U.S. Department 

of Transportation 

Federal Aviation

Administration

 Advisory 

 Circular

Subject: CONTROL OF PRODUCTS AND Date: 3/19/96 AC No: 21-32A

 PARTS SHIPPED PRIOR TO TYPE Initiated by: AIR-200 Change: 

 CERTIFICATE ISSUANCE 

1. PURPOSE. This advisory circular (AC) provides a means, but not the 

only means, to control products and parts shipped prior to the issuance 

of a type certificate (TC) or supplemental type certificate (STC) by a 

manufacturer with an approved production inspection system (APIS) or 

production certificate (PC). For the purposes of this AC, the acronym 

“TC” includes “STC.” This AC broadens the scope of AC 21-32, Control of 

Products and Parts Shipped Prior to Type Certificate Issuance, by 

including completed aircraft, aircraft engines, propellers, and parts 

thereof shipped prior to TC/STC issuance. 

2. CANCELLATION. AC 21-32, Control of Products and Parts Shipped Prior 

to Type Certificate Issuance, dated October 14, 1992. 

3. RELATED CODE OF FEDERAL REGULATIONS (CFR) . 

a. Title 14 CFR part 21, Subpart B, Type Certificates. 

b. Title 14 CFR part 21, Subpart E, Supplemental Type Certificates. 

c. Title 14 CFR part 21, Subpart F, Production Under TC Only. 

d. Title 14 CFR part 21, Subpart G, Production Certificates. 

e. Title 14 CFR part 21, Subpart L, Export Airworthiness Approvals. 

f. Title 14 CFR part 45, Identification and Registration Marking. 

4. BACKGROUND. Aircraft, aircraft engine, and propeller manufacturers 

must often ship completed products, detail parts, components, and 

subassemblies prior to TC issuance to support their overall TC 

programs. The guidance in this AC will facilitate TC programs as it 

contains procedures to control the configuration of urgently needed 

products and parts shipped during the TC process. It will also help the 

industry ensure that Federal Aviation Administration (FAA) approved 

parts are available for installation at the completion of the TC 

program. 
5. REGULATORY REQUIREMENTS. 

a. Applicants for type certification of aircraft engines, and 

propellers are responsible under 14 CFR part 21, section 

21.53(a), for submitting a statement of conformity to the FAA. 

b. Applicants for type certification of aircraft or parts thereof 

are responsible under section 21.53(b), for submitting a 

statement of conformity to the FAA. 

c. Manufacturers with an APIS are also responsible under section 

21.130 for submitting a statement of conformity to the FAA 

which must include: 

(1) For each product, a statement that the product conforms 

to its TC and is in condition for safe operation. 

(2) For each aircraft, a statement that the aircraft has 

been flight checked. 

(3) For each aircraft engine or variable pitch propeller, a 

statement that the engine or propeller has been 

subjected by the TC holder to a final operational 

check. 

 d. Production certificate holders are responsible for complying 

with section 21.165(b) by ensuring that each completed product and part 

submitted for airworthiness certification conforms to the approved 

design and is in a condition for safe operation. 

6. GENERAL. For any shipments prior to TC issuance, the applicant 

should submit a written proposal to the local FAA Manufacturing 

Inspection District Office requesting approval to ship completed 

products or parts thereof. Products or parts should not be shipped to 

ANY country whose authorities would prohibit the entry of FAA personnel 

into their country, or inhibit in any manner FAA activities. The 

applicant should provide assurance of access to the FAA. 

a. The proposal should include documented procedures detailing 

how the products or parts thereof will be controlled and positively 

identified consistent with paragraphs 7 and 8 of this AC. The applicant 

should give the FAA sufficient time to evaluate the viability of the 

proposal and coordinate with the Civil Aviation Authority (CAA) of 

other countries if necessary. 

NOTE: The FAA may request the CAA of the country where the 

product or part will be located to assist in conducting 

surveillance and inspections. Therefore, applicants are advised 

that certain CAAs may charge a fee for services rendered. In this 

instance, the payment of CAA fees is the responsibility of the 

applicant. The CAA of other countries may prohibit certain FAA 

activities, including functions performed by FAA designees, 

at facilities operating within their regulatory system. Any CAA 

assistance is subject to written agreements between the FAA and 

the respective CAA.
b. The proposal should include any planned use of FAA designees to 

conduct conformity inspections or make airworthiness determinations on 

behalf of the FAA. These functions would be performed on-site 

for each aircraft, aircraft engine, propeller, part, or lot of parts 

being shipped prior to TC issuance. The use of designees could be a 

factor in the FAA's approval of the proposal since the use of designees 

at a location outside the United States may alleviate an undue burden 

on the FAA. 

c. Applicants should be prepared to furnish the FAA or its 

designee with any and all design or quality control data which may be 

required to conduct conformity inspections or make airworthiness 

determinations. 

d. The proposal should include procedures to control completed 

aircraft, aircraft engines, or propellers, and parts thereof 

that are directly shipped from suppliers. 

e. Refer to paragraph 7 of this AC for additional guidance 

related to aircraft, aircraft engines, and propellers. Refer to 

paragraph 8 of this AC for additional guidance related to applicable 

aircraft, aircraft engine, and propeller parts. 

7. AIRCRAFT, AIRCRAFT ENGINES, AND PROPELLERS (PRODUCTS) . The proposal 

should contain the following as a minimum: 

a. PRIOR TO TYPE CERTIFICATION . 

(1) The procedures to track part configuration from the 

time of manufacture through the time of shipment and until the TC 

is issued. The procedures should require the use of FAA 

Form 8130-9, Statement of Conformity, to establish the status of the 

part by listing all deviations to the proposed type design. 

(2) The estimated quantity of products to be shipped and 

the destination(s) (country, facility name, address, etc.). 

(3) The reason why the products need to be shipped prior to 

TC issuance. 

(4) The approximate completion date of the TC program and 

estimated total operational hours that each product 

will accumulate prior to TC issuance. 

(5) The requirement to monitor product operation and the 

entry of inspection and maintenance activities into the product's 

records. This should include requirements to record any operation 

that occurs in excess of the product's proposed operating 

limitations. This includes parts used for static and flight tests 

that may have exceeded design limits. 

(5) The method of identifying the product with its 

airworthiness status clearly stated; e.g., “not for 

revenue service - flight test only” or “not for revenue 

service - type certificate pending.” 

(6) Method of monitoring the segregated storage and storage 

conditions of products at the destination facility. 
 (8) The facility location where the applicant will demonstrate 

that the product conforms to its proposed design and is in a condition 

for safe operation. The proposal should also include procedures 

to be used to update the product to its approved TC design, and the 

approximate date this will occur. 

NOTE: The location of this facility could be a factor in the 

FAA's approval of the proposal since a location outside the 

United States may create an undue burden on the FAA. 

(9) The proposed use of any designees to conduct conformity 

inspection on behalf of the FAA. 

b. AFTER TYPE CERTIFICATION . 

(1) Procedures for submitting FAA Form 8130-9, stating that the 

product conforms to its approved design and is in a condition 

for safe operation. The procedures should also require the 

inclusion of a statement in Block D that the product's final 

operational check was completed and date the operational 

check was conducted. 

(2) Procedures for marking the aircraft or aircraft engine data plate, 

propeller, propeller blade, or propeller hub with the TC NUMBER ONLY. 

Depending on the individual program, the product may be considered 

produced under TC only versus produced under a PC or APIS. The FAA 

will determine on a case-by-case basis the appropriate marking in 

accordance with part 45, Identification and Registration Marking. 

8. AIRCRAFT PARTS, AIRCRAFT ENGINE PARTS, AND PROPELLER PARTS . The 

proposal should contain the following as a minimum: 

a. Procedures to track the configuration of the parts from the 

time of manufacture through the time of shipment and until the TC is 

issued. The procedures should require the use of FAA Form 8130-9, to 

establish the status of the part by listing all deviations to the 

proposed type design. 

b. The method of identifying and segregating parts shipped by the 

applicant or its suppliers with direct ship authority to preclude their 

inadvertent installation on TC products prior to TC issuance. 

c. The method of monitoring the segregated storage and storage 

conditions of parts at the destination facility. 

d. The method of recall and updating parts to the current 

configuration that do not meet approved design at the time of TC 

issuance. This method, should ensure proper disposition to preclude 

installation in TC products or parts unless they are updated to the 

current configuration. 
e. The method of notifying facilities, where parts were shipped prior to TC 

issuance, concerning the approval status of parts after TC issuance. 

/s/ 

Frank P. Paskiewicz 

Acting Manager, Production and Airworthiness 

Certification Division