Chapter 6 - Allotment of Registration Marks
6.1 ALLOTMENT OF MARKS - GENERAL
Marks are generated through CCARCS - Mark Control. There is no specific application form for the allotment of a registration mark. An applicant can make a request by phone or by letter.
The following steps should be followed when allotting marks:
Obtain owner's name, address and phone number.
Obtain aircraft details (model, serial number, year of manufacture), if known.
Enter information into CCARCS - Mark Control.
Do a print of the screen once CCARCS has generated a mark and the expiry date.
Advise the owner of the mark allotted and of the expiry date. If advising by phone, use the phonetic alphabet (see Appendix A) and follow up with written confirmation to the applicant. CCARCS has a form letter that can be used when allotting marks.
Obtain payment if a fee applies.
Send a copy of the written confirmation and a copy of the CCARCS print out to the Records Management office for them to start an aircraft file.
- Have the file brought forward (BF’d) 1 month prior to the expiry of the allotment of marks.
6.2 MARK RESERVATION
CARs 202.02(3), CAR 202.02(4)
A mark is considered reserved if Transport Canada is not advised of both the model and serial number of the aircraft. In the case of an aircraft being imported, a mark is reserved if Transport Canada has NOT been advised that the aircraft has been removed from (de-registration), or never entered on (non-registration) the foreign register. A reserved mark must not be displayed on an aircraft before the mark is issued.
NOTE: Displayed means visible. If the marks are painted on and then covered up such that the aircraft is not flying with Canadian marks openly displayed while it is still on the foreign register, that is not a problem.
Example: This could be the case with imported aircraft where prospective owners like to get their marks early, before they travel to pick up the aircraft. They may then arrange to have the aircraft painted which made. These flights would be done under the foreign registration, with foreign marks taped over the painted Canadian marks. This is true not only for new aircraft but also for used aircraft. After acceptance, the aircraft is de-registered. This procedure can be extremely time-saving.
Time Period for a Reserved Mark
A mark is reserved for one year. If during that time, complete aircraft details are submitted and notification of de-registration or non-registration from the foreign aviation authority has been received, the mark then converts from reserved to issued. The details must be entered into CCARCS - Mark Control, which then determines the new issue expiry date.
The fee for reserving a registration mark is $45 unless the applicant requests reservation of a special mark in which case the fee is $140.
6.3 MARK ISSUANCE
A mark is considered issued if Transport Canada is given both the model and serial number of aircraft. In the case of an aircraft being imported, Transport Canada must also have been advised that the aircraft has been removed from (de-registration), or never entered on (non-registration) the foreign register. The mark is issued for one year.
There is no fee for issuing a registration mark unless the applicant is being issued with a special mark in which case a $140 fee applies.
6.4 SPECIAL REGISTRATION MARK
A registration mark is considered special if the applicant requests a specific mark rather than allowing CCARCS to generate the next alphabetically available mark. When an aircraft is returning to Canadian registration, after being exported or after having been withdrawn from use, and the owner wants the same mark the aircraft had when previously registered in Canada, it is considered a special mark. The fee for issuing or reserving a special mark is $140.
6.5 MARK RENEWAL
When a mark is allotted, an expiry date is generated by CCARCS. The file is brought forward (BF’d) one month prior to the expiry date. If the aircraft has not been registered and the owner does not want the reserved marks to expire or the issued marks to be cancelled, a renewal process is required. The process for renewing a reserved or issued mark is the same.
These steps should be followed when the file is received:
Send a letter to the applicant advising them of their impending mark expiry or cancellation and that $45 is required to retain the mark.
BF file to ensure payment is received.
If payment is received the mark is retained for an additional 12 months.
Update CCARCS - Mark Control with the new expiry date.
Have the file brought forward (BF) 1 month prior to the new expiry date.
- If payment is not received see Chapter 6.6 - Mark Expiry.
6.6 MARK EXPIRY OR CANCELLATION
One month prior to the mark expiring or being cancelled, a letter is sent by registered mail to the applicant requesting that they submit $45 to retain the alloted mark. If payment to renew the mark is not received, the mark is deleted from CCARCS - Mark Control. The mark will then be immediately available in the system for allotment. The applicant is sent a letter advising them that the mark is no longer available for their use. Route the file to Records Management to be cancelled and archived.
If the applicant decides they would like to retain the mark after it has been deleted from CCARCS, and it is still available, it would be considered a special mark. The $140 fee required for a special mark would apply. See Chapter 6.1 on how to allot the mark.
6.7 PRODUCTION MARKS
Canadian aircraft manufacturers who intend to operate the aircraft pursuant to CARs 202.14 must be reserved a registration mark. They are identified in CCARCS - Mark Control under the name "Production Flights". A $45 fee for the reservation will apply. Should they require the mark beyond the reservation expiry date, the $45 renewal fee also applies.
When an aircraft is issued a Certificate of Registration using the production mark and then removed from the register, the manufacturer must pay the mark reservation fee to retain the mark again as a production mark.
See Chapter 11 for information on issuing an authorization pursuant to CARs 202.14.
What’s the difference between reserving and issuing aircraft marks?
There are often questions about the difference between reserving and issuing marks - and the different terminology surrounding the two.
- Marks are allotted to an aircraft in one of two ways. They are:
- reserved; or
2. Marks can be either:
- system-generated (i.e. the next available ones generated by CCARCS); or
- special (i.e. specified by the registration applicant).
3. Both reserved and issued marks are "good for one year", during which time the registration process is usually completed. If this is not so, the owner must renew the marks, otherwise:
- reserved marks "expire" after one year;
- issued marks are "cancelled" after one year.
4. If the owner chooses, reserved or issued marks can be renewed annually in anticipation of the registration process being completed:
- reserved marks can be renewed for another year (mark reservation fee applies);
- issued marks can be renewed for another year (mark reservation fee applies).
NOTE: The fees pertaining to reserving marks and issuing and reserving special marks are set out in CARs Subpart 104, Schedule II.
Is there anything to prevent someone who has been issued marks, but who has not completed the registration process from not renewing the marks after one year, letting some time go by and then requesting Transport Canada to issue marks to the aircraft - thus, avoiding the annual renewal fee?
No. There is nothing to prevent this. It is not common practice, however, because the prospective registered owner generally has already painted the marks on the aircraft and does not want to go to the bother of removing them and repainting the aircraft.
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