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Aircraft Parts, aviation, Manufacturing, PMA

PMA in China

One of our members recently reported that his company has been offering cabin interior PMA parts to several Chinese airlines, only to be told that they are already using CAAC PMAs for many of these cabin parts. CAAC PMAs are Parts Manufacturer Approvals issued by the Civil Aviation Authority of China.  CAAC PMAs are acceptable for installation on Chinese-registered and Hong Kong-registered aircraft but they do not appear to be currently acceptable for installation on any other aircraft.

Our member asked whether there is a master list of CAAC PMA parts that MARPA members could review.  This would help MARPA members know which parts have not been PMAed in China which in turn will help to reveal which FAA-PMA parts might be most valuable and useful to Chinese air carriers.

CHINA

As far as we know, the master list of CAAC PMAs is only maintained as an advisory circular.  Because it is an advisory circular, it is not maintained in real time, but rather it is updated annually.  This link is to the 2015 revision of the CAAC PMA Catalog.

HONG KONG

Hong Kong has a separate aviation authority.  Hong Kong’s Civil Aviation Department also issues its own PMAs.  Hong Kong has issued PMA authority to Taikoo (Xiamen) Aircraft Engineering Co. Ltd.  There is a Schedule of Implementation Procedures between China and Hong Kong under which each accepts the PMAs of the other.

ACCEPTANCE OF CHINESE PMAs

Remember, the current US-China bilateral permits entry of US PMAs into China, but it is currently a one way only: it does not permit installation of Chinese PMAs onto US-registered aircraft. Without an explicit acceptance of CAAC PMAs through a US document (such as the US-Chinese bilateral agreement), CAAC PMAs are not currently eligible for installation on US registered aircraft as replacement or modification parts (under 14 C.F.R. 21.9).

FAA PMA FOR CHINESE MANUFACTURERS

There is a mechanism for Chinese companies to obtain US PMA.  Chinese companies wishing to set up final production sites in the US could apply for US PMA and could use that as a mechanism to create FAA-PMA parts that are accepted all over the world.  For many Chinese companies, the most efficient and effective way to accomplish this would be to partner with an existing FAA-PMA holder in the United States that has experience navigating the FAA regulatory system.

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About Jason Dickstein

Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. He represents several aviation trade associations, including the Aviation Suppliers Association, the Aircraft Electronics Association, the Aircraft Fleet Recycling Association and the Modification and Replacement Parts Association.

Discussion

2 thoughts on “PMA in China

  1. Hi Jason, could you update the links to the advisory circular and 2015 CAAC revision? They seem to not exist.

    Posted by loriying | October 19, 2016, 8:54 am

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