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 firstname.lastname@example.org. We look forward to hearing from you, and continuing to build the future of PMA.
This week, MARPA is in Japan at the 2013 Aerospace Industry Exhibition Tokyo (ASET 2013). MARPA has an exhibit booth featuring information about the PMA marketplace and about our membership.
MARPA is not alone! Both Heico and Jet Parts Engineering sent staff to participate in the PMA panel during the conference. The panel featured two hours of presentations about PMA and questions and answers about PMA. It was attended by over a hundred aerospace professionals interested in learning more abut PMA.
In addition, though, several of our members sent literature to the conference, and MARPA has been handing their information to interested conference attendees. Those members were:
So far, we’ve seen a lot of interest from Japanese manufacturing companies in partnering with PMA companies from the United States, so the literature from member companies has been very helpful in educating the Japanese marketplace about potential US partners.
Many Japanese companies seem able to bring novel production technologies and novel solutions to the table as potential partners/suppliers. But that has not been the sole focus of this trip. We also had an opportunity to spend time with representatives from both ANA and JAL during our trip. Both air carriers remain keenly interested in the potential posed by PMA.
We were fortunate to be invited to deliver training sessions to both ANA Trading and ANA’s Materials Management Department. Both organizations were very gracious hosts. PMA was an important topic in each of those training sessions, and there were lots of insightful questions.
We previously wrote in this space that MARPA will be attending the 2013 Aerospace Industry Exhibition Tokyo (ASET). As a benefit to our members, MARPA plans to feature member-company literature in our booth to allow you to make connections with the Japanese aerospace manufacturing market. This is just one of the benefits of MARPA membership. ASET offers an excellent opportunity get in front of a substantial segment of the Japanese aerospace manufacturing community; at the last conference over 23,000 people attended!
In order to help us feature member companies in the MARPA booth, members must ship their literature to us in Tokyo. To ensure we are able to showcase your literature, you must follow these steps:
1. Act quickly! ASET runs October 2-4. You should plan to have your literature arrive absolutely no later than Monday, September 23. This will allow adequate time to ensure your package clears customs.
2. Ship your package to:MARPA (Booth No. G-01) c/o AEROSPACE INDUSTRY EXHIBITION TOKYO 2013 2013 Management office Tokyo Big Site 3-11-1 Ariake, Koto-ku, Tokyo 135-0063, Japan
3. Email Katt Brigham at MARPA with your package tracking information. This should include the date the package was shipped and the estimated date of arrival. You should also include the contents of your package so we know what to look for.
4. Confirm your package arrives in Tokyo. When you have confirmed arrival email Katt to let us know as well.
Remember it will take about a week for your shipment to clear customs upon arrival in Japan. It is therefore vital that you ship your literature in time to ensure arrival by September 23.
MARPA is excited to be able to offer this opportunity to its members. If you have any questions about shipping, please contact Katt at (202) 628-6777 or by email at email@example.com.
MARPA is pleased to announce that we will be at the 2013 Aerospace Industry Exhibition Tokyo, and you can be there too!
While this is a fantastic opportunity for making connections in the Japanese aerospace manufacturing market, we recognize that not ever member can afford to add this to their trade show agenda, so MARPA will be featuring literature from members at their booth. That’s right – you can have your company literature included in the MARPA literature rack at ASET 2013 in Tokyo!
COST: Free to MARPA members (it is a membership benefit).
HOW BIG IS THIS CONFERENCE: The last conference was in 2011 (it is held every two years) and there were 23,373 visitors for the aerospace trade floor.
YOUR REQUIREMENTS: YOU are responsible for producing your company materials. YOU are responsible for shipping the materials to the convention center and for alerting us to look for it.
WHAT WE WILL DO: We will keep your literature in our literature rack or on our display table (depending on factors like size and volume of member response) and hand it out to interested conference-attendees.
HOW DO I GET STARTED: Contact Katt Brigham by calling or emailing the Association
OTHER CONFERENCE DETAILS:
The Aerospace Industry Exhibition Tokyo (ASET) is the only exhibition held in Tokyo dedicated to specialized aerospace technologies. In addition to the unique business opportunity, ASET also features programs and lectures from key industry figures, as well as business and social networking events.
MARPA will have an exhibit booth for the three day event, October 2-4, 2013, and MARPA President Jason Dickstein will give a keynote address discussing PMA and the advantages that it represents. This is an excellent opportunity to further raise industry awareness about the value and benefits of PMA and about MARPA itself.
DO YOU PLAN TO ATTEND?
ASET has asked for our help in getting the word out about this opportunity, as ASET is seeking PMA companies to join their PMA session. The PMA companies would be asked to introduce their business to the attendees and participate in a PMA panel. As inducement for participation, ASET is offering to provide exhibition booth space (three-day exhibition required) and potentially other inducements to PMA companies who are willing to present at the exhibition.
The city of Tokyo’s event planning subsidiary specifically requested the presence of PMA manufacturers at ASET 2013. This is a great opportunity for our members to exhibit their products in front of a large audience in one of Asia’s key business hubs. It is also a chance to further educate the aerospace community on the advantages of PMA.
If your company is interested in taking advantage of this opportunity, please contact ASET advisor Jay Kato via email at firstname.lastname@example.org. ASET 2013 runs October 2-4, so it is important to act quickly. MARPA hopes to see you there!