Aircraft part tag date: how old can an 8130-3 or EASA Form 1 be?
A quote line reads "OH, 8130-3, tag 2019", and your customer's purchasing terms say tags must be no older than two years. Has the tag expired, or is that limit only a contract term? This guide covers what the tag date records, what FAA and EASA rules say about its age, what a "fresh tag" buys, and how to write a tag-age requirement into an RFQ so the quotes come back comparable.
Is there a maximum age for an 8130-3 or EASA Form 1?
No regulation sets one. FAA Order 8130.21J (September 2025), which governs how the FAA Form 8130-3 is completed under Part 21 (production releases and export approvals), and AC 43-9D, which covers the same form as a maintenance release, contain no period after which a tag lapses. Neither do EASA's instructions for the Form 1 in Part 21 and Part-M. The Form 1 has no expiry field at all.
When the FAA introduced a revised 8130-3 in 2002, the Aviation Suppliers Association told its members that tags issued on the old version "will continue to be valid until the product, part, or appliance for which it was issued is installed." A tag records the part's status on the day it was signed and travels with it until installation.
What the rules do require is condition. Under EASA Part-145, a component may be installed only when it is "in satisfactory condition" and released on an EASA Form 1 or equivalent (145.A.42). The FAA states that a return-to-service 8130-3 "does not constitute approval to install" a part on a particular aircraft; that decision stays with the installer. And before a new 8130-3 is issued for a part that has already left the manufacturer's quality system, Order 8130.21J asks for "a determination that the item has not suffered damage or degradation that would affect its airworthiness."
So tag age is not a legal limit. It measures how long since someone last certified the part, and how much of its present condition has to be shown by something other than the tag.
Where the tag date is, and what it records
The 8130-3 and the EASA Form 1 share a layout. Block 11 says what the release is for, block 12 holds remarks, and there are two signature areas: block 13 for a Part 21 release, normally of a new item, and block 14 for a maintenance release. Only one is used on any form; the other is shaded out. The tag date is in 13e or 14e, written as a two-digit day, three-letter month and four-digit year, for example 03 Feb 2025.
| Form | Date block | Used for | What the date records |
|---|---|---|---|
| FAA 8130-3 | 13e | New item released under Part 21 (block 11 "NEW"); also an FAA export approval of a used item (block 11 "USED") | The date the form was signed |
| FAA 8130-3 | 14e | Return to service after maintenance (block 11 "OVERHAULED", "REPAIRED", "INSPECTED" and/or "TESTED", "MODIFIED") | The date the original work was completed, which need not match the printing or shipping date |
| EASA Form 1 | 13e | Production release (block 11 "NEW" or "PROTOTYPE") | The date block 13b was signed |
| EASA Form 1 | 14e | Maintenance release (block 11 "Overhauled", "Repaired", "Inspected/Tested", "Modified") | The date block 14b was signed |
Two consequences for a buyer. First, on an FAA maintenance release the date is when the work was finished, so a tag printed or shipped last week can correctly carry an older date. Second, a production-release date and a maintenance-release date answer different questions: when the manufacturer released a new part, and when a shop last worked on a used one. Keep them in separate columns. Which release your aircraft needs in the first place is covered in 8130-3 vs EASA Form 1.
How old the tags on real quotes are
In supplier quotes we received between June and September 2026, suppliers wrote a tag date we could read on 2,858 quote lines. The median tag age on those lines was 3 years. Age here is the year of the quote minus the year of the tag, so every figure is accurate to about a year, and it reflects what suppliers wrote on the quote, not an inspection of the tags.
| Condition | Lines with a tag date | Median tag age | Older than 2 years | Older than 5 years |
|---|---|---|---|---|
| OH — overhauled | 709 | Same year as the quote | 15.5% | 9.9% |
| SV — serviceable | 172 | Same year as the quote | 17.4% | 9.9% |
| NE — new | 1,359 | 5 years | 59.1% | 43.5% |
| NS — new surplus | 449 | 15 years | 94.9% | 90.9% |
The split follows from what the date records. An overhauled or serviceable unit goes back on the shelf with a maintenance release dated when the shop finished. A new part keeps the production release it left the factory with, however long it then sits. A two-year limit written with overhauled units in mind and applied unchanged to new stock would have ruled out more than half of the NE lines and almost all of the NS lines in this sample.
Tag date, manufacture date and overhaul date
Three dates get mixed up on quotes, and each answers a different question:
- Tag date: the date in block 13e or 14e. When the release was signed or, on an FAA maintenance release, when the work was completed.
- Date of manufacture: when the part was made. It is not a block on either form; it may appear in the remarks, on the data plate or on the maker's package. AC 20-62E lists "shelf-life data, including manufacturing date or cure date" among the information to obtain for a used part.
- Overhaul or last shop date: for a used unit, the date of its last maintenance release. Block 11 says what was done. "OH, tag 2023" and "SV, tag 2023" are the same age and different work.
Two things can put a recent date on an old release:
- A corrected form. When an issuer reissues an 8130-3 or a Form 1 to fix an administrative error, the new form carries a new date, but both the FAA and EASA instructions say it "is not a statement of current condition". Block 12 names the certificate it corrects and its original date, which is the one that counts.
- A copy. Additional copies of an 8130-3 may be provided on request, but AC 43-9D says they must be clearly identified as copies. A copy's print date is not a tag date.
Why new surplus usually carries an old tag
New surplus (NS) is unused stock that has left the manufacturer and passed through other hands, such as an operator's overstock or a distributor's inventory. The manufacturer's release goes with it, dated when the part was released. A 15-year-old tag on an NS line is normal and, by itself, says nothing bad about the part. It does say that the part has spent a long time somewhere, and the FAA is blunt about surplus: "The storage time, storage conditions, or shelf life of surplus parts and materials are not usually known" (AC 20-62E).
The same applies to much NE stock: in our sample the median NE tag was five years old. "NE" on a quote says the part is unused, not that it was made recently. How the condition codes differ is explained in aircraft part condition codes.
Age matters most for what AC 20-62E treats as storage-sensitive: parts with internal seals, such as pumps, valves, actuators, motors and generators, which "are subject to deterioration from long-term storage"; bearings stored for long periods; sealants and adhesives; and instruments that "have been sitting on a shelf for a period that cannot be established", which it says should be tested. For a bracket, an old tag is mostly a paperwork question. For a fuel pump it is also a question about seals; as ASA's Jason Dickstein puts it, "fuel pumps include seals that could degrade over time." Items with a formal shelf life, such as O-rings with a cure date, are covered in our guide to aircraft parts shelf life.
Why buyers set tag-age limits anyway
Because the rules set no limit, a tag-age limit is a contract term: the operator's, the lessor's, the MRO's end customer's or your own quality manual's. Such limits are common enough that an ASA blog post has taken issue with "some operator's policy that any parts purchased must have tags no older than two years", and one avionics shop writes that it likes "to see 8130's that are two years old or newer", with anything older "worth sending out for a fresh bench check." The reasons are sound when they are specific:
- Your customer requires it. A part outside the owner's or lessor's limit cannot be delivered to them, whatever its condition.
- Unknown storage. A recent release shows the unit was inspected or tested recently.
- Configuration. ADs and service bulletins issued after the tag date may apply to the part. A tag cannot show compliance with something issued after it was signed, so the older the tag, the longer the list to check.
The counter-argument is fair too. The same ASA post, by Roy Resto, points out that "typically, if there is a shelf or storage life, the CMM will contain it in its Storage section, or equivalent, of the manual." A flat two-year rule on every line pays for re-tests the manufacturer does not call for, and on NS stock it removes most of the market.
Fresh tag and re-certification: what you are paying for
"Fresh tag", "recert" and "re-tag" all mean a new release with a new date. What stands behind it depends on the part:
| Situation | What the new release is | Date that changes |
|---|---|---|
| Used unit (OH, SV, RP) with an old maintenance release | A repair station inspects and tests it and issues a new maintenance release, block 11 "INSPECTED" and/or "TESTED" | 14e |
| New or NS part, FAA | A new 8130-3 issued after a determination that the item has not suffered damage or degradation (a "recurrent airworthiness approval" in Order 8130.21J); when it is issued at a distributor, block 12 names the production approval holder that made the part | 13e |
| New or NS part, EASA | A new Form 1 marked "NEW" for "the examination of a previously released new item prior to entry into service", with the original release described in block 12 | 13e |
| Corrected form | Not a re-certification: "not a statement of current condition" | 13e or 14e, but the original date still applies |
One distinction buyers miss: a new part re-certified as new keeps a production release; an unused part that a shop inspects and tests leaves with a maintenance release. Some customer specifications treat the two differently, so say which you accept.
Re-certification is worth paying for when:
- your customer's specification or the importing authority requires a release your part does not have, or a tag newer than it has;
- the unit is storage-sensitive and its storage history is unknown;
- ADs or service bulletins have been issued since the tag date and you want their status stated in block 12 of the new release;
- the price gap to a recently tagged unit exceeds the re-test, the freight to the shop and the added lead time.
It is harder to justify for a simple part whose CMM sets no storage limit. Either way, ask for re-certification as a separate, priced option rather than a condition of the quote, so you can compare the part as it is with the part re-tagged.
How to write a tag-age requirement into an RFQ
An RFQ that says only "recent tags" gets back answers you cannot compare: one supplier reads it as the overhaul date, another as the manufacture date. Write the rule in five parts:
- Which date. The date in block 13e or 14e of the release that will ship with the part.
- Measured to when. Age at the date of your purchase order, or at shipment. A tag 23 months old when quoted can be 25 months old when it ships.
- By condition. One limit for overhauled, serviceable and repaired units, and a separate one, or none, for NE and NS stock. A single limit for everything empties the NS column.
- Outside the limit. Excluded, or quoted with re-certification as a separate price and lead time, naming the release that will be issued.
- Evidence. The tag date written on the quote line, a copy of the tag with the quote, and for shelf-life items the date of manufacture or cure date.
Tag age: for each line, state the date in block 13e or 14e of the release certificate that will ship with the part, and attach a copy. OH, SV and RP: release dated no more than [24] months before our purchase order date. NE and NS: no tag-age limit; state the date of the original release and, for items with seals or a shelf life, the date of manufacture or cure date. A line outside these limits may be quoted with re-certification as a separate price and lead time, stating the release that will be issued. If a release has been corrected or reissued, include the original.
Put the same wording on the purchase order. For the rest of the request, see our guide to writing an aircraft parts RFQ.
Send an RFQ with your tag-age rule in it
Send your RFQ to [email protected] in the file you already have (Excel, PDF, a scan or the email body, five lines or five hundred), with your tag-age limit written in it as your customer's specification states it. Your inquiry will be reviewed by a specialist within one business day. In our client portal, every quoted line shows its condition and certificates, and a purchase order carries a "certificate needed" tick per line and a note.
Our client portal, RFQ Radar, keeps every quote, order and invoice in one place.
Sources
- Order 8130.21J, Completion of FAA Form 8130-3 under Part 21 — FAA, 25 September 2025 (paragraphs 8.e, 8.l, 11.k, 11.l, 11.q).
- AC 43-9D, Maintenance Records and FAA Form 8130-3 Return to Service — FAA, 22 September 2025, editorial update 30 April 2026 (paragraphs 23.2.1, 23.2.4, 23.2.9; Appendix B, blocks 11 and 14e).
- AC 20-62E (Change 1), Eligibility, Quality, and Identification of Aeronautical Replacement Parts — FAA, 2010, change 2018 (paragraphs 10–13).
- Easy Access Rules for Initial Airworthiness (Regulation (EU) No 748/2012), Appendix I: EASA Form 1, Authorised Release Certificate — EASA, revision July 2024.
- Easy Access Rules for Continuing Airworthiness (Regulation (EU) No 1321/2014), Part-M Appendix II: EASA Form 1 and 145.A.42 Components — EASA, revision September 2025.
- NEW 8130-3 Tag Replaces the Old Version — Aviation Suppliers Association, Update Report, June 2002.
- Aftermarket Tags: Overhauled vs Repaired vs 2 Years — Roy Resto, Aviation Suppliers Association, April 2017.
- Condition Codes on Parts with Multiple Tags — Jason Dickstein, ASA Web Log, April 2018.
- Know Your Conditions! — Skyman Avionics, March 2023.