Legal Interpretations
Magruder-AIR-143 2015
Summary
The Question
May a production approval holder install used propellers on new production aircraft?
Background
The FAA's Production Certification Branch (AIR-143) asked about used propellers, citing an earlier agency letter stating that parts returned to service under 14 CFR part 43 may, under certain conditions, be used to build new aircraft under 14 CFR part 21, subpart G.
The FAA’s Interpretation
Yes. Finding at that time no regulation, order, or guidance prohibiting it, the FAA allowed it as long as every propeller is manufactured under an FAA production approval (14 CFR 21.8), conforms to an approved design and is in condition for safe operation (14 CFR 21.137), is marked under 14 CFR part 45 (14 CFR 21.146), and has time- or life-limited parts tracked under 14 CFR 91.417 and 14 CFR part 43.
- Requester
- Magruder
- Organization
- AIR-143
- Issued
- May 11, 2015
- Subjects
- General Operating & Flight Rules · Maintenance & Repair Stations · Aircraft & Parts Certification
Regulations Cited
Page 1
INTEROFFICE MEMO
DATE: May 11, 2015
TO: Dave Magrnder
Production Certification Branch, AIR-143
FROM: Lorelei Pe~·~
Deputy Assistant Chief Counsel for Regulations, AGC-200
RE: Installation of used propellers on production aircraft
This memorandum responds to your email dated January 30, 2013, which asks whether our regulations permit the installation of used propellers on new production aircraft. Your email references a letter prepared for Terry Allen's 1 signature ("Allen letter"). The Allen letter does not directly address propellers, but states that, under certain conditions, aircraft parts returned to service in accordance with part 43 ofTitie 14 of the Code of Federal Regulations (14 CFR) may be used in the manufacture of new aircraft produced in accordance with 14 CFR part 21, subpart G-Production Certificates. AGC-210 concuned with the AIJen letter on Oct. 29, 2011, as indicated by Ed A verman' s written initials.
With respect to propellers, we have not at this time found any regulations, orders, or guidance prohibiting the installation of used propellers on production aircraft. We therefore conclude that a production approval holder may install a used propeller or propellers on a new production aircraft as long as all propellers installed on the new aircraft:
Are manufactured under an FAA production approval (14 CFR § 21.8);
Conform to an approved design and are in a condition for safe operation (14 CFR § 21.137);
3. Are marked in accordance withpa1t45 (14 CFR § 21.146); and 4. All time-limited or life-limited paits are tracked and identified in accordance with 14 CFR § 91.417 and part 43.
This letter was prepared by Benjamin Jacobs, an attorney in the Regulations Division of the Office of the Chief Counsel, and was coordinated with the Repair Station Branch (AFS-340) of the Flight Standards Service. If you need further assistance, please contact our office at (202) 267-3073.
1 At the time, Teny Allen was Acting Manager of the Production and Airworthiness Division.
Regulations Referenced
Snapshot retrieved August 6, 2026.