A KICKSTART MANUAL TO 

TRACEABILITY & CERTIFICATION REQUIREMENTS

Understanding what you need, when you need it.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

OUTLINE
01 Introduction
.........................................................................................
02 Traceability 101:  Decoding What It Is And Why It Matters
.........................................................................................
03 What Is Aircraft Part Certification?
.........................................................................................
04 5 Step Trace & Certification Process To Use On Every Purchase
.........................................................................................
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

INTRODUCTION
Why do you need to know about traceability and certifications?
Quality Assurance.

Quality assurance is very important, as it ensures the safety of you and your clients. Yet, even if you
have quality accreditations, traceability and certifications can still be incredibly confusing for a lot of
people.

From the various meanings of C of C to an ATA 106.  From 129 and foreign carrier to B2B and 135.  The
sheer amount of information alone is daunting, and to make things even worse, people often use
these terms in the wrong context.

To help clear things up and answer all your questions, we’ve set out to make a simple resource
to help you. We hope you’ll use this resource often and share it with your colleagues.
Enjoy!
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

TRACEABILITY 101: DECODING WHAT

IT IS AND WHY IT MATTERS
WHAT IS AIRCRAFT PART TRACE AND WHY DO YOU NEED IT?
Trace ensures that quality, trustworthiness, and professionalism follows aircraft material and parts
through their various supply chains. Trace is not the same as airworthiness. It’s simply a record of
where the parts have been, and when.

Unfortunately, Trace often leads to a lot of confusion.

Nobody ever seems to agree on what trace is.

End users often have their own conflicting trace rules,

buyers usually haven’t been trained in how to
communicate trace needs, and salespeople use trace
terminology quite loosely.

Associations like the Aviation Suppliers Association, ISO, and others do a great job of setting quality
standards, but there’s often still a lot of confusion on what is really needed.

TRACE IS NOT THE LAW, IT'S ONLY A SUGGESTION

U.S. law does not require any documentation that follows aircraft parts from one owner to the next.

According to Jason Dickstein, “In FAA Registry cases, for example, the courts have recognized that the way
that the law treats documentation of complete aircraft is different from the way that the law treats
documentation of aircraft parts.”

So why bother with traceability?

 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

TRACEABILITY ENSURES THAT QUALITY STANDARDS ARE BEING MET

Guidelines have been established by the FAA, EASA and various quality assurance programs to
maintain these quality standards, but they are just that - guidelines.
Here’s a great example:
"Even though most people think that back- to- birth traceability is mandatory for such parts,
the FAA has repeatedly said that U.S. law does not require back-to-birth traceability – not
even for life-limited parts. A record of current life status is sufficient to meet the
regulatory obligations of the operator. But just try to sell a life-limited part without back- to-
birth traceability! The marketplace has deemed that this is the “appropriate” paperwork for
life-limited parts, and so commercial practice has evolved such that this form of traceability
is a de facto requirement for U.S. transactions in life-limited parts. .  . Ensuring that a part
has not yet reached its life limit is an important safety obligation.”
This is where Trace comes in. Trace is an essential commercial practice that ensures quality parts are
being used.
A SIMPLE GUIDE TO ENSURE YOU'RE GETTING SUFFICIENT
TRACEABILITY
Let’s say you’re an aircraft parts distributor.
Every repair station and every air carrier you
work with has different standards for what
they’ll accept - which leads to a giant headache
for you.

With all these different quality standards being

thrown around, it becomes much more important
to create a single system for quality. It may not be
the law, but it makes much more sense to ensure
that quality products are the only products found
within your supply chain system.

Here’s a short guide that should help you make sure you’re getting sufficient traceability, according to the
FAA’s AC 20-154 “Guide for Developing a Receiving Inspection System for Aircraft Parts and Material.”
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

1.  Acceptance Of New Parts Manufactured By FAA-Certificated Sources

Receiving personnel should ensure that new parts produced by FAA-certificated sources are
accompanied by the referenced documents or other information:
1)  PC Holders.  Invoice, packing list, or equivalent documentation (normal shipping documents), stating
the part number(s) and corresponding quantities in each shipment.

2)  STC Holder.  Normal shipping documents, documentation that identifies the part as an STC part and
the production authority under which the part was produced.

3)  TSOA Holder.  Normal shipping documents documentation and/or markings that identify the part as
a TSO part.

4)  PMA Holder.  Normal shipping documentation

and/or markings that identify the part as an FAA-
PMA part. The part or packaging must be marked
“FAA-PMA.”

5)  APIS Holder.  Normal shipping documents,

other documentation and/or data plates
that identify the product as being produced under a
TC only with an Approved Production Inspection
System.

6)  Letter of Direct Ship Authority Authorization.  Evidence that authority was given to the
supplier from the PAH to ship parts directly to the customer, which may have a statement on the
purchase order stating that the part/s “were produced under FAA approved manufacturing and
quality control systems/methods as set forth in the FAA Production Certificate.”
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

2. Acceptance of New Parts From Non-FAA Certificated Sources.

Always ensure that the distributor (seller) provides sufficient documentation that shows
traceability to one of the following:
1)  A copy of shipping tickets, packing lists, invoices and/or other documents providing evidence that the
origin of the part is from an FAA PAH or that the original acquisition was from an FAA-approved source.

2)  A copy of the written letter of direct shipment authorization that includes a statement that
those parts were produced in accordance with the PAH quality system.

3)  A copy of the Certificate of Conformance (C of C) (i.e., standard parts).This certificate should

identify the acceptable standard to which the part was produced.

4)  A copy of the return to service from FAA-approved foreign repair stations and/or FAA
certificated sources.

5)  The return to service entry under part 43 maintenance record entry.

6)  A return to service record entry from an FAA-certificated air carrier operating under part 121
or 135.

3. Acceptance of Used, Repaired or Overhauled Parts from FAA Certificated

Sources.
One or more of the following should accompany parts approved for return to service procured
from FAA-certificated sources:
1)  Repair station work order.

2)  FAA Form 8130-3, Airworthiness Approval Tag,

JAA Form 1 (prior to 11/28/04), EASA Form
1 (after 11/28/04), or Transport Canada Form 24-
0078.
3) FAA Form 8130-3, Authorized Release Certificate, Airworthiness Approval Tag; J AA Form 1 ( prior to
11/28/04); EASA Form 1 (after 11/28/04); or Transport Canada Form 24-0078.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

4)  Air carriers operating under parts 121 or 135 return to service maintenance record entry; part 145 repair
station return to service maintenance record entry that the repair station is authorized to perform.

5)  Part 145 repair station return to service maintenance record entry that the repair station
is authorized to perform. 

6)  Parts/components maintained under part 43 return to service release.

4. Acceptance of Used, Repaired or Overhauled Parts from Non-FAA Certificated

Sources.
Parts procured from non-FAA certificated
sources, such as distributors, should be
accompanied by one of the following:
1)  A return to service maintenance record entry
from an FAA-certificated air carrier operating
under part 121 or 135;

2)  A return to service maintenance record entry

from an FAA-certificated air agency operating
under part 145; or

3)  The return to service entry from the certificated entity that performed the original repair or
overhaul under part 43.

5. Acceptance of Parts from Foreign Sources.

As the need to maintain aircraft and components outside the United States continues to expand, so
does the predominance of foreign-manufactured products. Receiving personnel needs to be sure they
receive the proper documents to accompany any parts repaired or manufactured by foreign sources.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

6. Acceptance of Life-Limited or Time-Controlled Parts From Any Source.

Procedures for accepting life-limited or time-controlled used parts into an inventory system require
special attention due to safety ramifications.  

In addition to the documentation listed in paragraphs 8(a), (b), (c), or (d) receiving inspection personnel
should ensure that life-limited and time-controlled Par 7 Page 15 AC 20-154 12/12/05 parts are
 accompanied by the following documentation to substantiate the time remaining on the part:

1) The accumulated total time or remaining

hours, cycles, and/or calendar times, whichever
time
limit applies to the part;

2)  Ad Status;

3) Modification status (i.e., service bulletins,

technical bulletins), if applicable

4) All major repairs, alterations, and

modifications, which may have been
accomplished; 
5) Any usage/storage history, which may result in an adjustment to the remaining life of the part; and

6) Record of work accomplished during the last maintenance, repair, overhaul, or alteration performed.

SO WHAT DOES DO 121, 129, 135, & 145 MEAN?

If you’ve been in aviation long enough, you’ve seen your fair share of these numbers. These
numbers give you an idea of what FAA regulated source your aircraft material came from.
Let’s define each:
•  OEM (Original Equipment Manufacture):  Trace goes back to the OEM. It either came from the OEM
direct or through a distribution partner. If it’s traced back to the OEM you’ll always receive an OEM
certificate of conformance (C of C) but you are not guaranteed to always get an 8130.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

•  121:  Trace will come from a United States domestic airline.

•  129:   Trace will come from a foreign air carrier permitted to operate in the United States.

•  FC (Foreign Carrier): Trace will come from a foreign air carrier not permitted to operate in the United
States.

•  135: Trace will go back to a charter airline with unscheduled routes.

•  145: Trace will go back to an MRO operation. The term “repair station” refers to a maintenance facility
that has a certificate issued by the Federal Aviation Administration (FAA) under Title 14 of the Code of
Federal Regulations (14 CFR) Part 145 and is engaged in the maintenance, preventive maintenance,
inspection, and alteration of aircraft and aircraft products.

•  B2B: Trace will go back to birth records.

If you’d like to know more or go deeper into this topic, you can always read more about it from Aviation
Suppliers Association.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

WHAT IS AIRCRAFT PART

CERTIFICATION?
Just like aircraft part trace, knowing what type of certifications you need for your parts can be downright
maddening. Every operation is different, making it difficult to apply the same QA  standards to everyone.

It’s incredibly frustrating to spend hours sourcing and processing material orders, only to find out
that the certifications you received were completely wrong.To give you a hand, we’ll define what the
various certifications are, and some quick tips to use with your trusted material advisor.

WHAT DOES IT ALL MEAN? DEFINING AIRWORTHINESS, C OF C, &

MATERIAL CERTIFICATION
Airworthiness
What exactly is airworthiness?

According to the FAA Part 21, an airworthiness certification is “…a document, issued by the FAA for an aircraft,
aircraft engine, propeller, or article, which certifies that the aircraft, aircraft engine, propeller, or article conforms
to its approved design and is in a condition for safe operation, unless otherwise specified.”
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

An airworthiness certificate can come in many forms but the most common are FAA 8130 and an EASA Form 1.

All overhauled, repaired, inspected or modified components must come with an airworthiness
certificate. But not all expendables are required to do so.

Certifiate Of Conformity / Compliance / Conformance

A Certificate of Conformance is not the same as a Material Certificate.
OEMs are the predominant providers of Certificate of Conformance but suppliers, like Skylink, will
provide a Material Cert.

As Roy Resto says...

"When someone attests that an airplane, assembly, part, repair, or alteration conforms, they are
generally stating that it conforms to one or a combination of the following:

Drawings
Specifications
Approved Instructions
Industry Standards or Approvals
Aviation Regulations
Company Standards
Government Approvals”

In the aircraft parts world, the characteristics of

a Certificate of Conformity are usually:
They are issued by a manufacturer. (Note: some distributors, such as those with extensive
fastener sales, are equipped to make determinations of conformity. But the vast amount of
Certificates of Conformity are issued by the manufacturer.
They state that the part conforms to some of the subjects cited above
They are signed
The person signing is ‘authorized’ by the manufacturer to do so.
They are indeed most valuable as the document to determine airworthiness.”
Make sure you go back and read the rest of this post. It’s worth your time if this is a topic you
struggle with.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

Material Certification
A material certification states that a supplier certifies, to the best of its knowledge, that the
material being produced has not been submerged in water, been in a fire, been exposed to extreme
conditions, and or been sourced by a military source. It essentially states that the material has not
been compromised in any way.

As Roy Resto points out, “some suppliers such as Distributors, Brokers, or Stockists use the term Certificate of
Conformity on their own documentation, but they have not, nor are equipped to make such
determinations of Conformity. In referring to their own documents, some distributors use the term C of
C, when they should be using the term “Material Cert.” (Such as an ATA Spec 106 cert.).”
QUICK TIPS TO AVOID CERTIFICATION ISSUES
Know Your QA Policies
Most organizations have policies around what they can and cannot accept, and it’s important that you
familiarize yourself with these policies.
Clearly Articulate Your Needs To Your Trusted Material Partners
Knowing what you need is half the battle. Clearly communicating those needs is the other half. Be
clear and specific.
Remind your trusted material advisers: It’s also very important they communicate on their end. They
should be clarifying to ensure you’re both on the same page: “will any 8130 suice (i.e. DAR or 145) or do
you need a specific variant, like an OEM 8130?
Your Trusted Material Partner Should Be Clear In What They're Providing You 
It’s important that both you and your material partners are on the same page. If anything is unclear on
their quotes or order confirmations, make sure they specify that it is important to you. You want to catch
any mistakes or be aware of any issues before the material arrives.

Know what you need, communicate those needs, and avoid potential issues - before they become an
issue.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

5 Step Trace & Certification Process

To Use On Every Purchase
Here are some important steps to follow to make sure you’re getting proper traceability and
certification on every purchase.
STEP 1: DEFINE REGULATED SOURCE
A regulated source is a company who has oversight from an airworthiness body.
Skylink defines regulated sources as:

1) Original Equipment Manufacturers (OEMs)

2) All scheduled airlines and operators, including freight carriers (121, 129, 135, & foreign carrier).

3) Major airframe and powerplant certified repair stations (FAA, JAA, EASA, TC or CAAC) whose
capability allows them to perform C & D checks, repair or modify the aircraft structure, or repair the
major modules of an engine.
4) Certified Component Repair Stations (FAA, JAA, EASA, TC or
CAAC), provided the material they’re
supplying is within the repair capabilities of their Air Agency
Certificate.

Non-regulated sources include surplus parts suppliers,

dealers, brokers, leasing companies, or repair stations who
sell material outside of their repair capabilities.

STEP 2: DETERMINE ACCEPTABLE TRACE & CERTIFICATION FOR

AIRCRAFT PART CONDITIONS
 Factory New (FN) Part Manufactured By Regulated Sources
The original certification from the OEM. Appropriate documentation includes one or a combination of the
following: FAA Form 8130-3, EASA Form 1, JAA Form 1, SEG VOO 003, TC Form 1, Certificate of Confomance,
Packing Slip, Transfer Ticket or Invoice.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS
PC Holders:  Invoice, packing list, or equivalent documentation (normal shipping documents),
stating the part number(s) and corresponding quantities in each shipment.

TC Holder:  Normal shipping documents, documentation that identifies the part as an STC part,
and the production authority under which the part was produced.

TSOA Holder:  Normal shipping documents, documentation and/or markings that identify the
part as a TSO part.

PMA Holder:  Normal shipping documentation and/or markings that identify the part as an
FAAPMA part. The part or packaging must be marked “FAA-PMA.”

APIS Holder:  Normal shipping documents, other documentation and/or data plates that identify
the product as being produced under a TC only with an Approved Production Inspection System.
Letter of Direct Ship Authority Authorization: Evidence that authority was given to the supplier
from the PAH to ship parts directly to the customer, which may have a statement on the purchase
order stating that the part/s “were produced under FAA approved manufacturing and quality
control systems/methods as set forth in the FAA Production Certificate.”
New Parts From Non-FAA Certificated Sources
A copy of shipping tickets, packing lists, invoices
and/or other documents providing evidence that
the origin of the part is from an FAA PAH or that the
original acquisition was from an FAA-approved
source.

A copy of the written letter of direct shipment

authorization that includes a statement that those
parts were produced in accordance with the PAH
quality system.
A copy of the Certificate of Conformance (C of C) (i.e., standard parts). This certificate should
identify the standards to which the part was produced.

A copy of the return to service from FAA-approved foreign repair stations and/or FAA certificated
sources.

The return to service entry under part 43 maintenance record entry.

A return to service record entry from an FAA-certificated air carrier operating under part 121 or
135.
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

New Surplus From A Non-Regulated Source

You’ll want some certification & traceability back to a regulated source to verify that it is new.
Appropriate documentation may include one or a combination of the following: FAA Form 8130-3, EASA Form 1,
JAA Form 1, SEG VOO 003, TC Form 1, Certificate of Conformance, Packing Slip, Transfer Ticket, and a
material certification form that meets the requirements of ATA Spec 106 or other industry accepted certification.

Overhauled, Repaired, Inspected or Modified

Certification & traceability back to the last operator and/or regulated source, including a non-
incident/non-military statement.

Original material certification form that meets the requirements of ATA Spec 106 or other industry
accepted certification stating the part is in the same condition as listed on the Authorized Release
Certificate

The original FAA Form 8130-3, JAA Form 1, EASA Form 1, CAAC AAC-038, SEG VOO 003 or TC Form 1
(Dual FAA/EASA or JAA release)issued by a repair facility that is approved to perform the repair by
the relevant airworthiness regulatory authority;

Details of work performed or teardown report, including Service Bulletins (SB) number,
Modification number or Airworthiness Directives (AD), with revision number and date;

Name of the service manual and/or part number or ATA chapter reference used to perform the
repair and the revision level and revision date of the manual; and,
 A KICKSTART MANUAL TO TRACEABILITY & CERTIFICATION REQUIREMENTS

STEP 3: COMMUNICATE WHAT YOU NEED WITH YOUR TRUSTED

MATERIAL SUPPLIERS
Once you’ve established what you can accept for various aircraft part conditions, notify your trusted
material partners. Hopefully, they were a part of the discussion before you made any changes.
STEP 4: BE CLEAR ON YOUR PO’S
Communication is important. Even when you do tell your supplier what trace and certification
requirements you can accept, it’s always best to put such requirements on your PO.
It seems redundant, but it serves as a reminder. Do the same with your RFQs. State what’s acceptable
and what’s not. You’ll save a lot of time and money if you avoid having to reject material long before
it even gets to you.
STEP 5: REFINE YOUR SYSTEMS
Things change. Update your systems.
Work with your trusted material partners in order to update your systems. You need them and they
need you. Be a partner. Communicate. You’ll see the quality of your material increase - and your
rejection rate decrease.

Tools to help make your aviation life easier!

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