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Can a DAR (Designated Airworthiness Representative) or the FAA issue an 8130-3 Export Airworthiness Tag without being associated with the Product Manufacturer?

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Can a DAR (Designated Airworthiness Representative) or the FAA issue an 8130-3 Export Airworthiness Tag without being associated with the Product Manufacturer?

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No. FAR 21.323 (b) states that, “Any manufacturer may obtain an export airworthiness approval for a Class III product if the manufacturer – (1) Has in his employ a designated representative of the Administrator who has been authorized to issue that approval; and (2) Holds for that product – (i) A production certificate;(ii) An approved production inspection system; (iii) An FAA Parts Manufacturer Approval (PMA); or(iv) A Technical Standard Order authorization.” Therefore, Aircraft Parts Vendors that are not associated with the Prime Manufacturer or Manufacturers that not meet the requirements of this FAR are not entitled to receive an 8130-3 Export Tag. However, this in no way implies that the products are not airworthy. The products may still be purchased by the foreign entity and installed in their aeronautical end product after determining the part’s eligibility for installation.

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