ADVISORY CIRCULAR

AC 21-12 v1.1

Classification of design
changes

Date November 2022

File ref D22/468401
 CLASSIFICATION OF DESIGN CHANGES

Advisory circulars are intended to provide advice and guidance to illustrate a means, but not necessarily the only
means, of complying with the Regulations, or to explain certain regulatory requirements by providing informative,
interpretative and explanatory material.
Advisory circulars should always be read in conjunction with the relevant regulations.

Audience
This advisory circular (AC) applies to:

• Applicants for approval of design changes

• Approved design organisations
• Authorised persons with design approval privileges.

Purpose
This AC provides guidance on the classification of design changes for the purposes of approval of
the changes under Part 21. Classification of design changes is necessary to determine the
appropriate approval method and the certification basis for the change.

For further information

For further information, contact CASA’s Airworthiness Standards (telephone 131 757).

Status
This version of the AC is approved by the Branch Manager, Airworthiness and Engineering.
Note: Changes made in the current version are not annotated. The document should be read in full.

Version Date Details

v1.1 November Administrative review only.

2022

v1.0 March 2015 Initial AC.

Unless specified otherwise, all subregulations, regulations, Divisions, Subparts and Parts
referenced in this AC are references to the Civil Aviation Safety Regulations 1998 (CASR).

AC 21-12 v1.1 November 2022 Page 1

 CLASSIFICATION OF DESIGN CHANGES

Contents
1 Reference material 3
1.1 Acronyms 3
1.2 Definitions 3
1.3 References 5
1.4 Forms 6
2 Background 7
2.1 Introduction 7
2.2 Scope 7
2.3 Approval of design changes 7
2.4 Certification basis 8
2.5 Classifications of design changes 8
3 General considerations 9
3.2 Determination of the current approved design of the aircraft or aeronautical
product 9
4 Classification of repairs 10
4.1 Clarification of the terms Major/Minor 10
4.2 Airworthiness concerns for Major/Minor classification 10
4.3 Examples of 'Major' repairs 11
5 Classification of modifications 12
5.1 Purpose of classification 12
5.2 Introduction 12
5.3 Assessment of a modification for major/minor classification 12
5.4 Assessment of a major modification for substantial, significant or not significant
classification 14
5.5 Approval of major modifications 15
6 Establishment of the type-certification basis of changed aeronautical products 17
7 Reclassifying changes 18

AC 21-12 v1.1 November 2022 Page 2

 CLASSIFICATION OF DESIGN CHANGES

1 Reference material

1.1 Acronyms
The acronyms and abbreviations used in this AC are listed in the table below.

Acronym Description
AC Advisory Circular
AFM Aircraft flight manual

AMC Acceptable means of compliance

CAR Civil Aviation Regulations 1988
CASA Civil Aviation Safety Authority

CASR Civil Aviation Safety Regulations 1998

CPR Changed Product Rule
EASA European Aviation Safety Authority
FAA Federal Aviation Administration
GM Guidance Material
STC Supplemental type certificate
TC Type certificate

1.2 Definitions
Terms that have specific meaning within this AC are defined in the table below. Where
definitions from the civil aviation legislation have been reproduced for ease of reference, these
are identified by 'grey shading'. Should there be a discrepancy between a definition given in this
AC and the civil aviation legislation, the definition in the legislation prevails.

Term Definition
Adequate certification The type certification basis for a changed product under regulation 21.101 is
basis considered adequate when CASA determines that it provides adequate
standards for the design change, i.e. when the certification specifications of
the applicable airworthiness code and prescribed special conditions provide
an appropriate level of safety for the changed product and do not result in any
unsafe design features.
Affected area, system, Any system, component, part, or appliance which is either physically altered
component, part or by a proposed design change or, even if not altered physically, its functional
appliance characteristics are altered due to the effects of the physical change.
Aeronautical product The terms aeronautical product or product(s) used in this guidance material
includes type certificated aircraft, engines, and propellers.

Airworthy An aircraft or aeronautical product is airworthy if it is in a state that conforms

with its approved design and is in a condition for safe operation.
Approved design The type design for the aircraft, engine or propeller; and any changes to the
type design made in accordance with a Part 21 approval.

AC 21-12 v1.1 November 2022 Page 3

 CLASSIFICATION OF DESIGN CHANGES

Term Definition
Certification basis The applicable airworthiness requirements as established in regulation
21.017 and 21.101, as appropriate; special conditions; equivalent level of
safety findings; and exemptions applicable to the product to be certificated.
Design change A change in the approved design of an aircraft, aircraft engine or propeller.
Earlier requirements The requirements in effect prior to the date of application for the change, but
not prior to the existing certification basis
Existing certification The requirements incorporated by reference in the type certificate of the
basis aircraft, aircraft engine or propeller to be changed.
Latest requirements The requirements in effect on the date of application for the change.
Major change A change that is not a minor change.
Minor change A change that has no appreciable effect on the weight, balance, structural
strength, reliability, operational characteristics, or other characteristics
affecting the airworthiness of an aircraft, aircraft engine or propeller.
Not significant change A change that is not a significant change or a substantial change.
Previous relevant design Previous design changes, the cumulative effect of which could result in a
changes aircraft, aircraft engine or propeller significantly or substantially different from
the original product or model, when considered from the last time the latest
regulations were applied.
Product level change A change or combination of changes that makes the product distinct from
other models of the product (for example, range, payload, speed, design
philosophy). Product level change is defined at the aircraft, engine, propeller,
or APU level of change.
Secondary change A change is a secondary change if compliance to the latest amendment
would not contribute materially to the level of safety and where it is part of
and consequential to an overall significant change. A secondary change is a
physical change that restores without changing the system, structural
capacity, or functionality, but is necessary to support a significant change.
Significant change A change significant to the extent that it changes at the product level one or
more of the following: general configuration, principles of construction or the
assumptions used for certification, but not to the extent to be considered a
substantial change. The significance of the change is considered in the
context of all previous relevant design changes and all related revisions to the
applicable regulations. Not all product level changes are significant.
Substantial change A change which is so extensive that a substantially complete investigation of
compliance is required, and consequently a new TC.
Type design The design that applied for type certification of the aircraft, aircraft engine or
propeller. See regulation 21.031 for full details of what is included in the type
design.

AC 21-12 v1.1 November 2022 Page 4

 CLASSIFICATION OF DESIGN CHANGES

1.3 References
Legislation
Legislation is available on the Federal Register of Legislation website https://www.legislation.gov.au/

Document Title
Air Navigation (Aircraft Noise) Regulations 1984
Part 21 Certification and airworthiness requirements for
aircraft and parts

International Civil Aviation Organization documents

International Civil Aviation Organization (ICAO) documents are available for purchase from http://store1.icao.int/

Document Title
ICAO Annex 16

ICAO Doc 9501 ICAO Environmental Technical Manual

Advisory material
CASA's advisory materials are available at https://www.casa.gov.au/publications-and-resources/guidance-materials

Document Title
AC 21-8 Approval of modification and repair designs under Subpart 21.M
AC 21-15 Supplemental type certificates
AC 21-23 Technical data
AC 21-601 Australian Technical Standard Order Authorisation

Other documents
EASA documents are available at: http://easa.europa.eu/
FAA documents are available at: http://www.faa.gov/

Document Title
EASA AMC and GM to
Part 21
EASA CS-25 AMC
25.1309
FAA AC 21.101-1

FAA AC 23.1309-1
FAA AC 25.1309-1

AC 21-12 v1.1 November 2022 Page 5

 CLASSIFICATION OF DESIGN CHANGES

1.4 Forms
CASA’s forms are available at http://www.casa.gov.au/forms

Form number Title

Form 655 Design Advice

Form 733 Application for Supplemental Type Certificate

AC 21-12 v1.1 November 2022 Page 6

 CLASSIFICATION OF DESIGN CHANGES

2 Background

2.1 Introduction
2.1.1 Part 21 includes various provisions for the approval of design changes. Changes must
be classified as either major or minor. Modifications may be further classified as
substantial, significant or not significant. Classification of design changes is necessary
to determine the appropriate approval method and the certification basis for the change.

2.2 Scope
2.2.1 This AC provides guidance for classification of design changes for type certificated
aircraft, aircraft engines and propellers, including aeronautical products for those
aircraft, engines and propellers, for the purposes of approval of the design change
under Part 21.
2.2.2 This AC is not intended for direct application to non-type certificated aircraft. It also
does not cover the classification of defects or damage as major or minor for the
purposes of the continuing airworthiness regulations of either Part 42, or Part 4A of the
Civil Aviation Regulations 1988 (CAR).

2.3 Approval of design changes

2.3.1 All changes to the approved design of a type certificated aircraft, aircraft engine or
propeller must be approved under Part 21.
2.3.2 Alteration to any of the data included within the meaning of the type design, applied to
the approved design of the aircraft or aeronautical product, is considered a design
change. A design change includes both modifications and repairs, and may be any one
or a combination of a physical change, or a change to an operating envelope,
performance, operating characteristics, limitations or ICA. A design change may be a
single change or a collection of changes.
2.3.3 The general requirements for approval of a design change are the following:
a. the altered aircraft or aeronautical product complies with the applicable
airworthiness requirements – the certification basis
b. no feature or characteristic of the design change makes the altered aircraft or
aeronautical product unsafe for its intended use.
2.3.4 Subpart 21.D provides for approval of design changes to type certificated aircraft,
aircraft engines and propellers as a change in type design. The provisions of Subpart
21.D are for design changes proposed by the type certificate holder.
2.3.5 Subpart 21.E provides for approval of major design changes to type certificated aircraft,
aircraft engines and propellers under a supplemental type certificate (STC). See
AC 21-15 for more information on STCs.
2.3.6 Subpart 21.M provides the general requirements for approval of modification and repair
designs for aircraft, aircraft engines, propellers and appliances. See AC 21-8 for more
information on approval of modification/repair designs under Subpart 21.M.

AC 21-12 v1.1 November 2022 Page 7

 CLASSIFICATION OF DESIGN CHANGES

2.4 Certification basis

2.4.1 The certification basis for a change to a type certificated aircraft, aircraft engine or
propeller is:
a. the regulations mentioned in the type certificate – the type certification basis; or
b. the applicable regulations in effect on the date of the application, plus any other
amendments that CASA is satisfied are directly related.
2.4.2 The certification basis can vary depending on the magnitude and scope of the change.
The classification of the design change is therefore necessary to determine whether the
existing type certification basis is adequate for approval of the change, or whether the
latest version of the requirements must be used.

2.5 Classifications of design changes

2.5.1 Design changes must be classified as either major or minor, as described in regulation
21.093. A minor change is one that has no appreciable effect on the weight, balance,
structural strength, reliability, operational characteristics, or other characteristics
affecting the airworthiness of an aircraft, aircraft engine or propeller. All other changes
are major changes.
2.5.2 Major modifications should be further classified as substantial, significant or not
significant.
2.5.3 A substantial change is a change which is so extensive that a substantially complete
investigation of compliance is required, and consequently a new TC.
2.5.4 A significant change is a change significant to the extent that it changes at the product
level one or more of the following: general configuration, principles of construction or
the assumptions used for certification, but not to the extent to be considered a
substantial change.
2.5.5 A not significant change is a change that is neither a significant change nor a
substantial change, i.e. those changes where there is no change to the general
configuration, no change to the principle of construction and the assumptions used for
certification are still valid. Minor changes are automatically considered not significant.

AC 21-12 v1.1 November 2022 Page 8

 CLASSIFICATION OF DESIGN CHANGES

3 General considerations
3.1.1 On some occasions, the classification process is initiated at a time when some data
necessary to make a classification decision are not yet available. Therefore, the
applicant should wait for availability of data before making a decision.
3.1.2 Wherever there is doubt as to the classification of a change, CASA should be consulted
for clarification via submission of a Design Advice.
3.1.3 An initial classification may be subsequently reclassified if additional information
becomes available (see section 7).
3.1.4 The reasons for a classification decision should be recorded and retained with the
technical data for the design.

3.2 Determination of the current approved design of the aircraft or

aeronautical product
3.2.1 Prior to classifying the design change, the current approved design must be
determined. The approved design is the type design plus any other design changes
approved under Part 21, for example, STCs and modification/repair designs.
3.2.2 The type design must be determined to the specific type design configuration that
applied for type certification, i.e. the model or series within a model that will be modified.
3.2.3 In relation to a proposed design change, the determination of the approved design need
only consider other design changes that affect that particular proposed design change.

AC 21-12 v1.1 November 2022 Page 9

 CLASSIFICATION OF DESIGN CHANGES

4 Classification of repairs

4.1 Clarification of the terms Major/Minor

4.1.1 In line with the definitions given in regulation 21.093, a new repair is classified as 'major'
if the result on the approved design has an appreciable effect on structural
performance, weight, balance, systems, operational characteristics or other
characteristics affecting the airworthiness of the product, part or appliance. In particular,
a repair is classified as major if it needs extensive static, fatigue and damage tolerance
strength justification and/or testing in its own right, or if it needs methods, techniques or
practices that are unusual (i.e., unusual material selection, heat treatment, material
processes, jigging diagrams, etc.).
4.1.2 Repairs that require a re-assessment and re-evaluation of the original certification
substantiation data to ensure that the aircraft still complies with all the relevant
requirements, are to be considered as major repairs.
4.1.3 Repairs whose effects are considered minor and require minimal or no assessment of
the original certification substantiation data to ensure that the aircraft still complies with
all the relevant requirements, are to be considered ‘minor’.
4.1.4 It is understood that not all the certification substantiation data will be available to those
persons/organisations classifying repairs. A qualitative judgement of the effects of the
repair will therefore be acceptable for the initial classification. The subsequent review of
the design of the repair may lead to it being re-classified, owing to early judgements
being no longer valid (see section 7).

4.2 Airworthiness concerns for Major/Minor classification

4.2.1 The following should be considered for the significance of their effect when classifying
repairs. Should the effect be considered to be significant then the repair should be
classified 'Major'. The repair may be classified as 'Minor' where the effect is known to be
without appreciable consequence.

4.2.2 Structural performance

4.2.2.1 Structural performance of the product includes static strength, fatigue, damage
tolerance, flutter and stiffness characteristics. Repairs to any element of the structure
should be assessed for their effect upon the structural performance.

4.2.3 Weight and balance

4.2.3.1 The weight of the repair may have a greater effect upon smaller aircraft as opposed to
larger aircraft. The effects to be considered are related to overall aircraft centre of
gravity and aircraft load distribution. Control surfaces are particularly sensitive to the
changes due to the effect upon the stiffness, mass distribution and surface profile which
may have an effect upon flutter characteristics and controllability.

AC 21-12 v1.1 November 2022 Page 10

 CLASSIFICATION OF DESIGN CHANGES

4.2.4 Systems
4.2.4.1 Repairs to any elements of a system should be assessed for the effect intended on the
operation of the complete system and for the effect on system redundancy. The
consequence of a structural repair on an adjacent or remote system should also be
considered as above, (for example: airframe repair in area of a static port).

4.2.5 Operational characteristics

4.2.5.1 Changes may include:
a. stall characteristics
b. handling
c. performance and drag
d. vibration.

4.2.6 Other characteristics

4.2.6.1 Changes may include:
a. changes to load path and load sharing
b. change to noise and emissions
c. fire protection / resistance.
Note: Considerations for classifying repairs 'Major/Minor' should not be limited to those listed above.

4.3 Examples of 'Major' repairs

4.3.1 A repair that, in order to comply with the applicable airworthiness standards, requires a
permanent additional inspection to the approved maintenance programme, necessary
to ensure the continued airworthiness of the product. Temporary repairs for which
specific inspections are required prior to installation of a permanent repair do not
necessarily need to be classified as 'Major'. Also, inspections and changes to inspection
frequencies not required as part of the approval to ensure continued airworthiness do
not cause classification as 'Major' of the associated repair.
4.3.2 A repair to life limited or critical parts (as identified in the airworthiness limitations
section of the ICA or critical parts list respectively).
4.3.3 A repair that introduces a change to the aircraft flight manual (AFM).

AC 21-12 v1.1 November 2022 Page 11

 CLASSIFICATION OF DESIGN CHANGES

5 Classification of modifications

5.1 Purpose of classification

5.1.1 Classification of design changes is necessary to determine the appropriate approval
method and the certification basis for the change.

5.2 Introduction

5.2.1 Changes to the type design

5.2.1.1 Regulation 21.031 defines what constitutes the type design. Alteration to any of the
data included within the meaning of the type design, applied to the approved design of
the aircraft or aeronautical product, is considered a design change.

5.2.2 Classification process

5.2.2.1 Modifications must be classified as either major or minor, using the criteria of regulation
21.093. Modifications may be further classified as substantial, significant or not
significant.

5.3 Assessment of a modification for major/minor classification

5.3.1 Regulation 21.093 provides the criteria for the classification of design changes as minor
or major. A minor change is one that has no appreciable effect on the weight, balance,
structural strength, reliability, operational characteristics, or other characteristics
affecting the airworthiness of an aircraft, aircraft engine or propeller. All other changes
are major changes.
5.3.2 This section is intended to provide guidance for classification of a modification,
particularly in relation to the terms ‘appreciable effect’ and ‘affecting the airworthiness’
from regulation 21.093, where ‘airworthiness’ is interpreted in the context of an aircraft
or aeronautical product in conformity with its approved design and in a condition for safe
operation.

5.3.3 Guidance for major/minor classification of modifications

5.3.3.1 A change to the approved design is judged to have an ‘appreciable effect on other
characteristics affecting the airworthiness of the product’ and therefore should be
classified major, in particular but not only, when one or more of the following conditions
are met:
a. where the change requires an adjustment of the type-certification basis (such as
special condition, equivalent safety finding, elect to comply, earlier certification
specification (reversion), later certification specification)
b. where the applicant proposes a new interpretation of the certification specifications
used for the type type-certification basis, that has not been published as an
acceptable means of compliance or otherwise agreed with CASA

AC 21-12 v1.1 November 2022 Page 12

 CLASSIFICATION OF DESIGN CHANGES

c. where the demonstration of compliance uses methods that have not been
previously accepted as appropriate for the nature of the change to the product or
for similar changes to other products designed by the applicant
d. where the extent of new substantiation data necessary to comply with the
applicable certification specifications and the degree to which the original
substantiation data has to be re-assessed and re-evaluated is considerable
e. the change alters the airworthiness limitations or the operating limitations
f. the change is made mandatory by an airworthiness directive or the change is the
terminating action of an airworthiness directive (see note)
g. where the change introduces or affects functions where the failure effect is
classified catastrophic or hazardous.
Note: A design change previously classified minor and approved prior to the publication of the airworthiness
directive needs no re-classification. However, CASA may review the change and re-classify/re-approve if
necessary.

5.3.3.2 Appendix E provides examples of major changes for various engineering disciplines
that illustrate how to apply the above conditions.

AC 21-12 v1.1 November 2022 Page 13

 CLASSIFICATION OF DESIGN CHANGES

Change in
design

Classification of design change

Goals: - determine approval route
- assess effect on airworthiness

Any of the following criteria met?

- appreciable effect on weight
- appreciable effect on balance
- appreciable effect on structural strength yes
- appreciable effect on reliability
- appreciable effect on operational
characteristics
...of the product.

no

Any of the following criteria met?

(i) adjustment of certification basis
(ii) new interpretation of the requirements used for
the TC basis
(iii) aspects of compliance demonstration not
previously accepted
no (iv) extent of new substantiation data and degree of yes
reassessment and reevaluation considerable
(v) alters the limitations directly approved by CASA
(vi) mandated by AD or terminating action of AD
(vii) introduces or affects function where failure
condition is catastrophic or hazardous
See also Appendix E examples

Request for Any good

CASA decides reclassification yes reason to
(Design Advice) reclassify minor

Minor Major

Figure 1: Decision chart for major/minor classification of modifications

5.4 Assessment of a major modification for substantial, significant

or not significant classification

5.4.1 Substantial changes

5.4.1.1 A substantial change is a change which is so extensive that a substantially complete
investigation of compliance is required, and consequently a new TC.

5.4.2 Significant changes

5.4.2.1 A significant change is a change significant to the extent that it changes at the product
level one or more of the following: general configuration, principles of construction or
the assumptions used for certification, but not to the extent to be considered a
substantial change. The significance of the change is considered in the context of all

AC 21-12 v1.1 November 2022 Page 14

 CLASSIFICATION OF DESIGN CHANGES

previous relevant design changes and all related revisions to the applicable regulations.
Not all product level changes are significant.

5.4.3 Not significant changes

5.4.3.1 A not significant change is a change that is not a significant change or a substantial
change, i.e. those changes where there is no change to the general configuration, no
change to the principle of construction and the assumptions used for certification are
still valid.

5.4.4 Examples of substantial, significant or not significant changes

5.4.4.1 Appendix A contains examples of typical type design changes for small aeroplanes,
large aeroplanes, rotorcraft, engines, and propellers which are categorised by CASA
into individual tables according to the classifications to the level of design change –
substantial, significant, and not significant.

5.5 Approval of major modifications

5.5.1 As a general rule, substantial changes will require a new TC and significant changes
will require an STC (or an amended TC if the applicant is the TC holder).
5.5.2 Not significant changes may require an STC or, in certain circumstances, may be
approved under Subpart 21.M. One of the criteria used to determine the approval
method will be the number of aircraft or aeronautical products that are expected to be
modified.
5.5.3 AC 21-8 provides general guidance with regards to approval of modifications and
repairs under Subpart 21.M. AC 21-8, section 5.8, provides further information and
assessment criteria that will be applied by CASA when determining whether a major
modification may be approved under Subpart 21.M or if an STC approval is required.
5.5.4 The following flow chart provides a simplified depiction of the approval methods for
major modifications.

AC 21-12 v1.1 November 2022 Page 15

 CLASSIFICATION OF DESIGN CHANGES

Change in
design

May be approved
Is the design change a under
no
major change? Subpart 21.M
(r.21.437)

yes

Is the design change a Apply for a

yes new TC
substantial change? (Form 733)

no

Is the design change a Apply for an

yes STC
significant change? (Form 733)

no

Not significant change

Is an
STC required? yes
(see AC 21-8, s.5.8)

no

Submit a
Design Advice
(Form 655)

Figure 2: Approval methods for major modifications

AC 21-12 v1.1 November 2022 Page 16

 CLASSIFICATION OF DESIGN CHANGES

6 Establishment of the type-certification basis of

changed aeronautical products
Reserved for future use.

AC 21-12 v1.1 November 2022 Page 17

 CLASSIFICATION OF DESIGN CHANGES

7 Reclassifying changes
7.1.1 It is understood that in some cases not all the certification substantiation data will be
available to those persons/organisations classifying design changes. A qualitative
judgement of the effects of the change will therefore be acceptable for the initial
classification. The subsequent review of the design change may lead to it being re-
classified, owing to early judgements being no longer valid.
7.1.2 A request to reclassify an initial design change classification may be submitted to CASA
via a Design Advice. The Design Advice application should include the reasons why the
classification should be changed and data to substantiate the request, for example,
flight test data that shows the impact on aircraft performance.

AC 21-12 v1.1 November 2022 Page 18

 CLASSIFICATION OF DESIGN CHANGES

Classification of changes

AC 21-12 v1.1 November 2022 Page 19

 CLASSIFICATION OF DESIGN CHANGES

The following examples of substantial, significant and not significant changes are adopted by
CASA, the FAA, European Aviation Safety Agency (EASA) and Transport Canada Civil Aviation
(TCCA) through an international collaboration. The classification may change due to cumulative
effects and/or combinations of individual changes. The “NA” in the substantial example tables
indicates that the automatic classification criteria in the heading are “Not Applicable” at the
“21.019 Substantial Evaluation” phase.

Table 1: Examples of Changes for Small Aeroplanes (Part 23)

The following examples are for SUBSTANTIAL changes for Small Aeroplanes (Part 23):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Change in wing N/A N/A N/A Proposed change in

location (tandem, design is so
forward, canard, extensive that a
high/low) substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Fixed wing to tilt N/A N/A N/A Proposed change in

wing design is so
extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Increase or N/A N/A N/A Proposed change in

decrease in the design is so
number of engines extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

AC 21-12 v1.1 November 2022 Page 20

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Replacement of N/A N/A N/A Proposed change in

piston or turbo-prop design is so
engines with turbojet extensive that a
or turbofan engines substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Change in engine N/A N/A N/A Proposed change in

configuration (tractor design is so
to pusher) extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Increase from N/A N/A N/A Proposed change in

subsonic to design is so
supersonic flight extensive that a
regime substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Change from an all N/A N/A N/A Proposed change in

metal aeroplane to design is so
all composite extensive that a
primary structure substantially
(fuselage, wing, complete
empennage) investigation of
compliance with the
applicable
certification
specifications is
required.

AC 21-12 v1.1 November 2022 Page 21

 CLASSIFICATION OF DESIGN CHANGES

The following examples are for SIGNIFICANT changes for Small Aeroplanes (Part 23):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Conventional tail to Yes No Yes Change in general

T-tail or Y-tail, or configuration.
vice versa Requires extensive
structural, flying
qualities and
performance re-
investigation.

Requires a new AFM

to address
performance and
flight characteristics.

Changes in wing Yes No Yes Change in general

configuration such configuration. Likely
as change in requires extensive
dihedral, changes in changes to wing
wing span, flap or structure.
aileron span,
addition of winglets, Requires a new AFM
or increase of more to address
than 10% of the performance and
original wing sweep flight characteristics.
at the quarter chord
Note: Small changes
to wingtip are not
significant changes.
See table for not
significant changes.

Changes to tail Yes No Yes Change in general

configuration such configuration. Likely
as the addition of requires extensive
tail strakes or angle changes to tail
of incidence of the structure. Requires a
tail new AFM to address
performance and
flight characteristics.

Note: Small changes

to tail are not
significant changes.

Tricycle / tail wheel Yes No No Change in general

undercarriage configuration.
change or addition Principles of
of floats construction and
certification
assumptions remain
valid.

Passenger to Yes No Yes Change in general

AC 21-12 v1.1 November 2022 Page 22

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

freighter configuration
configuration affecting load paths,
conversion which aeroelastic
involves the characteristics,
introduction of a aircraft related
cargo door or an systems, etc.
increase in floor
loading of more than Change in design
20%, or provision assumptions.
for carriage of
passengers and
freight together

Replace No No Yes Invalidates

reciprocating certification
engines with the assumptions.
same number of Requires a new AFM
turbo-propeller to address
engines where the performance and
operating envelope flight characteristics.
is expanded

Addition of a turbo- No No Yes Invalidates

charger that certification
changes the power assumptions due to
envelope, operating changes in operating
range, or limitations envelope and
limitations.

Requires a new AFM

to address
performance and
flight characteristics.

The replacement of No Yes Yes Invalidates

an engine of higher certification
rated power or assumptions.
increase thrust Requires a new AFM
would be to address
considered performance and
significant if it would flight characteristics.
invalidate the Likely changes to
existing primary structure.
substantiation, or Requires extensive
would change the construction re-
primary structure, investigation.
aerodynamics, or
operating envelope
sufficiently to
invalidate the
assumptions of
certification

AC 21-12 v1.1 November 2022 Page 23

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

A change in the type No Yes Yes Change in principles

of material, such as of construction and
composites in place design from
of metal (or one conventional
composite fiber practices.
material system with
another (e.g., Likely change in
carbon for design/certification
fiberglass), for assumptions.
primary structure
would normally be
assessed as a
significant change

Change involving No No Yes Certification

appreciable assumptions
increase in design invalidated. Requires
speeds Vd, Vmo, a new AFM to
Vc, or Va address
performance and
flight characteristics.

Short Take-Off and No No Yes Certification

Landing (STOL) kit assumptions
invalidated. Requires
a new AFM to
address
performance and
flight characteristics.

A change in the No No Yes Certification

rated power or assumptions
thrust is likely to be invalidated. Requires
regarded as a new AFM to
significant if the address
design speeds are performance and
thereby changed so flight characteristics.
that compliance
needs to be re-
justified with a
majority of
certification
specifications

Fuel state: such as No No Yes Changes in

compressed design/certification
gaseous fuels, or assumptions.
fuel cells. This could Extensive alteration
completely alter the of fuel storage and
fuel storage and handling systems.
handling systems
and possibly affect
the aeroplane

AC 21-12 v1.1 November 2022 Page 24

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

structure

A design change No No Yes Certification

that alters the assumptions
aircraft flight invalidated.
characteristics or
performance from Requires a new AFM
the type design to address
would normally be performance and
significant if it flight characteristics.
appreciably
changes the
kinematics or
dynamics of the
aeroplane

A change in the No No Yes Changes in design

flight control and certification
concept for an assumptions.
aircraft, for example Requires extensive
to fly by wire (FBW) systems architecture
and side-stick and integration re-
control, or a change investigation.
from hydraulic to Requires a new
electronically AFM.
actuated flight
controls, would in
isolation normally be
regarded as a
significant change

Change to No No Yes An increase greater

aeroplane’s cabin than 10 % in
operating altitude, or maximum cabin
operating pressure pressure differential
invalidates
certification
assumptions and the
fundamental
approach used in
decompression,
structural strength,
and fatigue.

Addition of cabin No Yes Yes Extensive airframe

pressurisation changes affecting
system load paths, fatigue
evaluation, aero
elastic
characteristics, etc.
Invalidates design
assumptions.

AC 21-12 v1.1 November 2022 Page 25

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Changes in types Yes No Yes Emergency egress

and number of certification
emergency exits or specifications
an increase in exceed those
maximum previously
certificated substantiated.
passenger capacity Invalidates
assumptions of
certification.

A change in the No No Yes Extensive changes

required number of to avionics and
flight crew, which aircraft systems.
necessitates a Invalidates
complete cockpit re- certification
arrangement, and/or assumptions.
an increase in pilot Requires a new
workload would be a AFM.
significant change

Expansion of an No No Yes An appreciable

aircraft's operating expansion of
envelope operating capability
would normally be a
significant change
(e.g., an increase in
maximum altitude
limitation, approval
for flight in known
icing conditions, or
an increase in
airspeed limitations).
Merely operating a
product to an
expanded envelope
for which it was
originally designed is
generally not a
significant change. In
this case, the
assumptions used
for certification of the
basic product remain
valid and the results
can be applied to
cover the changed
product with
predictable effects or
can be demonstrated
without significant
changes to the
product.

AC 21-12 v1.1 November 2022 Page 26

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Replacement of an No No Yes A major change to

aviation gasoline the aeroplane. The
engine with an general configuration
engine of and principles of
approximately the construction will
same horsepower usually remain valid;
utilising diesel fuel however, the
assumptions for
certification are
invalidated.

Comprehensive No No Yes Affects avionics and

flight deck upgrade, electrical systems
such as conversion integration and
from entirely architecture
federated, concepts, or
independent electro- philosophies.
mechanical flight
instruments to
highly integrated
and combined
electronic display
systems with
extensive use of
software and/or
complex electronic
hardware

Introduction of No No Yes Invalidates original

autoland design assumptions.

Airframe life No No Yes This modification

extension pertains to fuselage
and/or wing limits,
and ageing
aeroplane concerns.
An increase from the
original life limit
which constitutes a
re-evaluation of
certification design
assumptions.

Extensive structural Yes No No Requires extensive

airframe changes to fuselage
modification, such structure, affects
as a large opening aircraft systems, and
in fuselage requires a new AFM
to address
performance and
flight characteristics.

Fuselage stretch or Yes No Yes Cabin interior

AC 21-12 v1.1 November 2022 Page 27

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

shortening in the changes are related

cabin or pressure changes since
vessel occupant safety
considerations are
impacted by a cabin
length change. Even
if a new cabin
interior is not
included in the
product level
change, the
functional effect of
the fuselage plug
has implications on
occupant safety
(e.g., the dynamic
environment in an
emergency landing,
emergency
evacuation, etc.),
and thus the existing
cabin interior
becomes an affected
area.

Conversion from Yes No Yes In many cases this

normal category to change could be
commuter category considered a
aeroplane substantial change
to the type design.
Therefore, a
proposed change of
this nature would be
subject to CASA
determination under
regulation 21.019.

AC 21-12 v1.1 November 2022 Page 28

 CLASSIFICATION OF DESIGN CHANGES

The following examples are for NOT SIGNIFICANT changes for Small Aeroplanes (Part 23):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Addition of wingtip No No No Although a major

modifications (not change to the
winglets) aeroplane, likely the
original general
configuration,
principles of
construction and
certification
assumptions remain
valid.

Installation of skis or No No No Although a major

wheel skis change to the
aeroplane, likely the
original general
configuration,
principles of
construction and
certification
assumptions remain
valid.

FLIR or surveillance No No No Additional flight or

camera installation structural evaluation
may be necessary
but the change does
not alter basic
aeroplane
certification.

Litter, berth and No No No

cargo tie down
device installation

Increased tire size, No No No

including tundra tires

Replacement of one No No No Although a major

propeller type with change to the
another (irrespective aeroplane, likely the
of increase in original general
number of blades) configuration,
principles of
construction and
certification
assumptions remain
valid.

Addition of a turbo- No No No
charger that does
not change the
power envelope,

AC 21-12 v1.1 November 2022 Page 29

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

operating range, or
limitations (e.g., a
turbo—normalised
engine, where the
additional power is
used to enhance
high altitude or hot
day performance)

Substitution of one No No No
method of bonding
for another (e.g.,
change in type of
adhesive)

Substitution of one No No No
type of metal for
another

Any change in No No No
construction or
fastening not
involving primary
structure

A new fabric type for No No No

fabric skinned
aircraft

Increase in flap No No No Although a major

speed or change to the
undercarriage limit aeroplane, likely the
speed original general
configuration,
principles of
construction and
certification
assumptions remain
valid.

Structural strength No No No Although a major

increases change to the
aeroplane, likely the
original general
configuration,
principles of
construction and
certification
assumptions remain
valid.

Instrument Flight No No No
Rules (IFR)

AC 21-12 v1.1 November 2022 Page 30

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

upgrades involving
installation of
components (where
the original
certification does not
indicate that the
aeroplane is not
suitable as an IFR
platform, e.g.,
special handling
concerns)

Fuel lines, where No No No

engine horsepower
is increased but fuel
flow is not increased
beyond the certified
maximum amount

Fuel tanks, where No No No

fuel is changed from
gasoline to diesel
fuel and tank support
loads are small
enough that an
extrapolation from
the previous analysis
would be valid.
Chemical
compatibility would
have to be
substantiated

Limited changes in a No No No Although a major

pressurisation change to the
system, e.g., number aeroplane, likely the
of outflow valves, original general
type of controller, or configuration,
size of pressurised principles of
compartment, but construction and
the system must be certification
re-substantiated if assumptions remain
the original test data valid.
is invalidated

Install a quieter No No No
exhaust system

Changes in engine No No No
cooling or cowling

Changing fuels of No No No Although a major

substantially the change to the

AC 21-12 v1.1 November 2022 Page 31

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

same type: Such as aeroplane, likely the

AvGas to AutoGas, original general
AvGas (80/87) to configuration,
AvGas (100LL), principles of
Ethanol to Isopropyl construction and
Alcohol, Jet B to Jet certification
A (although Jet A to assumptions remain
Jet B may be valid.
considered
significant due to the
fact that Jet B is
considered
potentially more
explosive)

Fuels that specify No No No Although a major

different levels of change to the
‘conventional’ fuel aeroplane, likely the
additives that do not original general
change the primary configuration,
fuel type. Different principles of
additives (MTBE, construction and
ETBE, ethanol, certification
amines, etc.) in assumptions remain
AvGas would not be valid.
considered a
significant change

A change to the No No No Although a major

maximum take-off change to the
weight of less than 5 aeroplane, likely the
% unless original general
assumptions made configuration,
in justification of the principles of
design are thereby construction and
invalidated certification
assumptions remain
valid. (Unless this
weight increase
would result in a shift
to commuter
category.)

An additional aileron No No No Although a major

tab (e.g. on the other change to the
wing) aeroplane, likely the
original general
configuration,
principles of
construction and
certification
assumptions remain
valid.

AC 21-12 v1.1 November 2022 Page 32

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Larger diameter No No No
flight control cables
with no change in
routing, or other
system design

Autopilot installation No No No Although a major

(for Instrument Flight change to the
Rules (IFR) use, aeroplane, likely the
where the original original general
certification does not configuration,
indicate that the principles of
aeroplane is not construction and
suitable as an IFR certification
platform) assumptions remain
valid.

Increased battery No No No
capacity or relocate
battery

Replace generator No No No
with alternator

Additional lighting No No No
(e.g., navigation
lights, strobes)

Higher capacity No No No
brake assemblies

Increase in fuel tank No No No Not a product level

capacity change, unless it is
tied with an increase
in gross weight.

Addition of an No No No
oxygen system

Relocation of a No No No
galley

Passenger to freight No No No Although a major

(only) conversion change to the
with no change to aeroplane, likely the
basic fuselage original general
structure configuration,
principles of
construction and
certification
assumptions remain
valid.

AC 21-12 v1.1 November 2022 Page 33

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Requires certification
substantiation
applicable to
freighter certification
specifications.

New cabin interior No No No

with no fuselage
length change

Installation of new No No No
seat belt or shoulder
harness

A small increase in No No No At product level, no

CG range change in general
configuration,
principles of
construction &
certification
assumptions.

APU Installation that No No No Although a major

is not flight essential change to the
aeroplane level,
likely the original
general
configuration,
principles of
construction and
certification
assumptions remain
valid.

An alternative No No No
autopilot

Addition of Class B No No No
Terrain Awareness
and Warning
Systems (TAWS)

AC 21-12 v1.1 November 2022 Page 34

 CLASSIFICATION OF DESIGN CHANGES

Table 2: Examples of Changes for Transport Aeroplanes (Part 25)

The following examples are for SUBSTANTIAL changes for Transport Aeroplanes (Part 25):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Change in the N/A N/A N/A Proposed change in

number or location of design is so
engines, e.g., four to extensive that a
two wing-mounted substantially
engines or two wing- complete
mounted to two investigation of
body-mounted compliance with the
engines applicable
certification
specifications is
required.

Change from a high N/A N/A N/A Proposed change in

wing to low wing design is so
configuration extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Change from an all N/A N/A N/A Proposed change in

metal aeroplane to design is so
all composite extensive that a
primary structure substantially
(fuselage, wing, complete
empennage) investigation of
compliance with the
applicable
certification
specifications is
required.

Change of N/A N/A N/A Proposed change in

empennage design is so
configuration for extensive that a
larger aeroplanes substantially
(cruciform vs. ‘T’ or complete
‘V’ tail) investigation of
compliance with the
applicable
certification
specifications is
required.

Increase from N/A N/A N/A Proposed change in

AC 21-12 v1.1 November 2022 Page 35

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

subsonic to design is so
supersonic flight extensive that a
regime substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

The following examples are for SIGNIFICANT changes for Transport Aeroplanes (Part 25):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Reduction in the Yes No Yes Extensive changes

number of flight crew to avionics and
(In conjunction with aircraft systems.
flight deck update) Impact to crew
workload and human
factors, pilot type
rating.

Modify an aeroplane Yes No Yes New aircraft

for flight in known operating envelop.
icing conditions by Requires major new
adding systems for systems installation
ice detection and and aircraft
elimination evaluation.
Operating envelope
changed.

Conversion – Yes No Yes Extensive airframe

passenger or changes affecting
combination load paths,
freighter/passenger aeroelastic
to all freighter characteristics,
including cargo door, aircraft related
redesign floor systems for fire
structure and 9g net protection, etc.
or rigid barrier Design assumptions
changed from
passenger to
freighter.

Increase in cabin No No Yes Typically, a change

pressurisation greater than 10 % in
operational cabin
pressure differential.

AC 21-12 v1.1 November 2022 Page 36

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

May require
extensive airframe
changes affecting
load paths, fatigue
evaluation,
aeroelastic
characteristics, etc.
Invalidates design
assumptions.

Addition of leading Yes No No Requires extensive

edge slats changes to wing
structure, adds
aircraft level
systems, and
requires a new AFM
to address
performance and
flight characteristics.

Fuselage stretch or Yes No Yes Cabin interior

shortening in the changes are related
cabin or pressure changes since
vessel occupant safety
considerations are
impacted by a cabin
length change. Even
if a new cabin
interior is not
included in the
product level
change, the
functional effect of
the fuselage plug
has implications on
occupant safety
(e.g., the dynamic
environment in an
emergency landing,
emergency
evacuation, etc.),
and thus the cabin
interior becomes an
affected area.

Extensive structural Yes No No Requires extensive

airframe changes to fuselage
modification, such as structure, affects
installation of a large aircraft level
telescope with large systems, and
opening in fuselage requires a new
aeroplane flight

AC 21-12 v1.1 November 2022 Page 37

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

manual to address
performance and
flight characteristics.

Changing the Yes No No Requires extensive

number of axles or changes to aircraft
number of landing structure, affects
gear done in context aircraft l systems
with a product level and requires AFM
change which changes.
involves changing
the aeroplane gross
weight

Primary structure No Yes No Change in principles

changes from of construction and
metallic material to design from
composite material conventional
practices.

Airframe life No No Yes This modification

extension pertains to fuselage
and/or wing limits,
and ageing
aeroplane concerns.
An increase from the
original life limit
which constitutes a
re-evaluation of
certification design
assumptions.

Typically, an No No Yes Requires extensive

increase in design re-substantiation of
weight of more than aircraft structure,
10% aircraft performance
and flying qualities
and associated
systems.

Installation of Yes No Yes

winglets

Wing changes in Yes No Yes When it requires

span, sweep, and tip extensive changes to
designs or wing wing structure, adds
chord aircraft level
systems, and
requires a new AFM
to address
performance and
flight characteristics.

AC 21-12 v1.1 November 2022 Page 38

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Note: Potentially
substantial if it is a
change from a high
wing to a low wing,
or a new wing.

Change in type or Yes No Yes The new emergency

number of egress certification
emergency exits or specifications
an increase in the exceed those
maximum previously
certificated number substantiated.
of passengers
demonstrated

Comprehensive No No Yes Affects avionics and

flight deck upgrade, electrical systems
such as conversion integration and
from entirely architecture
federated, concepts and
independent electro- philosophies.
mechanical flight
instruments to highly
integrated and
combined electronic
display systems with
extensive use of
software and
possibly complex
hardware

Change in primary No No Yes When the degree of

flight controls to fly change is so
by wire (FBW) extensive that it
system. (Some affects basic aircraft
aeroplanes have systems integration
some degree of and architecture
FBW. Achieving full concepts and
FBW may be a not philosophies. This
significant change drives a complete re-
on some assessment of flight
aeroplanes.) crew workload,
handling qualities,
and performance
evaluation, which are
different from the
original design
assumptions.

Replace Yes No No Requires extensive

reciprocating with changes to airframe
turbo-propeller structure, adds
engines aircraft level

AC 21-12 v1.1 November 2022 Page 39

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

systems, and
requires a new AFM
to address
performance and
flight characteristics.

Typically a thrust No No Yes Requires extensive

increase of more re-substantiation of
than 10% powerplant
installation, and has
a marked effect on
aircraft performance
and flying qualities.

Initial installation of No No Yes Baseline aeroplane

an autoland system not designed for
autoland operation,
potential crew work
load and systems
compatibility issues

Installation of a new No No Yes Requires changes to

fuel tank (horizontal airframe, systems
stabiliser tank or and AFM. Results in
auxiliary fuel tank in performance
the fuselage outside changes.
the wing in
conjunction with
increased maximum
take-off weight and
take-off thrust)

Main deck cargo Yes No No Redistribution of

door installation internal loads,
change in
aeroelastic
characteristics,
system changes.

Expansion of an No No Yes An expansion of

aircraft’s operating operating capability
envelope would normally be a
significant change
(e.g. an increase in
maximum altitude
limitation, approval
for flight in known
icing conditions, or
an increase in
airspeed limitations).

Merely operating a
product to an

AC 21-12 v1.1 November 2022 Page 40

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

expanded envelope
for which it was
originally designed is
generally not a
significant change.

In this case, the

assumptions used
for certification of the
basic product remain
valid and the results
can be applied to
cover the changed
product with
predictable effects or
can be demonstrated
without significant
physical changes to
the product.

Conversion from a No No Yes Completely new floor

passenger floor to a loading and design.
cargo floor and Redistribution of
installation of a internal loads,
cargo handling change in cabin
system safety certification
specifications,
system changes.

Initial installation of No No Yes Changes emergency

an APU essential for electrical power
aircraft flight certification
operation specifications,
change in AFM and
operating
characteristics.

Conversion from No No Yes Assumptions of

hydraulically certification for
actuated brakes to aeroplane
electrically actuated performance are
brakes changed.

Change to No No Yes An increase greater

aeroplane’s cabin than 10 % in
operating altitude, or maximum cabin
operating pressure pressure differential
invalidates
certification
assumptions and the
fundamental
approach used in
decompression.

AC 21-12 v1.1 November 2022 Page 41

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

structural strength,
and fatigue analysis.

Installation of engine Yes No Yes

thrust reversers

The following examples are for NOT SIGNIFICANT changes for Transport Aeroplanes (Part
25):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Alternate engine No No No Typically it is not

installation or hush significant so long as
kit at same position there is not more
than a 10% increase
in thrust or a change
in the principles of
propulsion.

A small change in No No No For cruise

fuselage length due performance
to re-fairing the aft reasons, where such
body or radome changes do not
require extensive
structural, systems,
aerodynamic or AFM
changes.

Re-fairing of wing tip No No No Does not require

caps (for lights, fuel extensive structural,
dump pipes) and AFM, or systems
addition of splitter changes.
plates to the trailing
edge thickness of
the cruise airfoil

Additional power No No No Usually no change in

used to enhance basic operating
high altitude or hot envelope. Existing
day performance cert. data can be
extrapolated.

Could be significant
product change if the
additional power is
provided by
installation of a
rocket motor or
additional, on

AC 21-12 v1.1 November 2022 Page 42

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

demand engine due

to changes in
certification
assumptions.

Initial installation of No No See note It may be possible

an autopilot system that the modification
is adaptive in nature,
with no change to
original certification
assumptions.
However, in certain
cases the installation
of an auto-pilot may
include extensive
changes and design
features which
change the
assumptions for
certification (i.e.
installation of the
auto-pilot may
introduce a number
of additional
mechanical and
electronic failure
modes and change
the hazard
classification of given
aircraft level
failures).

Change from No No No Method of

assembled primary construction must be
structure to well understood.
monolithic or
integrally machined
structure

Modification to ice No No No Re-certification

protection systems required, but type-
certification basis is
adequate.

Brakes: design or No No No Re-certification

material change, required, but type-
e.g., steel to carbon certification basis is
adequate.

Redesign floor No No No By itself, this is not a

structure significant product
change. It is
significant if part of a

AC 21-12 v1.1 November 2022 Page 43

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

cargo conversion of
a passenger
aeroplane.

New cabin interior No No No A new cabin interior

with no fuselage includes new ceiling
length change and sidewall panels,
stowage, galleys,
lavatories, and seats.
New and novel
features in the cabin
interior may require
special conditions.

Many interior related

certification
specifications are
incorporated in
operational rules.
Even though the
design approval
holder may not be
required to comply
with these
certification
specifications, the
operator may be
required to comply.

A re-arrangement of No No No Re-arrangement
an interior (e.g. requires the use of
seats, galleys, the existing floor
lavatories, closets, mounting structure.
etc.)

Novel or unusual No No No Special conditions

method of could be required if
construction of a there are no existing
component certification
specifications that
adequately address
these features.

The component
change does not rise
to the product level
change.

Initial installation of a No No No A stand-alone initial

non-essential APU APU installation on
an aeroplane
originally designed to
use ground/airport

AC 21-12 v1.1 November 2022 Page 44

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

supplied electricity,
and air-conditioning.
In this case, the APU
would be an option
to be independent of
airport power.

Table 3: Examples of Changes for Rotorcraft (Parts 27 and 29)

The following examples are for SUBSTANTIAL changes for Rotorcraft (Parts 27 and 29):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Change from the N/A N/A N/A Proposed change in

number and/or design is so
configuration of extensive that a
rotors (e.g. main & substantially
tail rotor system to complete
two main rotors investigation of
compliance with the
applicable
certification
specifications is
required.

Change from an all- N/A N/A N/A Proposed change in

metal rotorcraft to all design is so
composite rotorcraft extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required

AC 21-12 v1.1 November 2022 Page 45

 CLASSIFICATION OF DESIGN CHANGES

The following examples are for SIGNIFICANT changes for Rotorcraft (Parts 27 and 29):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Comprehensive flight No No Yes Affects avionics and

deck upgrade, such electrical systems
as conversion from integration and
entirely federated, architecture
independent electro- concepts and
mechanical flight philosophies.
instruments to highly
integrated and
combined electronic
display systems with
extensive use of
software and/or
complex electronic
hardware

Certification for flight No No Yes

into known icing
conditions

(Fixed) flying No No Yes This drives a

controls from complete re-
mechanical to fly by assessment of the
wire rotorcraft
controllability and
flight control failure.

Addition of an Yes Yes Yes May be a substantial

engine; e.g., from change depending
single to twin or upon project details.
reduction of the
number of engines;
e.g., from twin to
single

A change of rotor No Yes Yes

drive system primary
gearbox splash type
lubrication system to
a pressure lubricated
system due to an
increase in
horsepower of an
engine or changing a
piston engine to a
turbine engine

A fuselage or tail Yes No Yes

boom modification
that changes the
primary structure,
aerodynamics, and
operating envelope

AC 21-12 v1.1 November 2022 Page 46

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

sufficiently to
invalidate the
certification
assumptions

Application of an No Yes Yes

approved primary
structure to a
different approved
model (e.g.,
installation on a
former model of the
main rotor approved
on a new model that
results in increase
performance

Extensive primary No Yes Yes Change in principles

structure changes of construction and
from metallic assumptions used
material to for certification for
composite material. the product level
change. Changes of
a few individual
elements from metal
to composite are not
typically considered
a significant change .

Emergency Medical No No Yes Many EMS

Service (EMS) configurations will
configuration with not be classified as
primary structural significant.
changes sufficient to Modifications made
invalidate the for EMS are typically
certification internal, and the
assumptions general external
configuration is
normally not
affected. These
changes should not
automatically be
classified as
significant.

Skid landing gear to Yes No Yes

wheel landing gear
or wheel landing to
skid

Change of the Yes No Yes

number of rotor
blades

AC 21-12 v1.1 November 2022 Page 47

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Change tail anti- Yes Yes No

torque device (e.g.,
tail rotor, ducted fan
or other technology)

Passenger Yes No Yes Depends on the fire

configured helicopter fighting
to a fire fighting configuration.
equipment
configured helicopter

Passenger Yes No Yes Depends on the

configured helicopter agricultural
to an agricultural configuration.
configured helicopter

A new Category A No No Yes

certification approval
to an existing
configuration

Instrument Flight No No Yes

Rules (IFR)
upgrades involving
installation of
upgraded
components for new
IFR configuration

Human External No No Yes Must comply with the

Cargo (HEC) latest HEC
certification approval certification
specifications in
order to obtain
operational approval.
HEC include fatigue,
Quick Release
Systems, High
Intensity Radio
Frequency (HIRF),
One Engine
Inoperative (OEI)
performance and
OEI procedures.

Reducing the No No Yes

number of pilots for
IFR from 2 to 1

AC 21-12 v1.1 November 2022 Page 48

 CLASSIFICATION OF DESIGN CHANGES

The following examples are for NOT SIGNIFICANT changes for Rotorcraft (Parts 27 and 29):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions
configuration? of construction? used for
certification been
invalidated?

Emergency floats No No No Must comply with

the specific
applicable
certification
specifications for
emergency floats.
This installation, in
itself, does not
change the
rotorcraft
configuration,
overall
performance, or
operational
capability.
Expanding an
operating envelope
(such as operating
altitude and
temperature) and
mission profile
(such as passenger
carrying operations
to external load
operations, or flight
over water, or
operations in snow
conditions) are not
by themselves so
different that the
original certification
assumptions are no
longer valid at the
type-certificated
product level.

FLIR or surveillance No No No Additional flight or

camera installation structural
evaluation may be
necessary but the
change does not
alter the basic
rotorcraft
certification.

Helicopter Terrain No No No Certified per

Awareness Warning rotorcraft HTAWS
System (HTAWS) AC guidance
for operational material and
credit ETSO-C194.

AC 21-12 v1.1 November 2022 Page 49

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions
configuration? of construction? used for
certification been
invalidated?

Health Usage No No No Certified per

Monitoring System rotorcraft HUMS
(HUMS) for AC guidance
Maintenance Credit material.

Expanded No No No Expanding an
limitations with operating envelope
minimal or no (such as operating
design changes, altitude and
following further temperature) and
tests/justifications or mission profile
different mix of (such as passenger
limitations (CG carrying operations
limits, oil to external load
temperatures, operations, or flight
altitude, over water, or
minimum/maximum operations in snow
weight, conditions) are not
minimum/max by themselves so
external different that the
temperatures, original certification
speed, ratings assumptions are no
structure) longer valid at the
type-certificated
product level.

Installation of a new No No No Refer to AC 27-1 or

engine type, AC 29-2 for
equivalent to the guidance
former one; leaving
a/c installation and
limitations
substantially
unchanged

Windscreen No No No Does not change

installation the rotorcraft
overall product
configuration

Snow skis, ‘Bear No No No Must comply with

Paws’ specific certification
specifications
associated with the
change. Expanding
an operating
envelope (such as
operating altitude
and temperature)
and mission profile
(such as passenger
carrying operations

AC 21-12 v1.1 November 2022 Page 50

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions
configuration? of construction? used for
certification been
invalidated?

to external load
operations, or flight
over water, or
operations in snow
conditions) are not
by themselves so
different that the
original certification
assumptions are no
longer valid at the
type-certificated
product level.

External Cargo No No No Must comply with

Hoist the specific
applicable
certification
specifications for
external loads. This
installation, in itself,
does not change
the rotorcraft
configuration,
overall
performance, or
operational
capability.
Expanding an
operating envelope
(such as operating
altitude and
temperature) and
mission profile
(such as passenger
carrying operations
to external load
operations, or flight
over water, or
operations in snow
conditions) are not
by themselves so
different that the
original certification
assumptions are no
longer valid at the
type-certificated
product level.

Instrument Flight No No No Not a rotorcraft

Rules (IFR) level change.
upgrades involving
installation of
upgraded

AC 21-12 v1.1 November 2022 Page 51

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions
configuration? of construction? used for
certification been
invalidated?

components to
replace existing
components

Table 4: Examples of Changes for Engines (Part 33)

The following are examples of SUBSTANTIAL changes for Engines (Part 33):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Turbine Engines

Traditional N/A N/A N/A Proposed change in

turbofan to geared- design is so
fan engine extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Note: There may be

certain
circumstances
where this change
would be significant.

Low bypass ratio N/A N/A N/A Proposed change in

engine to high design is so
bypass ratio extensive that a
engine with an substantially
increased inlet complete
area investigation of
compliance with the
applicable
certification
specifications is
required.

Note: There may be

certain
circumstances
where this change
would be significant.

AC 21-12 v1.1 November 2022 Page 52

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Turbojet to N/A N/A N/A Proposed change in

Turbofan design is so
extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Note: There may be

certain
circumstances
where this change
would be significant.

Turbo-shaft to N/A N/A N/A Proposed change in

turbo-propeller design is so
extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Note: There may be

certain
circumstances
where this change
would be significant.

Conventional N/A N/A N/A Proposed change in

ducted fan to design is so
unducted fan extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

Note: There may be

certain
circumstances
where this change
would be significant.

AC 21-12 v1.1 November 2022 Page 53

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Turbine engine for N/A N/A N/A Proposed change in

subsonic operation design is so
to afterburning extensive that a
engine for substantially
supersonic complete
operation investigation of
compliance with the
applicable
certification
specifications is
required.

Increase/decrease Yes No Yes Change is

in the number of associated with
compressor/turbine other changes to
stages with the ratings and
resultant change in operating
approved limitations; engine
limitations* dynamic behaviour
(* excludes life in terms of
limits) backbone bending,
torque spike effects
on casing, surge
and stall
characteristics, etc.

New design fan Yes No Yes Change is

blade and fan hub, associated with
or a bladed fan other changes to
disk to a blisk or a the engine thrust,
fan diameter ratings and
change that could operating
not be retrofitted limitations; engine
dynamic behaviour
in terms of
backbone bending,
torque spike effects
on casing, foreign
object ingestion
behaviour, burst
model protection for
the aircraft. If there
is a diameter
change, installation
will be also affected.

Hydro-Mechanical Yes No No Change in engine

control to control
FADEC/EEC configuration.
without hydro-
mechanical backup Not
interchangeable.
Likely fundamental

AC 21-12 v1.1 November 2022 Page 54

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

change to engine
operation.

A change in the No Yes No Change in methods

containment case of construction that
from hard-wall to have affected
composite inherent strength,
construction or backbone bending,
vice-versa, that blade to case
could not be clearance retention,
retrofitted without containment wave
additional major effect on
changes to the installation, effect
engine or on burst model,
restrictions in the torque spike effects.
initial limitations in
the installation
manual

Replace gas No No Yes Change is

generator (core, associated with
turbine/compressor other changes that
/combustor) with a would affect engine
different one that is thrust/power and
associated with may affect the
changes in dynamic behaviour
approved of the engine.
limitations*
* excludes life Assumptions used
limits for certification may
no longer be valid.

Piston Engines

Convert from Yes Yes No Change in engine

mechanical to configuration:
electronic control Installation interface
system of engine changed.

Changes to
principles of
construction: Digital
controllers and
sensors require new
construction
techniques and
environmental
testing.

Add turbocharger Yes No Yes Change in general

that increases configuration:
performance and Installation interface
changes in overall of engine changed

AC 21-12 v1.1 November 2022 Page 55

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

product (exhaust system).

Certification
assumptions
invalidated: Change
in operating
envelope and
performance.

Convert from air- Yes No Yes Change in general

cooled cylinders to configuration:
liquid cooled Installation interface
cylinders of engine changed
(cooling lines from
radiator, change to
cooling baffles).

Certification
assumptions
invalidated:
• Change in
operating
envelope and
engine
temperature
specifications.

Convert from Yes No Yes Change in general

spark-ignition to configuration:
compression- Installation interface
ignition of engine changed
(no mixture lever).

Certification
assumptions
invalidated: Change
in operating
envelope and
performance.

AC 21-12 v1.1 November 2022 Page 56

 CLASSIFICATION OF DESIGN CHANGES

The following are examples of SIGNIFICANT changes for Engines (Part 33):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions
configuration? of construction? used for
certification been
invalidated?

Turbine Engines

Increase/decrease in Yes No Yes Change is

the number of associated with
compressor/turbine other changes to
stages with resultant the ratings and
change in approved operating
limitations*. limitations; engine
(* excludes life dynamic behaviour
limits) in terms of
backbone bending,
torque spike effects
on casing, surge
and stall
characteristics, etc.

New design fan Yes No Yes Change is

blade and fan hub, associated with
or a bladed fan disk other changes to
to a blisk or a fan the engine thrust,
diameter change ratings and
that could not be operating
retrofitted limitations; engine
dynamic behaviour
in terms of
backbone bending,
torque spike effects
on casing, foreign
object ingestion
behaviour, burst
model protection for
the aircraft. If there
is a diameter
change, installation
will be also affected.

Hydro-Mechanical Yes No No Change in engine

control to control
FADEC/EEC without configuration.
hydro-mechanical
backup Not
interchangeable.
Likely fundamental
change to engine
operation.

A change in the No Yes No Change in methods

containment case of construction that
from hard-wall to have affected
composite inherent strength,
construction or vice- backbone bending,

AC 21-12 v1.1 November 2022 Page 57

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions
configuration? of construction? used for
certification been
invalidated?

versa, that could not blade to case

be retrofitted without clearance retention,
additional major containment wave
changes to the effect on
engine installation, effect
or restrictions in the on burst model,
initial limitations in torque spike effects.
the installation
manual

Replace gas No No Yes Change is

generator (core, associated with
turbine/compressor/ other changes that
combustor) with a would affect engine
different one that is thrust/power and
associated with may affect the
changes in approved dynamic behaviour
limitations* of the engine.
* excludes life limits
Assumptions used
for certification may
no longer be valid

Piston Engines

Convert from Yes Yes No Change in engine

mechanical to configuration:
electronic control Installation interface
system of engine changed.

Changes to
principles of
construction: Digital
controllers and
sensors require new
construction
techniques and
environmental
testing.

Add turbocharger Yes No Yes Change in general

that increases configuration:
performance and Installation interface
changes in overall of engine changed
product (exhaust system).

Certification
assumptions
invalidated: Change
in operating
envelope and
performance.

AC 21-12 v1.1 November 2022 Page 58

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions
configuration? of construction? used for
certification been
invalidated?

Convert from air- Yes No Yes Change in general

cooled cylinders to configuration:
liquid cooled Installation interface
cylinders. of engine changed
(cooling lines from
radiator, change to
cooling baffles).

Certification
assumptions
invalidated:
• Change in
operating
envelope and
engine
temperature
specifications.

Convert from spark- Yes No Yes Change in general

ignition to configuration:
compression-ignition Installation interface
of engine changed
(no mixture lever).

Certification
assumptions
invalidated: Change
in operating
envelope and
performance.

The following are examples of NOT SIGNIFICANT changes for Engines (Part 33):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Turbine Engines

Change in the No No No No change in

material from one performance.
type of metal to
another type of Assumptions are still
metal of a valid.
compressor drum

Increase/decrease in No No No No change in
the number of performance.
compressor/turbine
stages without Assumptions are still

AC 21-12 v1.1 November 2022 Page 59

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

resultant change in valid.

performance
envelope

New components No No No No change in

internal to the configuration.
FADEC/EEC the
introduction of which Retrofitable.
does not change the
function of the Assumptions used
system for certification are
still valid.

Possible changes in
principles of
construction are
insignificant.

Software changes No No No

Rub-strip design No No No
changes

A new combustor No No No
that does not change
the approved
limitations, or
dynamic behaviour*
(* excludes life
limits)

Bearing changes No No No

New blade designs No No No

with similar material
that can be
retrofitted

Fan blade re-design No No No

that can be
retrofitted

Oil tank re-design No No No

Change from one No No No

hydro-mechanical
control to another
hydro-mechanical
control

Change to limits on No No No
life limited
components

AC 21-12 v1.1 November 2022 Page 60

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Changes to limits on No No No
exhaust gas
temperature

Changes in No No No
certification
maintenance
requirements (CMR)
with no configuration
changes

Bump ratings within No No No

the product’s
physical capabilities
that may be
enhanced with gas
path changes such
as blade re-stagger,
cooling hole
patterns, blade
coating changes,
etc.

A change in principal No No No
physical properties
and mechanics of
load transfer of a
material of primary
structure or highly
loaded components.
For example,
change from
traditional metal to
either an exotic alloy
or a composite
material on a highly
loaded component

Piston Engines

A change in principal No No No
physical properties
and mechanics of
load transfer of a
material of primary
structure or highly
loaded components.
For example,
change from
traditional metal to
either an exotic alloy
or a composite
material on a highly

AC 21-12 v1.1 November 2022 Page 61

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

loaded component

New or redesigned No No No
cylinder head, or
valves or pistons

Changes in No No No
crankshaft

Changes in No No No
crankcase

Changes in No No No
carburettor

Changes in No No No
mechanical fuel
injection system

Changes in No No No
mechanical fuel
injection pump

Engine model No No No
change to
accommodate new
aeroplane
installation. No
change in principles
of operation of major
subsystems; no
significant expansion
in power or
operating envelopes
or in limitations

No change in basic No No No
principles of
operation, or a
simple mechanical
change. For
example, change
from dual magneto
to two single
magnetos on a
model.

Subsystem change No No No
produces no
changes in base
engine input
parameters, and
previous analysis

AC 21-12 v1.1 November 2022 Page 62

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

can be reliably
extended.

For example, a
change in
turbocharger where
induction system
inlet conditions
remain unchanged,
or if changed, the
effects can be
reliably extrapolated.

Change in material No No No
of secondary
structure or not
highly loaded
component. For
example, a change
from metal to
composite material
in a non-highly
loaded component,
such as an oil pan
that is not used as a
mount pad.

Change in material No No No
that retains the
physical properties
and mechanics of
load transfer. For
example, a change
in trace elements in
a metal casting for
ease of pouring or to
update to a newer or
more readily
available alloy with
similar mechanical
properties.

AC 21-12 v1.1 November 2022 Page 63

 CLASSIFICATION OF DESIGN CHANGES

Table 4: Examples of Changes for Propellers (Part 35)

The following are examples of SUBSTANTIAL changes for Propellers (Part 35):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Change in the N/A N/A N/A Proposed change in

number of blades design is so
extensive that a
substantially
complete
investigation of
compliance with the
applicable
certification
specifications is
required.

The following are examples of SIGNIFICANT changes for Propellers (Part 35):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Principle of pitch Yes Yes Yes Requires extensive

change such as a modification of the
change from single pitch change system
acting to dual acting with the introduction
of back-up systems.

The inherent control

system requires re-
evaluation.

Introduction of a Yes Yes No Requires extensive

different principle of modification of the
blade retention such propeller hub and
as a single row to a blade structure.
dual row bearing
The inherent
strength requires re-
evaluation.

A hub configuration Yes Yes No Requires extensive

change such as a modification of the
split hub to a one- propeller hub
piece hub structure.

The inherent
strength requires re-
evaluation.

Changing the Yes Yes No Requires extensive

AC 21-12 v1.1 November 2022 Page 64

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

method of mounting modification of the

the propeller to the propeller hub
engine such as a structure.
spline to a flange
mount Note: Such a change
could be considered
not significant if
implemented without
a change in general
configuration or
principals of
construction.

Change in hub Yes Yes No Requires extensive

material from steel to modification of the
aluminium propeller hub
structure and change
to method of blade
retention.

The inherent
strength requires re-
evaluation.

Change in blade Yes Yes Yes Requires extensive

material from metal modification of the
to composite propeller blade
structure and change
to method of blade
retention. Composite
construction
methods required.

The inherent
strength requires re-
evaluation.

Change from hydro- Yes Yes Yes Electronic

mechanical to manufacturing and
electronic control design methods
required.

Assumptions used
for certification are
no longer valid or
were not addressed
in the original
certification, i.e., high
intensity radio
frequency (HIRF)
and lightning
protection, fault
tolerance, software

AC 21-12 v1.1 November 2022 Page 65

 CLASSIFICATION OF DESIGN CHANGES

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

certification and
other aspects.

The propeller will

require special
conditions under
21.016.

The following are examples of NOT SIGNIFICANT changes for Propellers (Part 35):

Description of Is there a change Is there a change Have the Notes

change to the general to the principles assumptions used
configuration? of construction? for certification
been invalidated?

Change in the No No No
material of a blade
bearing

Change to a No No No
component in the
control system

Change to a de-icer No No No
boot

Changes to the No No No Propeller's operating

operational design characteristics and
envelope such as an inherent strength
increase in power. require re-
evaluation.

Change to the No No No Propeller's operating

intended usage such characteristics and
as normal to inherent strength
aerobatic category require re-
evaluation.

AC 21-12 v1.1 November 2022 Page 66

 CLASSIFICATION OF DESIGN CHANGES

Reserved for future use

AC 21-12 v1.1 November 2022 Page 67

 CLASSIFICATION OF DESIGN CHANGES

Reserved for future use

AC 21-12 v1.1 November 2022 Page 68

 CLASSIFICATION OF DESIGN CHANGES

Reserved for future use

AC 21-12 v1.1 November 2022 Page 69

 CLASSIFICATION OF DESIGN CHANGES

Examples of major modifications

AC 21-12 v1.1 November 2022 Page 70

 CLASSIFICATION OF DESIGN CHANGES

E.1 Examples of major modifications per discipline

E.1.1 The information below is intended to provide some examples of major changes per
discipline. It is not intended to present a comprehensive list of all major changes.
Examples are categorised by discipline and are applicable to all aircraft, engines and
propellers. However, a particular change may involve more than one discipline, for
example a change to engine controls may be covered in engines and systems
(software).
E.1.2 Those involved with classification should always be aware of the interaction between
disciplines and the consequences this will have when assessing the effects of a change
(e.g. operations and structures, systems and structures, systems and systems).
E.1.3 Where in this list of examples the words ‘has effect’ or ‘affect(s)’ are used, they are to
be understood as being the opposite of ‘no appreciable effect’ as in the definition of
minor change in regulation 21.093. The words ‘has appreciable effect’ and ‘appreciably
affect(s)’ have been used to improve readability.

E.1.4 Structure
E.1.4.1 Changes such as a cargo door cut-out, fuselage plugs, change of dihedral, addition of
floats.
E.1.4.2 Changes to materials, processes or methods of manufacture of primary structural
elements, such as spars, frames and critical parts.
E.1.4.3 Changes that adversely affect fatigue or damage tolerance or life limit characteristics.
E.1.4.4 Changes that adversely affect aeroelastic characteristics.

E.1.5 Cabin Safety

E.1.5.1 Changes which introduce a new cabin layout of sufficient change to require a re-
assessment of emergency evacuation capability or which adversely affect other aspects
of passenger or crew safety. Items to consider include, but are not limited to:
a. changes to or introduction of dynamically tested seats
b. change to the pitch between seat rows
c. change of distance between seat and adjacent obstacle like a divider
d. changes to cabin lay outs that affect evacuation path or access to exits
e. installation of new galleys, toilets, wardrobes, etc.
f. installation of new type of electrically powered galley insert
g. changes to the pressurisation control system which adversely affect previously
approved limitations.

E.1.6 Flight
E.1.6.1 Changes which adversely affect the approved performance, such as high altitude
operation, brake changes that affect braking performance.
E.1.6.2 Changes which adversely affect the flight envelope.

AC 21-12 v1.1 November 2022 Page 71

 CLASSIFICATION OF DESIGN CHANGES

E.1.6.3 Changes which adversely affect the handling qualities of the product including changes
to the flight controls function (gains adjustments, functional modification to software) or
changes to the flight protection or warning system.

E.1.7 Systems
E.1.7.1 For systems assessed under FAR or CS 25.1309, the classification process is based on
the functional aspects of the change and its potential effects on safety.
E.1.7.2 Where failure effect is 'Catastrophic' or 'Hazardous', the change should be classified as
major.
E.1.7.3 Where failure effect is 'major', the change should be classified as major if:
a. aspects of the compliance demonstration use means that have not been previously
accepted for the nature of the change to the system
b. the change affects the pilot/system interface (displays, controls, approved
procedures), or
c. the change introduces new types of functions/systems such as GPS primary,
TCAS, Predictive windshear, HUD.
E.1.7.4 The assessment of the criteria for software changes to systems also needs to be
performed.
E.1.7.5 When software is involved, account should be taken also of the following guidelines:
a. Where a change is made to software produced in accordance with the guidelines of
the latest edition of EASA AMC 20-115 (or equivalent, see EASA AMC-20
document) the change should be classified as major if any of the following apply,
and the failure effect is Catastrophic, Hazardous or Major:
i. the executable code for software, determined to be Level A or Level B in
accordance with the guidelines, is changed unless that change involves only a
variation of a parameter value within a range already verified for the previous
certification standard
ii. the software is upgraded to or downgraded from Level A, Level B or Level C,
or
iii. the executable code, determined to be level C, is deeply changed, e.g. after a
software re-engineering process accompanying a change of processor.
E.1.7.6 For software developed to guidelines other than the latest edition of EASA AMC 20-115
(or equivalent), the applicant should assess changes in accordance with the foregoing
principles.
E.1.7.7 For other codes the principles noted above may be used. However, due consideration
should be given to specific certification specifications/interpretations.
E.1.7.8 A change to a system should be classified as minor where the failure effect would have
no adverse safety implications of any flight operation.
E.1.7.9 For more information see FAA AC 23.1309-1, FAA AC 25.1309-1 and EASA CS-25
AMC 25.1309.

AC 21-12 v1.1 November 2022 Page 72

 CLASSIFICATION OF DESIGN CHANGES

E.1.8 Propellers
E.1.8.1 Changes to:
a. diameter
b. airfoil
c. planform
d. material
e. blade retention system, etc.

E.1.9 Engines
E.1.9.1 Changes:
a. that adversely affect operating speeds, temperatures, and other limitations
b. that affect or introduce parts identified by CS E-510 or FAR 33.75 where the failure
effect has been shown to be hazardous
c. that affect or introduce engine critical parts or their life limits
d. to a structural part which requires a re-substantiation of the fatigue and static load
determination used during certification
e. to any part of the engine which adversely affects the existing containment capability
of the structure
f. that adversely affect the fuel, oil and air systems, which alter the method of
operation, or require reinvestigation against the type-certification basis
g. that introduce new materials or processes, particularly on critical components.

E.1.10 Rotors and drive systems

E.1.10.1 Changes that:
a. adversely affect fatigue evaluation unless the service life or inspection interval are
unchanged. This includes changes to materials, processes or methods of
manufacture of parts, such as:
i. rotor blades
ii. rotor hubs including dampers and controls
iii. gears
iv. drive shafts
v. couplings
b. affect systems the failure of which may have hazardous or catastrophic effects. The
design assessment will include:
i. cooling system
ii. lubrication system
iii. rotor controls
c. adversely affect the results of the rotor drive system endurance test, the rotor drive
system being defined in CS or FAR 27/29.917
d. adversely affect the results of the shafting critical speed analysis required by CS or
FAR 27/29.931.

AC 21-12 v1.1 November 2022 Page 73

 CLASSIFICATION OF DESIGN CHANGES

E.1.11 Environment
E.1.11.1 Where a change is made to an aircraft or aircraft engine, the effect of the change on the
product’s environmental characteristics should be taken into account. Examples of
changes that might have an appreciable effect on the product’s environmental
characteristics, and might therefore be classified as a major change, are listed below.
The examples are not exhaustive and will not, in every case, result in an appreciable
change to the product’s environmental characteristics, and therefore, will not per-se and
in every case result in a major change classification.
E.1.11.2 An appreciable effect is considered to be one which exceeds the ICAO criteria for a no-
acoustical change or a no-emissions change. For the definition of a no-acoustical
change refer to the section of the ICAO Environmental Technical Manual, Volume I
(ICAO Doc 9501, Volume I – Procedures for the Noise Certification of Aircraft)
concerning changes to aircraft type designs involving no-acoustical changes (see also
the definitions of a ‘derived version’ in ICAO Annex 16, Volume I). For the definition of a
no-emissions change refer to the section of the ICAO Environmental Technical Manual,
Volume II (ICAO Doc 9501, Volume II – Procedures for the Emissions Certification of
Aircraft Engines) concerning no-emissions changes.
Notes:
1. Noise and emissions certification, or lack of such certification, does not directly affect a design approval
under Part 21 of CASR. However, if an individual aircraft does not meet the relevant Australian
requirements, then it is illegal for that aircraft to operate in Australian territory, even though the aircraft
may have a valid certificate of airworthiness. If a design change would affect the existing noise or
emissions certification, then recertification will be required.
2. Aircraft noise is regulated by Airservices Australia under the Air Navigation (Aircraft Noise) Regulations
1984. Aircraft emissions are regulated by the Department of Infrastructure and Transport under the Air
Navigation (Aircraft Engine Emissions) Regulations. Further information regarding noise and emissions
certification is available on the Airservices Australia and Department of Infrastructure and Transport
websites.
3. The following examples should be considered, particularly in relation to designs intended for use in
foreign countries under international agreements.

Noise
E.1.11.3 A change that introduces either:
a. an increase in the noise certification level(s), or
b. a reduction in the noise certification level(s) for which the applicant wishes to take
credit.
E.1.11.4 Examples of noise-related changes that might lead to a major change classification are:
a. For jet and heavy (maximum take-off mass greater than 8618 kg) propeller-driven
aeroplanes:
i. A change that might affect the aircraft’s take-off performance including:
A. a change to the maximum take-off mass
B. a change to V2 (‘take-off safety speed’), or
C. a change to the lift augmentation devices, including their configuration
under normal take-off operating conditions.
ii. A change that might affect the aircraft’s landing performance including:
A. a change to the maximum landing mass

AC 21-12 v1.1 November 2022 Page 74

 CLASSIFICATION OF DESIGN CHANGES

B. a change to VREF (reference landing speed), or

C. a change to the lift augmentation devices, including their deployment
under normal landing operating conditions.
iii. A change to the Centre of Gravity (CG) limits
iv. A change that increases the aircraft’s drag
v. A change that alters the external profile of the aircraft, including the installation
or change of shape or size of any item on the external surface of the aircraft
that might protrude into the airflow such as winglets and vortex generators;
generally the installation of small antennas does not represent an acoustical
change
vi. A change that introduces an open-ended hollow cavity at more or less right
angles to the airflow (e.g. hollow pins in undercarriage assemblies)
vii. A change of engine or, if fitted, propeller type
viii. A change in engine thrust rating
ix. A change to the engine rotating parts or stators, such as geometry, blade
profile or blade number
x. A change to the aerodynamic flow lines through the engine
xi. A change that affects the engine thermodynamic cycle, including a change to
the engine’s bypass ratio
xii. A change to the engine nacelle, including a change to the acoustic liners
xiii. A change to the engine exhaust
xiv. A change to the engine bleed valves, including bleed valve scheduling
xv. A change in the operation of engine power off-takes (e.g. the operation of the
Environmental Control System (ECS) during a normal take-off or approach)
xvi. A change to the Auxiliary Power Unit (APU), including associated operating
limitations (e.g. a change that allows the APU to be operated during a normal
approach when previously it was not allowed)
xvii. A change to the propeller pitch and/or propeller speed during a normal take-off
or approach
xviii. A change that causes a change to the angle at which air flows into the
propeller.
b. For light (maximum take-off mass 8618 kg or less) propeller-driven aeroplanes:
i. A change that might affect the aircraft’s take-off performance including:
A. a change to the maximum take-off mass
B. a change to the take-off distance
C. a change to the rate of climb, or
D. a change to Vy (best rate of climb speed).
ii. A change that increases the aircraft’s drag (e.g. the installation of external
cargo pods, external fuel tanks, larger tyres to a fixed undercarriage, floats
etc.)
iii. A change of engine or propeller type
iv. A change in take-off power including a change in engine speed (tachometer
‘red line’) or, for piston engines, a change to the manifold pressure limitations

AC 21-12 v1.1 November 2022 Page 75

 CLASSIFICATION OF DESIGN CHANGES

v. A change to the highest power in the normal operating range (‘top of green
arc’)
vi. In the case of an aircraft where take-off power/engine speed is time limited, a
change in the period over which take-off power/engine speed may be applied
vii. A change to the engine inlet or exhaust including, if fitted, the inlet or exhaust
muffler
viii. A change in propeller diameter, tip shape, blade thickness or the number of
blades
ix. The installation of a variable or adjustable pitch propeller in place of a fixed
pitch propeller and vice versa
x. A change that causes a change to the angle at which air flows into the
propeller.
c. For helicopters:
i. A change that might affect the take-off and/or landing performance, including a
change in take-off mass and VY (best rate of climb speed)
ii. A change to VNE (never-exceed airspeed) or to VH (airspeed in level flight
obtained using the torque corresponding to minimum engine installed,
maximum continuous power available for sea level pressure, 25°C ambient
conditions at the relevant maximum certificated mass)
iii. A change to the maximum take-off engine power or maximum continuous
power
iv. A change to the gearbox torque limits
v. A change of engine type
vi. A change to the engine intake or exhaust
vii. A change to the maximum normal operating rpm of the main or tail rotors
viii. A change to the main or tail rotors, including a change in diameter, blade
thickness or blade tip profile.

Emissions
E.1.11.5 A change that introduces an increase or decrease in the emissions certification levels.
Examples of smoke and gaseous engine emission-related changes that might lead to a
major change classification are:
a. a change in engine thrust rating
b. a change to the aerodynamic flow lines through the engine
c. a change that affects the engine thermodynamic cycle, specifically relevant engine
cycle parameters (e.g. combustor pressure P3, combustor entry temperature T3,
Air Fuel Ratio (AFR))
d. a change to the compressor that might influence the combustor inlet conditions and
engine overall pressure ratio
e. a change to the combustor design (geometry)
f. a change to the cooling of the combustor
g. a change to the air mass flow through the combustor
h. a change that affects the fuel spray characteristics.

AC 21-12 v1.1 November 2022 Page 76

 CLASSIFICATION OF DESIGN CHANGES

E.1.12 Power plant Installation

E.1.12.1 Changes which include:
a. control system changes which affect the engine/propeller/airframe interface
b. new instrumentation displaying operating limits
c. modifications to the fuel system and tanks (number, size and configuration)
d. change of engine/propeller type.

AC 21-12 v1.1 November 2022 Page 77