MEL · October 31, 2026 · 6 min read · By BizJetDocs

Nonessential equipment and furnishings (NEF) and your Part 91 MEL

What counts as NEF, the nine elements a Part 91 NEF program must contain under AC 91-67A, the verbatim MEL proviso, and what never qualifies.

Short answer: an NEF program lets a Part 91 operator defer inoperative, damaged or missing items that have no effect on safe operation, such as a cabin entertainment screen or a cosmetic trim strip, using the deferral authority of its MEL letter of authorization (LOA D095 or D195). It is not a standalone approval. It is a supplement to your MEL, it is not submitted to the FAA, and AC 91-67A, Chapter 11, says it must contain nine specific processes and a verbatim proviso in ATA chapter 25. Without an MEL, there is no NEF program.

What NEF is, and what it is not

AC 91-67A, paragraph 11.1, defines NEF as "items installed on the aircraft as part of the original TC, STC, EO, or other form of alteration that have no effect on the safe operation of flight and would not be required by the applicable certification or operational rules." Paragraph 11.3.1 adds that NEF items can be anywhere in the aircraft, including the flight deck, service, cargo and crew rest areas as well as the cabin, lavatories and galley, and can include cosmetic items not associated with an MEL or CDL item.

Paragraph 11.3.2 lists what NEF items are not:

• instruments and equipment already in the MMEL, MEL or CDL;
• instruments and equipment functionally required for any certification rule;
• instruments and equipment required by any operational rule;
• items deferred contrary to a continuous airworthiness maintenance program;
• paint;
• rodent or pest infestations;
• items that are only dirty or soiled.

The same paragraph says an NEF item is not to be used as an administrative control item, which is listed in the MEL only for tracking. The background in paragraph 11.2 explains the history: NEF replaced the older Passenger Convenience Items program, which covered only cabin, galley and lavatory items.

Where the authority comes from

AC 91-67A, paragraph 11.4: "Authority for an operator's NEF program is inherent in their MEL LOA; therefore, the NEF program does not need to be submitted to the FAA with the operator's MEL LOA application." Paragraph 11.7: an operator "is not required to submit their NEF program, or NEF program revisions, to the FAA, and the FAA is not required to review it," but the FAA may conduct surveillance at any time.

FAA Order 8900.1, Volume 4, Chapter 4, Section 4, paragraph 4-702, confirms that NEF programs of Part 91 operators (other than Part 91K) "are not FAA-approved but still require surveillance by the responsible Flight Standards office." Paragraph 4-705C says that for Part 91 the NEF program "becomes a supplement to the MMEL or MEL depending on whether LOA D095/D195 is issued" and "is not a standalone program."

That has a practical consequence. 14 CFR 91.213(a) only allows takeoff with inoperative equipment under an approved MEL and LOA (or the limited 91.213(d) alternative). The NEF program borrows that MEL authority, so the MEL comes first. If you are choosing an MEL path, see D195 vs D095.

The nine required elements

AC 91-67A, paragraph 11.6, says operators design the NEF program to fit their operation, "including, at a minimum, the following nine processes and procedures":

1. Method of tracking NEF items (11.6.1). A list is optional. Without one, each deferral is treated as a newly discovered item. If used, the list can be general ("cosmetic trim-strips"), need not be in the MEL, and changes need not be submitted to the FAA. Applicable parts of the list and process must be available to flight and cabin crews, maintenance and flight operations personnel when items are deferred.
2. Identifying deferrals (11.6.2).
3. Tracking deferrals (11.6.3).
4. Documentation procedures for inoperative, damaged or missing items (11.6.4).
5. (M) and (O) procedures (11.6.5).
6. Follow-up maintenance, repair and replacement (11.6.6).
7. Repair intervals (11.6.7). The current MEL deferral categories, or another method acceptable to the Administrator.
8. Section 43.13 compliance (11.6.8). Any maintenance procedure in the program must comply with acceptable practices under § 43.13.
9. The NEF proviso (11.6.9). Figure 11-1 gives the proviso, which goes in ATA chapter 25 of a D195 MEL or in the D095 procedures document, and "must be copied verbatim." It says NEF items may be inoperative, damaged or missing "provided that the item(s) is deferred in accordance with the NEF deferral program," names the operator's manual where the program is found, and notes that exterior lavatory door ash trays are not NEF items.

Paragraph 11.4.2 sets a limit: the NEF process may not defer items within serviceable limits identified in the manufacturer's maintenance manual, Structural Repair Manual, airworthiness directives or the operator's maintenance program. Paragraph 11.4.3: NEF items are deferred under the operator's NEF program, "not under the authority of an Airframe and Powerplant (A&P) certificate."

Deciding whether an item qualifies

AC 91-67A, paragraph 11.8, lists questions to ask before listing an item:

• Is the item required by the operating rules for the aircraft?
• Could it create fire, smoke or another hazard?
• Could it affect other required systems?
• Could its condition affect the safety of passengers, crew or service personnel?
• Could it affect emergency or abnormal procedures?
• Does it add crew workload at critical times?
• Does the crew need to evaluate it flight by flight?

Paragraph 11.9 and Figure 11-2 then give the deferral sequence: document the discrepancy in the aircraft logbook; if it is on the NEF list, follow the procedure; if it is an MMEL, CDL or MEL item, or a subcomponent supporting the primary function of one, it cannot be deferred under NEF; if it is required by certification or operating rules, or raises a safety-of-flight issue, it cannot be deferred; if the underlying cause cannot be identified, it must be repaired before flight; otherwise evaluate its effect on an equivalent level of safety and defer it under the program, updating the list as needed.

Checklist

• An approved MEL and LOA (D095 or D195) for the aircraft.
• The verbatim NEF proviso in ATA 25 of the MEL or in the D095 procedures document, naming the manual that holds the program.
• A written program covering the nine elements in AC 91-67A, paragraph 11.6.
• An NEF list, if you choose to keep one, available to the people who defer items.
• Repair intervals defined.
• A logbook entry process for every NEF deferral.
• A statement that items within maintenance manual, SRM or AD limits are never deferred under NEF.

What you submit and who submits it

Nothing, for the NEF program itself: AC 91-67A says it is not submitted and the FAA is not required to review it. The proviso travels inside your MEL, so for D195 it is part of the MEL you submit with your request or revision. The operator submits the MEL request to its responsible Flight Standards office.

We prepare the NEF program written to fit your MEL and aircraft, with the verbatim proviso for ATA 25 and instructions for keeping the list current. You adopt the program. The FAA may review it during surveillance.

Frequently asked questions

Does the FAA approve a Part 91 NEF program?

No. 8900.1 says Part 91 NEF programs (other than Part 91K) are not FAA-approved, but the responsible office conducts surveillance.

Can a mechanic defer a broken cabin item without an NEF program?

AC 91-67A says NEF items are deferred under the operator's NEF program, not under the authority of an A&P certificate.

Can worn paint or a stained seat be deferred under NEF?

No. Paint and items that are only dirty or soiled are excluded in AC 91-67A, paragraph 11.3.2.

Have it prepared

The NEF program for a Part 91 MEL is $425. If you also need the MEL it supplements, an aircraft-specific D195 MEL is from $550 by aircraft class, and a D095 procedures document is $650. See the format below.

Sources

Primary sources, as retrieved when this article was last updated. Check the current text before you rely on it.

• AC 91-67A, Minimum Equipment Requirements for General Aviation Operations Under 14 CFR Part 91
• FAA Order 8900.1, Volume 4, Chapter 4, Section 4, Nonessential Equipment and Furnishings (NEF) Program (CHG 777)
• 14 CFR 91.213, Inoperative instruments and equipment
• FAA Order 8900.1, Volume 4, Chapter 4, Section 2, MEL Requirements for Part 91 Operators (CHG 994)

Informational only. Not legal advice, not FAA guidance and not a promise of FAA approval or of any FAA timeline. The operator submits its own application; only the FAA approves, accepts or issues an authorization.