PMA parts vs OEM: what the FAA approval covers and when a PMA part is the right buy
A PMA part is an FAA-approved replacement part made by a company other than the original manufacturer. Whether it is right for your aircraft depends less on the part than on what surrounds it: how it was approved, its paperwork, the aircraft's authority, the lease and your own quality manual. This guide covers each, then shows how to say on an RFQ exactly what you will accept.
What a PMA is, and what it is not
The FAA defines a Parts Manufacturer Approval as "a combined design and production approval for modification and replacement articles." It allows a manufacturer to produce and sell those articles for installation on type-certificated aircraft, engines and propellers. The rules are in 14 CFR part 21, subpart K (§§ 21.301–21.320); FAA Orders 8110.42 and 8120.22 set out how the FAA processes applications.
A PMA is one of three forms of FAA production approval, alongside a production certificate and a TSO authorization (§ 21.1). That matters under § 21.9, which lets a replacement part likely to end up on a type-certificated product be produced only under a type certificate or an FAA production approval, as a standard or commercial part, or under a few narrow exceptions. The PMA holder must keep an FAA-approved quality system, ensure each article conforms to its approved design and is in a condition for safe operation, and mark it (§ 21.316). A PMA cannot be transferred: a company that buys PMA data needs a PMA of its own.
So "PMA vs OEM" is not approved versus unapproved: both are approved. They differ in who designed the part, on what data, under which number, and in who else has a say: a foreign authority, a lessor, a customer.
Three routes to a PMA, and why the route matters
Under § 21.303 the applicant submits the design (drawings, specifications, dimensions, materials and processes) and shows that it meets the airworthiness requirements. There are three ways to do it:
| Route | What the applicant shows | What it means for the buyer |
|---|---|---|
| Test and computation | Test reports and computations showing the design meets the airworthiness requirements for the product, plus a signed statement of compliance | The design is the PMA holder's own and need not be identical to the OEM's. The part carries its own number. |
| Identicality with a license | Evidence of a licensing agreement under which the design came from the design approval holder | The OEM's design, made by someone else. It may carry the OEM part number, but is still marked "FAA-PMA" with the holder's name. |
| Identicality without a license | That the design is the same in every respect: dimensions, tolerances, materials, processes and specifications | FAA guidance says this is typically possible only with the original drawing and specifications. Applications resting solely on reverse engineering are rejected and redirected to test and computation. |
The route is recorded: the FAA lists PMA articles in its Dynamic Regulatory System (DRS), searchable by holder, part, approval basis and the make and model the part fits. It decides how EASA treats the part, and, depending on the wording, how your lease does.
How to recognize a PMA part
Under 14 CFR 45.15(a), the manufacturer must permanently and legibly mark each PMA article with the PMA holder's name, trademark, symbol or other FAA-approved identification, the part number, and the letters "FAA-PMA". If the FAA finds a part too small or otherwise impractical to mark, that information is attached to the part or its container (§ 45.15(d)). A critical part, one with a replacement time, inspection interval or related procedure in the Airworthiness Limitations section, also gets a unique serial number.
- The part number usually differs from the OEM's. FAA guidance asks for a number that distinguishes the PMA part from the type certificate holder's part, and an OEM number with an added prefix or suffix is enough. It will usually not appear in the OEM's illustrated parts catalog, so whether it may replace the catalog number is a decision for your engineering. See our guide to alternate and interchangeable part numbers.
- Licensed parts are the exception. They may carry the OEM number, but still bear "FAA-PMA" and the holder's name.
- Assemblies are marked at the top level. Detail parts of a PMA assembly sold separately carry the marking information on their shipping documents, identified as subcomponents of that assembly.
- Check eligibility. A PMA covers the products listed in its approval. The FAA's own guidance warns that some eligibility listings in DRS are inaccurate, and says to confirm doubtful ones with the PMA holder or the FAA office that issued the approval.
Release paperwork: 8130-3 or not
Inside the US, a new PMA part does not have to ship with an FAA Form 8130-3. A production approval holder issues authorized release documents only "if the production approval holder intends to issue those documents" (§ 21.137(o)), and the FAA's AC 20-62E notes that shipping tickets and invoices may provide evidence that a part came from a production approval holder. Plenty of PMA parts are released on an 8130-3 all the same, and a new part exported to the EU normally travels with one (TIP 7.10).
For a product EASA has certified or validated, paragraph 7.11 of the EU–US Technical Implementation Procedures (TIP) says block 12 of the 8130-3 should carry one of three statements:
- "This PMA part is not a critical component."
- "Produced under licensing agreement from the holder of [TC or STC number]."
- Where the PMA holder also holds the EASA STC that incorporates the part, a statement naming that EASA STC.
If the 8130-3 was issued at a distributor rather than at the factory, FAA Order 8130.21J asks for block 12 to name the production approval holder that made the part.
Overhauled and repaired units can contain PMA parts. AC 43-9D lists "any Parts Manufacturer Approval (PMA) parts used" among the entries for block 12 of a maintenance 8130-3, because "some European Union Aviation Safety Agency (EASA)-based air carriers do not accept PMA parts and documenting the use of them on FAA Form 8130-3 notifies the end user prior to installation." If PMA is ruled out for you, that includes piece parts inside an overhauled unit. Read block 12, and say so on the RFQ.
In supplier quotes we received between June and September 2026, about 112,700 quote lines, only 396 mentioned PMA at all (0.35%). Of the 386 that said PMA without "non-PMA", 71% stated an FAA 8130-3. Another 10 lines explicitly offered a "non-PMA" equivalent. These counts reflect what suppliers wrote, not how many of the parts were actually PMA.
The low count is the lesson. A quote line that says nothing about PMA does not tell you the part is OEM. If it matters, ask.
How EASA and other authorities treat FAA PMA parts
EASA's acceptance of FAA PMA parts is set by the TIP under the EU–US bilateral agreement (Revision 7, dated 19 October 2023, amended in 2025). Under paragraph 3.3.4, EASA accepts FAA PMA approvals "without further showing" for parts installed on products it has certified or validated, in these cases:
| PMA part | Approval route | EASA acceptance |
|---|---|---|
| Not a critical component | Test and computation, or identicality without a license | Accepted directly |
| Critical or not | Licence from the TC or STC holder | Accepted directly if EASA has validated that TC or STC |
| Critical component | FAA-issued STC | Accepted if EASA has validated the STC |
| Critical component | Test and computation, or identicality without a license | Accepted only if EASA has issued an equivalent STC; otherwise it needs EASA validation first |
The TIP defines a critical component as a part identified as critical by the design approval holder, or by the authority of the state of design. Typically that means a part with a replacement time, inspection interval or related procedure in the Airworthiness Limitations section or the certification maintenance requirements. In EASA's validation procedure, an application for a critical PMA part not made under license is classified "Non-Basic".
Amendment 1 to TIP Revision 7, signed in June 2025, lets repair stations in the US that hold an EASA approval fit new parts into a component they repair without an 8130-3 for each part, provided documents trace them to the FAA production approval holder and show conformity to the approved design. FAA critical PMA parts and life-limited parts are excluded.
The TIP binds the FAA and EASA only. Other authorities set their own terms for FAA PMA parts, so for an aircraft on another register, check with your quality department or the authority before you order. And an authority's acceptance does not bind an operator: as AC 43-9D notes, some EASA-based carriers do not accept PMA parts at all.
When a PMA part is the right buy, and when it is not
Good reasons to buy PMA
- Price. One distributor puts it this way: "Generally, PMA parts cost less than the OEM equivalent; however, that is not always the case." Compare like with like: same condition, same paperwork, same quantity.
- Availability. When the OEM part is on a long lead time, a PMA part on the shelf can be the difference between a delay and a flight.
- Non-critical, high-usage parts on aircraft you own or control, where your engineering has already accepted the PMA number.
- Licensed PMA. The design is the OEM's own, and EASA accepts it without further showing where it has validated the TC or STC.
When to stop and check first
- Leased aircraft. Leases can restrict PMA. A lease-training organization gives this sample clause: "No PMA Part shall be installed within or on the Aircraft. No PMA Part shall be installed within an Engine, the APU or the Landing Gear." Its reasoning: "the lease is there to maintain the asset value, the regulations are there for airworthiness." An aircraft can be airworthy and still fail its return conditions. Clauses can be negotiated: a 2016 trade-press column argued that lessors were growing more willing to allow PMA when the lessee asks, while noting that most "remain squeamish about PMA in the gas path or life-limited engine PMA".
- How your lease defines "PMA part". The same source suggests "a Part which has not been manufactured by, or with the written permission of, the Manufacturer or the Engine Manufacturer, as the case may be." Read literally, that wording may leave out a part made under a written license from the manufacturer; a wider definition will not. How your own clause is read is a question for your lessor or your leasing team, not for the supplier.
- Engines, APU, landing gear, critical and life-limited parts. The FAA coordinates PMA applications for critical and life-limited parts more closely (Order 8110.42D), EASA accepts critical PMA only in the cases above, and lease clauses single these assemblies out. Default to "OEM only unless engineering says otherwise".
- Your own rules and your customer's. Your quality manual, a customer's purchase order terms or an engine maintenance agreement may already decide the question.
- EU-registered aircraft where the part falls outside TIP 3.3.4, or the 8130-3 lacks the TIP statement.
PMA, "PMA equivalent", "non-PMA" and DER repairs are different things
Quotes use these words loosely:
| On the quote | What it is | Status |
|---|---|---|
| OEM | Made by the type or production certificate holder, or by its supplier with direct ship authority | Approved |
| FAA-PMA | Made under a PMA and marked "FAA-PMA" | Approved for the listed products; outside the US, per the importing authority |
| Licensed PMA | PMA by identicality under a license from the design holder | Approved; the OEM's design |
| "PMA equivalent" | Not a regulatory term. It may mean a PMA part that replaces the OEM number, or only "similar to" | Unknown until the supplier names the PMA holder and part number |
| "Non-PMA" or "non-PMA equivalent" | Not produced under an FAA production approval | Its maker may not represent it as suitable for installation on a type-certificated product (§ 21.9(b)). It is installable only if another route in § 21.9 applies, such as a standard part (AN, MS, NAS) your data calls for, and your engineering must establish that. |
| DER repair | A repair to an existing part, made to repair data approved by an FAA Designated Engineering Representative and documented on FAA Form 8110-3 | The part keeps its identity; what is not OEM is the repair. EASA accepts FAA-approved major repair data for products it has certified or validated, but not repair designs that need new parts amounting to a design change (TIP 3.3.5). |
A lease that restricts PMA may restrict non-OEM repairs too, so ask whether a quoted overhauled or repaired unit was repaired to DER data.
How to say it on an RFQ
Put the rule on each line, not only in the covering email: quotes come back line by line.
| What you mean | Write on the line |
|---|---|
| No PMA anywhere | "OEM only. No PMA parts. For OH/SV/RP units, list any PMA parts used in block 12." |
| PMA welcome, side by side with OEM | "PMA acceptable. Quote PMA as a separate line with PMA holder, PMA P/N and the OEM P/N it replaces." |
| PMA with limits | "PMA acceptable if not a critical component. 8130-3 with TIP statement in block 12." |
| Only the OEM's design | "Licensed PMA only. State the licensing TC/STC holder." |
| No unapproved substitutes | "No non-PMA equivalents. Alternates only per IPC." |
When a PMA offer comes back, check before you order:
- Identity. PMA holder, PMA part number, the OEM number it replaces.
- Basis and eligibility. Licence, identicality or test and computation; your model on the approval.
- Paperwork. 8130-3 or shipping documents; the TIP statement for an EU aircraft.
- Permission. Lease, customer and quality manual.
The rest of a complete RFQ line, from quantity and condition to certificate and delivery point, is in our guide to writing an aircraft parts RFQ.
Tell us where PMA is acceptable
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. Write "OEM only" or "PMA acceptable" next to the lines where it matters. Your inquiry will be reviewed by a specialist within one business day. In our client portal, every quoted line shows part number, description, condition and certificates, so you can hold each answer against what you asked for.
Our client portal, RFQ Radar, keeps every quote, order and invoice in one place, and a purchase order placed there carries your note and a "certificate needed" tick on each line.
Sources
- 14 CFR part 21, subpart K, Parts Manufacturer Approvals (§§ 21.303, 21.314, 21.316) — eCFR.
- 14 CFR 21.1, Applicability and definitions, 14 CFR 21.9, Replacement and modification articles and 14 CFR 21.137, Quality system — eCFR.
- 14 CFR 45.15, Marking requirements for PMA articles, TSO articles, and critical parts — eCFR.
- Parts Manufacturer Approval (PMA), PMA Design Approval and PMA Production Approval — FAA.
- Order 8110.42D (Change 2), Parts Manufacturer Approval Procedures — FAA, 27 October 2023.
- Documenting Compliance Findings: Using FAA Form 8110-3 — FAA.
- Order 8130.21J, Completion of FAA Form 8130-3 under Part 21 — FAA, 25 September 2025.
- AC 20-62E (Change 1), Eligibility, Quality, and Identification of Aeronautical Replacement Parts — FAA, 2010, change 2018.
- AC 43-9D, Maintenance Records and FAA Form 8130-3 Return to Service — FAA, 22 September 2025, editorial update 30 April 2026.
- Technical Implementation Procedures for Airworthiness and Environmental Certification between the FAA and EASA, Revision 7 — EASA, 19 October 2023.
- Amendment 1 to TIP Revision 7 — FAA and EASA, June 2025.
- Aircraft Lease & Conditions for Parts Usage — IALTA, April 2023.
- You've Got to Fight for Your Right to PMA-ty — Aviation Maintenance Magazine, November 2016.
- OEM vs PMA Parts: Which Should You Choose for Your Aircraft? — C&L Aero.