. Choose the member state and continuing airworthiness organization first, check modifications and EASA ADs before purchase, budget for import VAT and keep the airplane on its U.S. registration until it has arrived.

Aerista helps European buyers with every step on the U.S. side, from the search and records review through the pre-buy, closing, export and ferry, and works alongside your CAMO or CAO at home. Tell us what you are looking for, or browse the Aerista showroom.