The U.S. Bureau of Industry and Security has issued an order denying the export privileges of:
This is a temporary denial order that is only valid for 180 days, unless extended. Although published in today’s Federal register, the order is actually dated January 19, 2016. The Order prohibits the denied parties from engaging in export transactions, and it includes a prohibition against third parties exporting from the U.S. to any of these denied parties.
Absent a license that authorizes sales to these denied parties, sales of US-origin FAA-PMA parts to such denied parties may violate the temporary denial order.
MARPA members with a history of doing business with any of these parties should ensure that their future transactions remain consistent with U.S. law. While the Order remains effective, those who are approached by any of these denied parties should exercise caution in their dealings.
MARPA and the Korean Trade Promotion Agency (KOTRA) delivered a PMA workshop in Seoul this week. Hosted at KOTRA Headquarters in Seoul, the workshop provided an opportunity to begin educating the Korean aerospace community about the value of FAA-PMA parts. It also afforded the PMA community an opportunity to begin strengthening business relationships with the Korean aerospace industry.
MARPA’s President, Jason Dickstein, spent the first day of the workshop laying the goudnwork for understaing the PMA process.
The room was packed with about 60 participants from all sectors of the Korean aeroaspace community. MARPA discussed issues like the parts approval process, the safety, reliability and economic advantages afforded by FAA-PMA, and strategies for partnering with US PMA companies in order to increase trade and increase the profis of both companies.
Three of our members attended the workshop. Representatives from Heico, Jet Parts Engineering, and the Wencor Group joined us at the workshop and had an opportunity to network with potential suppliers from Korea’s manufacturing community as well as potential customers from MROs and airlines.
We were honored to be joined by Ha Girl Chung, the Deputy Director of Aircraft Certification for Korea’s Ministry of Land, Infastructure and Transportation. Mr. Chung was a key negotiator in the recently updated technical implementation procedures for the US-Korean bilateral aviation safety agreement. He reviewed the elements of Korean law that permit the acceptance of US PMA parts in Korea, and he also explained Korea’s own ability to issue PMA for parts made in Korea.
Privately, Mr. Chung told MARPA that Korea would like to begin issuing domestic PMA. This was foreshadowed by last years update to the US-Korean technical implementation procedures, which left a specific reservation (a place holder) for US acceptance of Korean PMA parts.
Asiana and Korean Air Lines were both well-represented at the event. Hoon Yong Kim, from Korean Air, delivered a presentation about his air carrier’s PMA policy. He explained that his carrier does not currently use critical PMA parts, but that they would like to expand their current use of non-critical PMA (critical PMAs are less than 1% of all PMAs). Mr.Kim said that they are particularly targeting interiors parts, right now, but they would like to increase both the quantity and the scope of the PMAs that they use.
What specific qualities does Korean Air seek? Mr. Kim explained that parts partners need to hold FAA PMA (other nations’ systems are currently not on his radar) and they should be prepared to support Korean Air in cooperative analysis. He described one situation where a supplier helped Korean Air perform a root cause analysis. Despite the fact that the root cause was unrelated to the supplier, the supplier provided continued engineering support. During subsequent conversations, Mr. Kim confirmed that he is looking for companies that have established systems like MARPA’s Continued Operational Support (COS) program.
All three of the MARPA members who were on hand had an opportunity to meet and speak with the attendees. Steve Johnson from Jet Parts Engineering added some insightful questions to the workshop. Joe DePaoli of Heico explained that his company and his peers from other PMA companies were interested in opportunities to work with Korean manufacturing companies with specialized technologies, and also with Korean manufacturing companies that are already making certain types of parts and who could use those skills to manufacture parts that could be approved under FAA-PMA.
Mark Powell of the Wencor Group delivered the anchor presentation at the end of the workshop, and he summarized the process that helped to ensure that PMA parts met the highest standards.
KOTRA and MARPA have begun a partnership to promote US-Korean aerospace trade with a focus around PMA parts. MARPA members should expect – and should look forward to – future oppotunities to increase their trade with Korean businesses.
We will be discussing issues that affect Korean-US business relationships and strategies for increased Korean-US trade. MARPA members will be networking with existing and potential Korean business partners.
We should be able to secure complimentary registration for any MARPA member who wants to attend. If you have personnel in the Republic of Korea or elsewhere in northern Asia, then you should certainly have them on site for this meeting.
If you have personnel that you would like to register for the workshop, please let MARPA know ASAP as time is running short.
Yes, China accepts FAA-PMA parts.
The United States and China signed a Bilateral Airworthiness Agreement (BAA) in 1991. That agreement recognized that each authority (FAA and CAAC) had a system for production and airworthiness approval of civil aeronautical products, and that each system was sufficiently equivalent to the other to permit the authorities to accept certain approval decisions of the other.
The BAA is implemented through a Schedule of Implementation Procedures. This schedule explains how international aerospace transactions will work. It is meant to facilitate certain transactions and relationships.
The schedule covers, inter alia, Chinese acceptance of FAA Export Certificates of Airworthiness appliances, parts, and materials for which the FAA is the exporting authority. The schedule explains that China will accept US export certificates of airworthiness for parts and materials when the FAA certifies that each article:
(a) Conforms to approved design data;
(b) Is properly marked; and
(c) Meets the special requirements of the importing country.
This is typically done through the issue of an FAA 8130-3 tag.
The special import requirements of China must be formally presented to the United States, and then the United States publishes those special import requirements in Advisory Circular (AC) 21-2. The Chinese special import requirements apply to airframes, engines, propellers, and TSOA articles, but the only special import requirement that applies to FAA-PMA parts is that the part must be accompanied by an 8130-3 tag. Since the 8130-3 tag is the medium for communicating the compliance, the 8130-3 for a FAA-PMA part can be safely annotated as meeting the special import requirements of China.
The Chinese have clarified in several places that they really mean it when they say that they are accepting PMA parts.
In order to ensure that there is no confusion, appendix D of the Schedule of Implementation Procedures specifies that the term ‘part’ means replacement and modification parts manufactured under any FAA production approval. The appendix goes on to say that this includes replacement and modification parts manufactured by an FAA-PMA holder!
Some additional provisions are listed in the Schedule of Implementation Procedures , but none of them actually impose any additional obligations on someone who exports a PMA part to China, so long as that part already complies with US regulatory standards.
China has also published their own advisory circular on the acceptance of FAA-PMA parts. The advisory circular clarifies that FAA-PMA parts are acceptable for use on Chinese aircraft and reiterates that the parts should marked according to the requirements of FAA Part 45.
The purpose of this trade mission is to introduce air carriers and MROs in Southeast Asia and China to the concept of PMA, and to the significant advantages that they can recognize by doing business with PMA manufacturers from the United States. We hope that this will help increase PMA sales into these regions.
The mission will begin for MARPA at MRO Asia in Singapore, November 3 through 5. We are planning to set up a few pre-scheduled meetings as well as allowing members to interact with the MRO attendees. After MRO, we will fly to Hong Kong to meet with air carriers on Friday. We plan to transfer to Guangzhou over the weekend in order to meet with Gameco and China Southern on Monday. Then we will spend Tuesday-Wednesday in Shanghai and Thursday-Friday in Beijing meeting with air carrier and MRO sales targets.
If you aren’t yet selling into Asia, then this is a wonderful way to start meeting potential customers. If you already have business in Singapore, China and Hong Kong, then you won’t want to miss this exceptional opportunity to renew acquaintances and build more business.
MARPA has been planning this 2015 trade mission since late 2014, and we’ve enjoyed incredible support from our US government contacts. This trade mission is undertaken in partnership with the US Department of Commerce, and we are being assisted by the International Trade Administration and the Commercial Foreign Service officers in the embassies and consulate offices. This is a valuable membership benefit that is available to help MARPA members increase their export business so make sure you take advantage of it!
If you are interested in participating or want more information, then please contact the Association. We’d love to hear from you.
We hope to soon be able to offer a specific itinerary and price for the mission. Once this is announced, we will take firm commitments from members on a first-come-first-served basis until the program is full.
Wondering if you can sell PMA parts into China? Tomorrow we will start addressing the legal standards for PMA acceptance in China!
The customers will be there in Istanbul in twelve days – will you?
MARPA and the Association of European Airlines (AEA) will co-host a PMA meeting in Istanbul on May 25-26. By my count we have 29 customer-personnel attending the conference – these are air carriers and MROs that are interested in PMA solutions. You can see the current “early registration list” online to see who has already committed. And we are hoping to confirm a few more European carriers before the end of this week.
“29 customer representatives in an intimate setting like that? Unlimited access to air carrier and MRO purchasing representatives? I can’t think of a better networking opportunity for a PMA company that wants to sell into Europe”
Customer attendees will include (but not be limited to):
Why are they gathering? To learn more about PMA and to network with PMA companies that can provide them with solutions. Why have AEA and MARPA gone to the effort to bring these air carriers together? To help educate the world about PMA and to help our members make sales to air carriers in the region!
If you’ve been dying for an opportunity to have one-on-one time with air carriers and MROs that are eager to learn more about PMA, then this is the conference for you. If you aren’t yet registered for the conference, then you should be.
Looking for more opportunities like this one? Take a look at everything that MARPA is planning for the remainder of the year to help promote YOUR export sales.
UPDATE: Due to an unforeseen conflict the dates of the AEA/MARPA PMA Aircraft Parts Conference have CHANGED! The new dates are May 25-26, 2015 in Istanbul, Turkey. Please visit the conference website for latest hotel and registration information.
Over the past several months MARPA has been in discussions with the Association of European Airlines (AEA) to work together to put on a PMA conference specifically designed to further education about PMA in Europe and the Middle East, and open new export opportunities for our members. MARPA is pleased to officially announce its partnership with the Association of European Airlines and formally announce the dates and location of our first ever European MARPA conference.
The AEA/MARPA PMA Aircraft Parts Conference conference will be held May 18-19, 2015, in Istanbul, Turkey at the Hilton Istanbul Bosphorus.
AEA and its members have expressed considerable enthusiasm for this event. AEA has pledged to work with its members to ensure their attendance at the conference, and will be holding its own meeting the afternoon of May 18 to provide additional incentive for its members to attend. AEA and MARPA expect a significant number of the European air carriers to be in attendance at the conference. MARPA is also reaching out to contacts in the Middle East to encourage air carriers from that region to attend as well.
This will be an excellent opportunity for MARPA members to meet and network with European and Middle Eastern air carriers, or to continue to develop preexisting relationships. Of course, we will also present a slate of educational and informational speakers to give attendees the very latest information about PMA, export regulations, and developments in air carrier and leasing issues.
The AEA/MARPA PMA Aircraft Parts Conference is one element of MARPA’s partnership with the International Trade Administration under its Market Development Cooperator Program, intended to increase the export of U.S.-made PMA parts.
MARPA is very excited to work with AEA to present an excellent conference program and provide substantial opportunities for our members to meet and network with air carriers. Be sure to mark your calendar for May 18-19, 2015 in Istanbul! For more information, visit the conference website at http://www.pmaparts.org/EMEAconference/about.shtml.
MARPA looks forward to seeing you in Istanbul!
PMA manufacturers who are exporting their parts from the U.S. need to ensure that they remain in compliance with the U.S. export regulations. In addition to the BIS and DDTC regulations that apply to aircraft parts, exporters also need to remain in compliance with Treasury Department regulations.
Some of those Treasury Department regulations include lists of people and entities that you ought not to do business with. Every agency has multiple lists that you need to examine, but Treasury is doing something to consolidate its lists and make it easier to review them. This consolidation should make it easier to search to ensure compliance, whether you are searching on line or using a computer program to automatically research your business partners.
The Treasury Department office with jurisdiction over export programs is the Office of Foreign Asset Control (OFAC). OFAC has a list of Specially Designated Nationals (SDNs) as well as other (non-SDN) sanctions lists. OFAC is now offering all of its non-SDN sanctions lists in a consolidated set of data files called the Consolidated Sanctions List. This consolidated list will include the following:
OFAC announced that it plans to discontinue some of these lists as separate lists, so they will only be available as part of the consolidated list.
Persons seeking to check whether there are OFAC sanctions that might apply to their transaction should be sure to check their export business partners (by personal name and company name) against the Specially Designated Nationals List and the Consolidated Sanctions List.
One can also use the Sanctions List Search which consolidates both lists into a single searchable database. This tool is useful because it can automatically search for names that are close (bot not exact matches) and can be set to find matches with different levels of confidence (which will then be reviewed by a human to assess whether they actually match).
Exporters should also check the details of their transaction (including destination country) against the Sanctions Programs and Country Information page, which list sanctions programs based on country and on certain other criteria.
MARPA is proud to announce that it is the recipient of a $300,000 matching grant from the Department of Commerce International Trade Administration Market Development Cooperator Program! MARPA was one of eight recipients of funding under the Market Development Cooperator Program (MDCP), which is intended to help organizations boost exports and create U.S. jobs. With the receipt of this assistance, MARPA plans to implement a number of initiatives to help grow the international PMA market and most importantly help our members grow their businesses by exporting more PMA parts!
The first of these initiatives will be to establish a European MARPA Conference, similar to the MARPA Annual Conference held in Las Vegas. Our current target is for the inaugural MARPA Europe conference to occur in May 2015, in Istanbul, Turkey. The primary goal of MARPA Europe will be to bring together PMA manufacturers (our members) and customers from both Europe and the Middle East. Air carriers reliably account for 25% of our Las Vegas attendees, and we expect to meet or exceed that rate at MARPA Europe.
Another initiative will be to lead educational missions to regions that present an opportunity for expanded PMA penetration. These include Japan, China, Southeast Asia, and the Middle East. MARPA will lead technical and regulatory seminars explaining the benefits of PMA and the way PMAs fit within the regulatory framework of the various countries we visit. MARPA also plans to attend regional MRO shows and other trade shows to educate the global aviation industry about the benefits of PMA.
Finally, MARPA will work with our partners and air carrier contacts to continue to bring more air carriers to both the MARPA Annual Conference in Las Vegas as well as MARPA Europe. The significant and growing attendance by air carriers at MARPA’s conferences make them the premiere events for PMA manufacturers to meet and network with air carriers in an intimate setting.
Of course nothing in life is free! One very important element of MARPA’s participation is the MDCP program will be measuring the effects our efforts have on growing the export PMA market. In a previous post we explained that MARPA would begin collecting export data from our members to get a better idea of the global PMA market share and identify to what market PMAs were being sold and where opportunities lay. As a part of our commitment to the Commerce Department, MARPA will track and measure the increases in exports reported by our members. This will be an important part of the next three years, as MARPA works closely with the Commerce Department to grow exports of PMA. MARPA will also need the help of its members to collect and report accurate data to measure the effects of our initiatives. We will be working with our members to help them increase their exposure to foreign markets and increase their exports in order to optimize the return on the Commerce Department’s investment as well as to develop accurate PMA export data.
Fred Elliot from the Department of Commerce and Ryan Aggergaard from MARPA will be on hand at the MARPA 2014 Annual Conference in Las Vegas to discuss some of MARPA’s planned initiatives and the requirements related to the award of the MDCP grant, as well as to answer member questions on how they can benefit from MARPA’s new programs. We look forward to seeing you there!
As the sole trade association representing the PMA industry, MARPA receives many inquiries from both industry and regulators regarding the economic effect of the PMA industry. Among the most frequent question is to the extent PMA parts are exported to other countries. Because the aerospace industry is such a large exporter, information regarding economic effect is useful in helping to shape policy and build support for the industry.
Unfortunately, MARPA does not have a significant pool of data from which to report or draw conclusions when approached with questions about economic effects and export statistics. Although we have data from a handful of members and plenty of anecdotal evidence to support the PMA industry’s positive economic effect, we lack significant hard data from which to draw any statistical conclusions. We would like to change this.
MARPA is therefore beginning an initiative to collect export data from our members to begin developing statistical data specific to the PMA industry. Rather than relying on information from aerospace trade publications or industry forecasting groups, which tend to focus on the aerospace industry as a whole without distinguishing PMA, MARPA seeks to develop a PMA-specific industry analysis.
But to develop and perform such economic export analyses, we need the help of our members. We will therefore be requesting that our members provide to us economic export data about their businesses. Such data would include, for example, to which countries you export, revenue derived from export, and percentage of total revenue derived from exports.
Of course, there is nothing more important to MARPA than a robust and competitive PMA industry. With that in mind, all information submitted to MARPA will be kept strictly confidential, and used only for overall statistical analysis. No company names, data, or strategies will ever be disclosed, either to other members, regulators, or the public in general. We understand and appreciate how important confidentiality is, and how much value is placed in keeping data about your business private.
The more data we obtain the better we will be able to promote the benefits of PMA, open new markets and expand existing markets, continue to build the trust of industry, and gain the support of regulators. We cannot do any of this without the support of our members.
We will be discussing this initiative further at the MARPA Annual Conference in Las Vegas, just a little more than a month away. But in the meantime, if you have data readily available, or have any questions about this initiative, you can email them to Ryan Aggergaard at MARPA at email@example.com. We look forward to hearing from you, and continuing to build the future of PMA.