After years of frustration, Europe is beginning to see a breakthrough in its ability to certify military aircraft to fly across the continent, as regulatory bodies in France and the U.K. are recognizing one another's work in declaring the Airbus A400M airworthy.

The problem of differing country-specific standards has grown in the last few decades. Not only do major cross-border defense procurement programs have to cope with individual national requirements, but they carry the cost that comes with a series of expensive trials for each certification.

With programs becoming more complex and encompassing a wider number of countries, all facing the same economic strains, work is underway—supported by industry—to develop a common set of rules.

The Military Airworthiness Authorities Forum, known as MAWA and established by the European Defense Agency (EDA), is developing a set of European Military Airworthiness Regulations (EMAR). Work began in 2008, with a study of the military standards across the EDA's member states. The first success came this year with the DSAE, France's through-life airworthiness authority, and the U.K. Military Aviation Authority (MAA) recognizing each other's activities on the A400M.

“There have been lots of attempts at harmonizing airworthiness rules across Europe, but many of these were no more than discussion groups, a gentleman's club, and there were no real outcomes,” says one airworthiness official.

The EMARs are harmonized regulations that countries have the option to adopt to benefit from European Aviation Safety Agency (EASA) rulings on certification. EMAR 21 is the same as Part 21, EASA's guidance for design and production of aircraft, while EMARs 145 and 147 shadow EASA's Part 145 for maintenance organization and Part 147 training organization rules on approvals, respectively. Partner nations may choose among four levels of EMAR implementation, a full or partial adoption, or a full or partial compliance, depending on their current aircraft fleets or whether their national rules are more stringent than the EMAR's.

“We are still using the national regulators, not one European regulator,” said Col. (Ret.) Jan Plevka, the EDA's principal airworthiness officer, at the Harmonization of Military Through-Life Airworthiness conference in London last month. “Among the 27 nations, all so different, we have a mix of strong nations with aerospace industries and some small air forces with a few state aircraft that mainly rely on civil aviation authorities,” Plevka explained. “Certification will still be a sovereign national decision.”

The U.K., France and Italy are also leading task forces on harmonizing the European Military Airworthiness Certification Criteria (Emacc) with a view to adopting civil elements where it is safe and sensible and militarily necessary but recognizing that some civil regulations would not be safe to use in a military environment.

“We are taking a common view across other European airworthiness authorities, working to make it as similar as possible to other national MAAs,” says a U.K. MAA official. “Taking each line by line, scanning the various codes and understanding the intent—it is not straightforward.”

The U.K.'s military air safety and airworthiness regime has been radically overhauled as a result of the Haddon-Cave report into the Nimrod patrol aircraft crash over Afghanistan back in 2006. Officials are revising the U.K.'s certification rule book, known as DefStan 00-970, which originated as a 1918 publication called the Handbook of Strength Calculations and has evolved in an ad-hoc way, according to officials. The new version is being restructured with the EMARs and Emaccs in mind.

Another key area the rules would address is mutual recognition of airworthiness rules and duty of care oversight. Since the 2003 crash of a Ukrainian-registered Yakovlev Yak-42 in which 62 Spanish servicemen returning home from Afghanistan were killed, NATO countries in particular have tightened the rules about allowing their personnel to fly on aircraft belonging to other air forces.

To speed up the process, the U.K. MAA is working on a scheme of self-assessment in conjunction with the Aviation Engineering Directorate of the U.S. Army's Aviation and Missile Research Development and Engineering Center, which would see the two departments examine and analyze each other's rules on troop transportation and exchange certifications “hopefully in the future,” say MAA officials. The move would allow British Army commanders to transport U.S. soldiers in U.K. C-130 Hercules aircraft.

Other advantages that would result from the harmonized rules include greater opportunities for pooling and sharing of assets and maintenance, repair and overhaul activities; increased cross-border cooperation and interoperability; and a boost to efforts to allow unmanned air systems to operate in European airspace.