Consultation on changes to requirements for the design, production, and identification of approved aeronautical parts now open

Comments on RBACs 21 and 45 will be accepted until December 29

Publicado em 13/11/2025 16h39 Atualizado em 21/11/2025 17h17

The National Civil Aviation Agency of Brazil (Anac) opened on Wednesday, November 12th, a public consultation about proposed amendments to two Brazilian Civil Aviation Regulations (RBACs):

- RBAC No. 21, which deals with the certification of aeronautical products and articles; and

- RBAC No. 45, which addresses identification, nationality, and registration marks.

Contributions may be submitted until December 29, through the specific online form.

Key points
The proposed changes consolidate several improvements to the regulations governing Certificates of Approved Aeronautical Product (CPAA), CPAA under a Technical Standard Order (CPAA/OTP), and the related Production Organization Certificate (COP), as well as updates to associated terminology.

Highlights of the public consultation include:

- Inclusion of provisions allowing the transfer of ownership of CPAA and CPAA/OTP, or their licensing for manufacture by third parties;

- For CPAA/OTP, it is proposed that technical data and demonstrations no longer be required at the time of application, but may instead be submitted throughout the certification process. This change aims to reduce rework and enhance the Agency’s involvement during the process;

- Brazilian Technical Standard Orders (OTP) will be based not only on the Federal Aviation Administration (FAA) Technical Standard Orders (TSO), but also on European Technical Standard Orders (ETSO), and Canadian Technical Standard Orders (CAN-TSO). This scope expansion may enable Brazilian manufacturers to develop parts for international markets or use minimum performance standards not available from the FAA;

- Inclusion of new eligibility requirements for obtaining CPAA, CPAA/OTP, or COP, as well as requirements for record retention and availability. These obligations, previously implicit, are now made explicit for greater clarity; and

- Terminology updates, such as replacing “product,” and “part" where appropriate. The CPAA will now be referred to as the Certificated of Approved Aeronautical Part, aligning it with the definitions of “product” and “article” in RBAC 21. A similar update is proposed for RBAC 45.

Documents
The following documents are available for consultation:

Draft ANAC Resolution (Portuguese only), that will be the document issued by the Board of Directors for changing the RBAC

Draft RBAC n° 21 and 45 (Portuguese only), compiling proposed changes into the full regulation documents;

Comparative chart (English version available), highlighting changes item per item, along with foreign reference regulation and a detailed justification;

Technical Note No. 11/2025/GTNI/SAR (Portuguese only), which contains full details of the proposed changes and reasons for such changes.

Justification (English version available), containing the legal basis for proposing the changes and a general description of normative changes; and

Board of Directors report and decision (Portuguese only) for submitting this theme for public consultation.

Justification and the Comparative Chart were translated into English for encouraging the participation of foreign civil aviation authorities and organizations.

Anac’s Communications Office

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