FAA Guidance Highlights Foreign Issuance of 8130-3 Tags

What about aircraft parts that are already outside the United States, but that do not bear an 8130-3 tag? In addition to the changes to permit easier access to class III export 8130-3 tags (see last paragraph), the FAA has also added new guidance to implement the recent regulatory change that permits 8130-3 tags to be issued outside the United States.

Order 8130.21E change two has added new language to explicitly permit DARs to issue 8130-3 tags outside the United States. Before this year, 8130-3 tags could not be issued outside the United States unless the applicant had obtained a special exemption from the regulations. Such exemptions had been issued to a number of large companies. The FAA decided to eliminate this limitation in light of the wide range of exemptions that were being issued.

Under the new guidance, designees will still need to apply for geographic expansion in order to obtain the privilege of issuing 8130-3 tags outside the United States. This will require the designee and/or the 8130-3 applicant to file for a no-undue-burden finding with the FAA. Although the FAA has published parameters for making such a finding in the case of a manufacturer-applicant, the FAA does not yet have published parameters for no-undue-burden findings for designees who wish to issue 8130-3 tags for overseas distributors.