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21.A.165 Obligations of the holder

Annex I · Regulation (EU) No 748/2012 · EAR revision 27 Nov 2025

IRImplementing rule

21.A.165Obligations of the holder

Pursuant to the terms of approval issued under point 21.A.135, the holder of a production organisation approval shall:

(a)ensure that the production organisation exposition furnished in accordance with point 21.A.143 and the documents to which it refers, are used as basic working documents within the organisation;

(b)maintain the production organisation in conformity with the data and procedures approved for the production organisation approval;

(c)1. determine that each completed aircraft conforms to the type design and is in condition for safe operation prior to submitting statements of conformity to the competent authority; or

2.determine that other products, parts, appliances, CMUs or CMU components are complete and conform to the approved design data and are in a condition for safe operation before issuing an EASA Form 1 to certify their conformity to approved or declared design data and that they are in a condition for safe operation;

3.additionally, in the case of environmental protection, determine that:

(i)the completed engine is in compliance with the applicable engine exhaust emissions requirements on the date of manufacture of the engine; and

(ii)the completed aeroplane is in compliance with the applicable CO2 emissions requirements on the date its first certificate of airworthiness is issued.

4.determine that other products, parts, appliances, CMUs or CMU components conform to the applicable data before issuing an EASA Form 1 as a conformity certificate;

(d)provide assistance to the holder of the type-certificate or other design approval or a natural or legal person who made a declaration of design compliance under Subpart C of Section A of Annex Ib (Part 21 Light) in dealing with any continuing airworthiness actions that are related to the products, parts, appliances, UAS, CMUs or CMU components that have been produced;

(e)where, under its terms of approval, the holder intends to issue a certificate of release to service, determine that each completed aircraft has been subjected to the necessary maintenance and is in a condition for safe operation, prior to issuing the certificate;

(f)where applicable, under the privilege of point 21.A.163(e), determine the conditions under which a permit to fly can be issued;

(g)where applicable, under the privilege of point 21.A.163(e), establish compliance with points 21.A.711(c) and (e) before issuing an aircraft with a permit to fly;

(h)comply with Subpart A of this Section.

IR · 21.A.165 — Regulation (EU) No 748/2012 · Regulation (EU) 2025/1065 · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM 21.A.165(a)Obligations of the holder – Basic working document

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Compliance with the production organisation exposition (POE) is a prerequisite for obtaining and retaining a production organisation approval. The organisation should make the POE available to its personnel where necessary for the performance of their duties. A distribution list should therefore be established. Where the POE mainly refers to separate manuals or procedures, the distribution of the POE could be limited. The organisation should ensure that personnel have access to and are familiar with that part of the content of the POE or the referenced documents, which covers their activities. Monitoring of compliance with the POE is normally the responsibility of the quality assurance function.

GM · GM 21.A.165(a) — Regulation (EU) No 748/2012 · ED Decision 2012/020/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC1 21.A.165(c)(3)(i)Obligations of the holder

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APPLICABLE ENGINE EXHAUST EMISSIONS REQUIREMENTS This determination is made according to the data provided by the engine type-certificate holder. It should be noted that the competent authority has the possibility to grant exemptions from these requirements as noted in Chapter 2, paragraph 2.1.1 and Chapter 4, paragraph 4.1.1 of Part III of Volume II of Annex 16 to the Chicago Convention. When such an exemption is granted, the competent authority: takes into account the number of exempted engines that will be produced and their impact on the environment; considers imposing a time limit on the production of such engines; and issues an exemption document. ICAO Doc 9501 ‘Environmental Technical Manual’ Volume II provides guidance on the issuing of exemptions.

AMC · AMC1 21.A.165(c)(3)(i) — Regulation (EU) No 748/2012 · ED Decision 2025/016/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

GMGuidance material

GM1 21.A.165(c)(3)(i)Obligations of the holder

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DEFINITIONS OF ENGINE TYPE CERTIFICATION DATE AND PRODUCTION DATE Volume II of Annex 16 to the Chicago Convention contains three different references to applicability dates:

1.the ‘date of manufacture for the first individual production model’, which refers to the date when the type certificate is issued for the engine type or model;

2.the ‘date of application for a type certificate’, which refers to the application date to the certificating authority of the State of Design of the engine type certification; and

3.the ‘date of manufacture for the individual engine’, which refers to the production date of a specific engine serial number (date of EASA Form 1). Point 1 refers to the date of the first engine EASA Form 1 issued after the completion of the engine production pass-off test. Point 3 refers to the date used in the application of engine emissions production cut-off requirement, on or after which all in-production engine models must meet a certain emissions standard. 21.A.165(c)(3) includes the applicable production requirements for aircraft engine emissions. ICAO Doc 9501 ‘Environmental Technical Manual’ Volume II provides guidance on these applicability dates.

GM · GM1 21.A.165(c)(3)(i) — Regulation (EU) No 748/2012 · ED Decision 2025/016/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

AMCAcceptable means of compliance

AMC1 21.A.165(c)(3)(ii)Obligations of the holder

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APPLICABLE AEROPLANE CO2 EMISSIONS REQUIREMENTS This determination is made according to the data provided by the aeroplane type-certificate holder. This data should allow the determination of whether the aeroplane complies with the CO2 emissions applicability requirements in Chapter 2, paragraph 2.1.1 of Part II of Volume III of Annex 16 to the Chicago Convention. It should be noted that the competent authority has the possibility to grant exemptions as noted in Chapter 1, paragraph 1.11 and Chapter 2, paragraph 2.1.3 of Part II of Volume III of Annex 16 to the Chicago Convention. When such an exemption is granted, the competent authority: takes into account the number of exempted aeroplanes that will be produced and their impact on the environment; and issues an exemption document. ICAO Doc 9501 ‘Environmental Technical Manual’ Volume III provides guidance on the issuing of exemptions.

AMC · AMC1 21.A.165(c)(3)(ii) — Regulation (EU) No 748/2012 · ED Decision 2025/016/R · Initial Airworthiness Easy Access Rules · EAR revision 27 Nov 2025

All rules in SECTION A — TECHNICAL REQUIREMENTS

Consolidated from the EASA Easy Access Rules (revision 27 Nov 2025, extracted 17 Aug 2026) for convenience. Not the official publication — verify against the Official Journal of the European Union and the EASA publications before operational use.

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