Buyer's guide

Are aircraft parts duty-free? The civil aircraft relief and the 2025–2026 US tariffs

By the MG AVIATION TECH team · Published · 10 min read

Usually, yes, but only if someone claims it. Civil aircraft parts can enter the United States, the EU and the UK free of customs duty, and since 2025 the same test has decided whether a part escapes several of the new US tariffs. This guide covers what each claim needs, what the tariffs of 2025–2026 did to aircraft parts, what duty relief does not cover, and what you and your customs broker should have ready.

Not legal or customs advice

This is a plain-language overview of the rules as published on 23 September 2026. US tariff measures have changed several times in two years and may change again. Classification, origin and eligibility depend on the specific part and entry: confirm every case with your licensed customs broker or adviser.

Where the relief comes from

The WTO Agreement on Trade in Civil Aircraft entered into force on 1 January 1980. It is a plurilateral agreement: only the WTO members that signed it are bound. Its signatories must eliminate customs duties and other import charges on civil aircraft, civil aircraft engines and their parts, all other parts, components and sub-assemblies of civil aircraft, and ground flight simulators, when used in manufacture, repair, maintenance, rebuilding, modification or conversion. Duties on repairs of civil aircraft are covered too.

Each signatory writes this into its own tariff, with its own conditions. So "aircraft parts are duty-free" is true only in the form each country gives it, and only for the part and use that qualify.

The three regimes at a glance

United StatesEuropean UnionUnited Kingdom
Legal basisHTSUS General Note 6; 19 CFR 10.183Combined Nomenclature end-use relief; or Regulation (EU) 2018/581Authorised Use relief; or the airworthiness scheme
How it is claimedSpecial program indicator "C" on the entry summary, on a line with "Free (C)"End-use authorisation; or the release certificate's number on the declarationAuthorised Use; or the release certificate's number on the declaration
CertificateEvidence of FAA or FAA-recognized airworthiness certification, kept on fileEASA Form 1 or a listed equivalent (FAA 8130-3 is on the list) for the certificate routeCAA Form 1, EASA Form 1 or a listed equivalent for the airworthiness scheme
What it removesCustoms duty, and several 2025–2026 tariffs, with limits (below)Customs dutyImport duty
What staysFees, broker charges, any tariff without a civil aircraft exemptionImport VAT (with narrow exceptions), feesImport VAT, fees

United States: "Free (C)" and 19 CFR 10.183

The US version is General Note 6 of the Harmonized Tariff Schedule (HTSUS) and the CBP regulation 19 CFR 10.183. A part qualifies as "civil aircraft" when two things are true:

  • Use. It is used as original or replacement equipment in the design, development, testing, evaluation, manufacture, repair, maintenance, rebuilding, modification or conversion of aircraft.
  • Airworthiness. It is manufactured or operated under an FAA certificate, or under the approval of the exporting country's airworthiness authority where the FAA recognizes that approval as a substitute. Two narrower cases cover certificate applications by existing type and production certificate holders.

Parts bought for the Department of Defense or the US Coast Guard qualify only on a narrower test.

How the claim is made

The importer enters the part under a tariff provision whose "Special" column shows Free (C) and puts the special program indicator C on the entry summary. Nothing is filed with the entry to prove it, but by making the claim the importer is deemed to certify that the article is a civil aircraft, or was imported for use in one and will be so used.

What to keep, and for how long

Each claim must be supported by documentation kept under CBP's recordkeeping rules: the written order or contract, and evidence of both the use and the airworthiness certification. The regulation lists that evidence "as appropriate in the circumstances": an FAA certification, a foreign airworthiness approval with evidence that the FAA recognizes it, or the application cases. Records relating to an entry are generally kept for five years from the date of entry. CBP can ask for them at any time; if they do not satisfy it, duty-free treatment is denied. Proof of end use itself need not be kept.

A missed claim is not lost at once. The importer can claim afterwards by a written statement filed before liquidation of the entry becomes final; any refund comes without interest.

The "C" only helps where it is printed

Many aircraft lines are duty-free for everyone already: "Other parts of airplanes, helicopters or unmanned aircraft", 8807.30.00, has a general rate of Free. The claim earns its keep on parts classified by what they are rather than where they fit. Wiring sets of 8544.30.00 carry a 5% general rate and Free (C) in the special column; transmission shafts of 8483.10.30 carry 2.5% and the same C. But the screws and bolts of 7318.15.80 carry 8.5%, and the letter C is not among their special programs. Not every aircraft part can be claimed.

Repairs have their own rules. A part repaired abroad returns under chapter 98, where the duty is on the value of the repair, and program C appears in those lines too. Ask your broker how it applies to your entry.

The US tariffs of 2025–2026 and aircraft parts

The additional tariffs of the past two years sit on top of the ordinary tariff, and each one has its own exemption list. In the two Section 301 actions in force today, aircraft parts have a civil aircraft exemption, but it is tied to the General Note 6 criteria and to a list of tariff subheadings.

DateMeasureCivil aircraft parts
2025Tariffs under the International Emergency Economic Powers Act (IEEPA), Executive Order 14257 and othersTaken out for products of the UK (EO 14309), the EU (from 1 September 2025, 90 FR 46136), Japan and Korea under trade deals
20 February 2026Supreme Court, Learning Resources, Inc. v. Trump: IEEPA does not authorize tariffsThe IEEPA tariffs fell
24 February – 23 July 202610% surcharge under Section 122 of the Trade Act of 1974, Proclamation 11012, limited to 150 days unless Congress extended it; it expired at the close of 23 July 2026"Certain aerospace products" excepted, as listed in its Annex II
9 July 2026Section 232 on commercial aircraft, jet engines and parts, Proclamation 11040A national-security threat found, but no immediate tariffs; negotiations with trading partners instead, with an update to the President due within 180 days
From 22 July 2026Section 301 action on Brazil, 25%, 91 FR 45516Exempt when they meet General Note 6 and fall in the listed subheadings
From 24 July 2026Section 301 "forced labor" action: 10% or 12.5% on products of 60 economies, 91 FR 47318Exempt under heading 9903.05.88 when they meet General Note 6 and fall in the listed subheadings

Two details in the current exemption

The forced-labor action exempts civil aircraft articles that meet the General Note 6 criteria and are classified in the provisions listed in U.S. note 52(d) to chapter 99, "regardless of whether" they are entered under a Free (C) line. The exemption therefore reaches some lines where the C does not appear. The limit runs the other way: a part whose subheading is not on the list gets no exemption, however clearly it is for an aircraft. Heading 7318, screws, bolts, nuts and washers, is not on it. CBP's instructions (CSMS #69326983) have filers report the chapter 99 number, such as 9903.05.88, before the part's own classification.

The rate follows the country of origin, not the country the part ships from. A part made in one country and stocked in another is still a product of the first.

Metals are a separate regime

The Section 232 duties on steel, aluminum and copper articles and their derivatives were restructured from 6 April 2026 (Proclamation 11021) and now apply to the full customs value of the product. That proclamation leaves in place the agreements with the UK, the EU, Japan, Korea and other partners that relieve civil aircraft articles under the Aircraft Agreement from those duties. For a metal part from anywhere else, ask your broker whether a 232 duty applies.

European Union: two routes

End-use relief. The Combined Nomenclature grants relief from customs duty for civil aircraft, for certain goods for use in civil aircraft and incorporated in them during manufacture, repair, maintenance, rebuilding, modification or conversion, and for civil ground flying trainers, under a list of headings. The relief runs under end-use customs supervision (Article 254 of the Union Customs Code), which needs an authorisation.

The certificate route. Regulation (EU) 2018/581 suspends the autonomous duties on listed goods for aircraft, a route the regulation's own recitals present as lighter than end-use supervision. The condition: the declarant makes an authorised release certificate available to customs: an EASA Form 1 or an equivalent certificate. The declaration for release for free circulation must carry the certificate's identification number; for a part that has lost its airworthiness status and is imported for repair or maintenance, the number of a previous release certificate. The list of equivalents in Implementing Regulation (EU) 2018/1517 includes the FAA Form 8130-3, as well as the Transport Canada, ANAC Brazil, CAAC China and Hong Kong CAD forms, among others. Where customs suspect a certificate is falsified, they may ask the national aviation authority for an expert opinion at the importer's cost.

For which release to ask the seller for, see 8130-3 vs EASA Form 1 vs dual release.

United Kingdom: Authorised Use or the airworthiness scheme

HMRC's airworthiness scheme is an alternative to Authorised Use relief. It suspends import duty on parts, components and other goods used to manufacture, repair, maintain, rebuild or modify aircraft when they arrive with an authorised release certificate: a CAA Form 1, an EASA Form 1 or a listed equivalent, among them the FAA release (listed by HMRC as "FAA Form 8130"). The declaration must refer to the certificate's identification number. Goods already under Authorised Use cannot be moved to the scheme.

What duty relief does not remove

  • Import VAT or GST. Duty relief is about customs duty. In the EU, import VAT is a separate question; the VAT Directive (Article 148) exempts supplies of equipment for aircraft used by airlines operating for reward chiefly on international routes, and how a member state applies that at import is a local matter. Elsewhere, assume VAT or GST is due unless your broker confirms a relief.
  • Customs fees. A US formal entry carries a merchandise processing fee based on value, with a minimum and a maximum. Ask your broker how it applies to your entry.
  • Small parcels. The de minimis exemption for shipments valued at $800 or less has been suspended since 29 August 2025, and a CBP rule effective 24 June 2026 suspends it indefinitely for all modes other than the international postal network: a courier box of O-rings needs a formal or informal entry like anything else.
  • Broker and carrier charges. Entry preparation, disbursement and document handling are priced by your broker or carrier, not set by law.

For the rest of what separates a line price from a landed cost, see the true cost of an aircraft part.

From our quote data

In supplier quotes we received between June and September 2026, 46.6% of the lines named no certificate at all. An FAA 8130-3 alone was named on 12.8%, an EASA Form 1 alone on 8.8% and a dual release on 4.4%; the rest named a certificate of conformity, a manufacturer's certificate or something else. The EU and UK certificate routes and the US evidence file all start from a release certificate, so ask which one comes with the part before you order.

Checklist: you and your broker

WhoWhat to have or askWhy
You, before the POWhich release certificate comes with the part, and its numberThe EU and UK certificate routes put it on the declaration; the US file needs evidence of airworthiness certification
You, before the POCountry of origin, separately from the ships-from countryAdditional US tariffs and their exemptions follow origin
YouThe PO or contract, and a record of what the part is forThe written order is part of the US evidence file
YouA file per entry, kept five years (US)CBP can ask at any time and deny the claim if the file is thin
Your brokerThe HTS or CN classification, and whether the line shows Free (C) or the EU reliefThe claim only exists where the tariff provides it
Your brokerFor a US entry: is the subheading on the 9903.05.88 list, and does a Section 232 metals duty apply?An aircraft part outside the list pays the additional duty
Your brokerEnd use or certificate route (EU); Authorised Use or airworthiness scheme (UK)Different paperwork, and UK goods cannot switch later
Your brokerVAT or GST, fees and the broker's own charges, in writingDuty relief does not cover them
Your brokerIf duty was paid without the claim: can a post-entry claim still be made?In the US, before liquidation becomes final, without interest

Where MG AVIATION TECH fits

MG AVIATION TECH prices are Ex Works our warehouse in Orlando, FL. Under EXW the import at your end is yours: your forwarder and customs broker make the entry and the claim. Where the supplier states it, each line in our quotes shows the country the part ships from; as above, that is not the same as the country of origin. What EXW leaves to the buyer, and who files the US export, is in our Incoterms guide; export licensing is in export control for aircraft parts.

Ask for the certificate on the RFQ, not after the invoice

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. Your inquiry will be reviewed by a specialist within one business day. In the RFQ Radar client portal every line shows its certificates, and each line of a purchase order has a "certificate needed" tick, so you can say which paper you need before you order.

Send your RFQ →

Our client portal, RFQ Radar, keeps every quote, order and invoice in one place.

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