PPRuNe Forums - View Single Post - China requires provenance of all foreign aircraft
Old 3rd Jun 2022, 23:48
  #8 (permalink)  
fdr
 
Join Date: Jun 2001
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Originally Posted by hoistop
Honestly, I don`t get it. Every airplane that I had flown/inspected/released to flight had a Certificate of Registration on board, where it was clearly stated who is the owner of that particular aircraft. If that document is forged, any other document, supporting that (false) claim, can be forged too.
A "Certificate of Registration" , CoR generally does not indicate who is the beneficial owner of an aircraft. Under the FAA's regs, it is an express statement that it does not indicate ownership, same for most CAA's Part 47. The CoR provides evidence of the party that is the contact point for the CAA for administrative matters.

Jurisdictionally dependent, the ICAO definition of operator is applied to the CoR, that is, whoever has the right to control the aircraft for 28 days or more will be recorded on the CoR, however that is CAA dependent, some note the 28 day period, but do not require notification to the CAA of parties with rights to control of the aircraft.

China is not necessarily acting unreasonably with their action, it is consistent with taking some care with not getting crosswise with the US led sanctions series, but it is a pain for many. The beneficial owner of a leased aircraft is not the operator as recorded on the CoR. It will become problematic for many FAR 91K operations, as there is a complex ownership requirement for such programs, but they are recorded so can be provided. For leased aircraft, the same applies, the documents of ownership and lease may differ from the CoR in fact generally must be different.

good work for lawyers.
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