Importing Aircraft, Part 2: Aircraft Registration and Deregistration

When importing a multi-million-dollar aircraft, understanding both aircraft registration in its country of origin and compliance with FAA requirements is critical.

While the specifics of deregistration and registration vary globally, the core principles remain consistent. 

This process begins with a foundational rule every student pilot learns: a valid certificate of aircraft registration (like the FAA’s AC Form 8050-3) is mandatory to fly legally…

But how do you obtain one when buying a foreign-registered aircraft?

Aircraft Deregistration

An aircraft may only be registered with one country at a time. Therefore, the plane must be deregistered from the foreign jurisdiction.

Process

Many countries have their own forms that must be completed and submitted locally. Some may be submitted electronically, while others must be submitted in person.

For deregistration from the FAA on exports, a simple one-page deregistration request will suffice. It needs to be properly signed by the aircraft owner and filed with the FAA registry.

Timing

The timing of deregistration varies wildly by country. The FAA registry prioritizes import and export paperwork over regular filings, and deregistration usually occurs within a business day or two.

Some foreign countries issue deregistration certificates on the same day they are requested. Typically, they come within a few days to a week. But some countries take weeks or even longer to process the deregistration, therefore slowing down the whole import transaction process.

Stop! Considerations Before Deregistration

Deregistration is typically the penultimate step in the closing process, occurring immediately before the contemporaneous payment to the seller and filing the purchaser’s registration documents.

Once deregistration is complete, the plane is a glorified paperweight—it has no registration and cannot fly.

So, prior to deregistration, the plane better be in the location it belongs. This must be one that’s accessible by maintenance to modify the plane for the FAA and an FAA representative to confirm the plane is ready for an airworthiness certificate.

Once the plane is deregistered, its former registry no longer has jurisdiction over it. So, any paperwork that’s needed, such as an export certificate of airworthiness, also better be in hand.

A clear title must also be verified in the plane’s former jurisdiction before deregistration. Some countries will not issue a deregistration certificate if there’s a lien or mortgage filed, but some will. Some registries do not record liens or mortgages at all. Either way, a clear title in the foreign country must be verified before deregistration.

Finally, a buyer must confirm that any required customs process is completed prior to deregistration. If customs is overlooked, it will be too late to fly the plane back out of the country and re-import it through customs because the plane can’t fly after deregistration. Plus, the penalties can be staggering for failure to comply with customs.

Aircraft Registration

Deregistration was completed. Congratulations! The foreign registry sends a certificate of deregistration directly to the FAA either by fax, email or telex (I had to look that up!) The certificate should show up in the FAA registry’s files within a business day or two.

Now comes the easy part. Once the FAA receives the certificate of deregistration, the new owner may file their own FAA Aircraft Registration Application (form 8050-1). A temporary registration known as a “flywire” will quickly be issued, with the more permanent “hard card” registration to follow within a few months depending on the FAA registry’s backlog

Now that your plane is registered with the FAA, the next challenge is getting it ready to fly. Next month’s article will cover this final piece.

Stay tuned for upcoming articles that break down the challenges of buying a foreign aircraft—and how to navigate them with confidence.

Part 3: Airworthiness: How to Get the Aircraft Ready to Fly

Part 4: How to Balance Taxes Between Multiple Jurisdictions

Part 5: Logistics: Where to Inspect the Plane and Complete Closing?

Part 6: Contractual Quirks of Foreign Transactions

This article is not intended, nor should it be construed or relied upon, as legal advice. The comments, recommendations, and analysis expressed in this article are those of the individual author, John Farrish, and are purely informational. This article does not create an attorney-client relationship between you and the author or his law firm. If specific legal information is needed, each person should retain and consult an attorney with knowledge of the subject matter.

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