Goodbye Appliances! Hello Non-Installed Equipment (NIE)!

Following the publication of EASA’s Notice of Proposed Amendment 2025-02(A), significant clarifications have been set regarding the airworthiness of non-installed equipment (NIE).

Regulation (EU) 2018/1139, the Basic Regulation, formally introduced and defined NIE as any instrument, equipment, mechanism, apparatus, appurtenance, software or accessory carried on board of an aircraft by the aircraft operator, which is not a part, and which is used or intended to be used in operating or controlling an aircraft, supports the occupants’ survivability, or which could impact the safe operation of the aircraft’.

At the same time, the Basic Regulation removed the term “appliance” from high-level definitions. As a result, EASA now recognises three broad categories for certification:

• Product: an aircraft, an engine, or a propeller.

• Part: any element of a product, as defined by that product's type design.

• Non-installed equipment (NIE): as defined above.

Work is still underway to align the detailed implementing and continuing airworthiness regulations, which continue to reference appliances, with this updated terminology.

Not all NIE is treated the same

A key principle of the proposed regulatory changes is proportionality. NIE is not automatically treated as a component.

A component is any engine, propeller, part or non-installed equipment required to be approved in accordance with the applicable airworthiness requirements;

Only NIE that:

• is required by operational regulations (EU) No 965/2012, 2018/395, or 2018/1976, and

• must be approved in accordance with applicable airworthiness requirements

is included in the regulatory definition of a component.

This distinction matters. Only this subset of NIE is required to be maintained and released by a Part-145 (or Part-CAO) approved organisation. Other NIE remains under operator control, avoiding unnecessary regulatory burden.

Maintenance of NIE

Maintenance is redefined as the performance of tasks on an aircraft, a component for installation, or NIE that is required to ensure the continuing airworthiness of an aircraft or component for installation, or to ensure the serviceability of NIE. Maintenance includes any one or combination of overhaul, repair, inspection, replacement, modification, or defect rectification, excluding pre-flight inspection.

Fitting NIE on board aircraft is not considered maintenance. Maintenance involves performing tasks that actively ensure airworthiness or serviceability; simply placing an item on board does not meet this requirement.

Where ETSO fits — and where it doesn’t

Some NIE is issued with an ETSO authorisation. For NIE that does not fall under the definition of a component, an ETSO authorisation allows — but does not mandate — maintenance and certification under Part-145.

Conversely, Part-145 certification is not possible for NIE without an ETSO authorisation. This closes long-standing grey areas and prevents inconsistent maintenance practices across the EU.

Importantly, when NIE is maintained under Part-145, component maintenance standards apply: facilities, certifying staff, tools, maintenance data, and release procedures — except for requirements related to installation, which do not apply by definition.

Examples of Non-Installed Equipment (NIE)

To better understand NIE in practice, it helps to look at real examples from proposed EASA guidance.

NIE included in the definition of a component

Some NIE, when required by operational regulations and approved in accordance with applicable airworthiness requirements, are treated as components and must be maintained under Part-145 or Part-CAO. Examples include:

• Hand fire extinguishers, except when they are part of the aircraft type design

• Other emergency equipment required by operational regulations (portable lights, first-aid kits and emergency medical kits, megaphones), except when they are part of the type design.

NIE for which an airworthiness approval is not required but ETSO authorisation exists

Other NIE do not fall under the “component” definition, but may have an ETSO authorisation, allowing Part-145 organisations to maintain and certify them if desired:

• Cargo pallets, nets, and containers

• Galley equipment

Conclusion

While these changes are still proposed under NPA 2025-02(A), they clarify how non-installed equipment should be certified, maintained, and controlled, and aim to harmonize EU practices. Aircraft operators, CAMOs, maintenance organisations, and ETSOA applicants should be aware of these developments, as they will define the future regulatory framework for NIE once adopted.