It started with a minor part—an alternator bracket. Jack, a seasoned pilot and aircraft owner, decided to have one custom-fabricated after the OEM version broke. His local A&P mechanic approved the design, and it was installed without issue. Months later, during an FAA ramp check, Jack learned the hard way that not all “owner-produced” parts are treated equally. Despite good intentions, he found himself entangled in a compliance investigation. Jack’s story underscores a crucial distinction in aviation maintenance: FAA-approved parts vs. owner-produced parts.
Understanding the Stakes: Why Part Compliance Matters
Aircraft owners are legally responsible for the airworthiness of their aircraft. The Federal Aviation Administration (FAA) enforces strict guidelines under 14 CFR Parts 21 and 43 to ensure replacement parts meet safety and design standards. According to a 2023 Aircraft Electronics Association (AEA) report, non-compliant parts were linked to over 30 enforcement actions and several safety incidents in the past five years.
FAA-compliant parts ensure traceability, airworthiness, and conformity to certified aircraft designs. Owner-produced parts, while legal in certain contexts, introduce a gray area that requires careful navigation.
FAA-Approved Parts: The Gold Standard
What Qualifies as an FAA-Approved Part?
FAA-approved parts must follow one of several certification pathways:
- Parts Manufacturer Approval (PMA)
- Technical Standard Order (TSO)
- Supplemental Type Certificate (STC)
- Type Certificate or Production Certificate from OEMs
These parts are manufactured under strict FAA oversight, with documentation that includes airworthiness tags (e.g., Form 8130-3) and detailed traceability.
Benefits of FAA-Approved Parts
- Full regulatory compliance
- Better insurance support and resale value
- Reduced risk of enforcement action
- Peace of mind for high-use or commercial aircraft
Owner-Produced Parts: Legal but Limited
What Are Owner-Produced Parts?
Per 14 CFR § 21.9(a)(5), an owner can produce a part for their own aircraft if:
- The part is not for resale
- The owner participated in its design or manufacture
- The part meets the form, fit, and function of the original
- The installation is done or supervised by a certified mechanic
Examples include brackets, baffles, or other non-critical components. However, anything affecting structural integrity or flight controls may trigger additional scrutiny.
Documentation Requirements
Owner-produced parts do not receive Form 8130-3 tags. Instead, they rely on documentation of the owner’s involvement (e.g., sketches, purchase orders for raw materials, and records of consultation with a mechanic).
Risks and Drawbacks
- No resale or use on other aircraft
- No formal FAA paperwork
- Difficult to prove compliance during audits or ramp checks
- May affect airworthiness determinations and insurance claims
What Aircraft Engineers Should Know Before Sourcing Parts
For those involved in maintenance, procurement, or engineering roles, what aircraft engineers should know before sourcing parts goes beyond choosing between OEM and aftermarket. It includes understanding FAA approval pathways, recordkeeping practices, and how parts impact long-term aircraft value and compliance.
When Owner-Produced Parts Make Sense
In some situations, they are a practical solution:
- Legacy aircraft with discontinued OEM parts
- Remote operations where delivery delays compromise safety
- Unique modifications for experimental aircraft (with mechanic oversight)
Still, aircraft owners must weigh the trade-off between cost and long-term regulatory exposure.
FAA Oversight and Real-World Examples
According to the FAA’s Suspected Unapproved Parts (SUP) Program, several cases each year involve parts incorrectly claimed as owner-produced. In one 2022 case, a piston aircraft operator installed several homemade exhaust components without A&P oversight. An FAA audit led to the aircraft’s temporary grounding and a $25,000 civil penalty.
The Aircraft Owners and Pilots Association (AOPA) notes that proper documentation is critical. AOPA advises owners to keep detailed logs, including emails with engineers, part drawings, and installation records signed by a certified mechanic.
Choosing the Right Path: Key Considerations
Risk Tolerance
For commercial operators or aircraft used in high-frequency flight, FAA-approved parts offer a clearer path to compliance and insurability.
Cost vs. Compliance
While owner-produced parts can save money upfront, they may complicate future resale or cause regulatory delays.
Operational Environment
Remote operators or those with access to skilled fabricators and A&P mechanics may find owner-produced parts practical in limited use cases.
Conclusion
The distinction between FAA-approved and owner-produced parts isn’t just bureaucratic—it affects safety, compliance, and operational continuity. With enforcement increasing and aircraft maintenance becoming more data-driven, owners must make informed decisions that align with both their budget and regulatory obligations. Which type of part will your aircraft rely on next?
