How are US export licenses impacting C919 certification?

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US Export Licensing Requirements Hinder C919 Certification and Production

US export licensing requirements implemented in December 2020 have significantly impacted China's C919 jetliner program, causing delays in certification and potentially affecting early production stages. The stringent rules necessitate special licenses for exporting parts and technology assistance to companies with ties to the Chinese military, a category that includes key subsidiaries of the C919's manufacturer, Commercial Aircraft Corp of China (Comac). While US-linked suppliers are gradually obtaining these licenses, the process has introduced bureaucratic hurdles and extended timelines, jeopardizing Comac's ability to meet its production and delivery targets.
Delays in Chinese Certification Processes

The implementation of US export licensing requirements has directly slowed down the certification process for the C919. These regulations, which came into effect in December 2020, mandate special licenses for any technology or parts transfer to entities linked with the Chinese military. Comac, as a state-owned enterprise, and its subsidiaries, including two added to a military-linked list in December 2020, fall under these stringent requirements. This has created a bottleneck, as the time-consuming licensing procedures add significant lead times to the acquisition of essential components and technical support from US-linked suppliers, thereby delaying the overall progress towards certification.
Potential Impact on Early Production and Deliveries

The protracted licensing process poses a threat to the early production and delivery phases of the C919. Although US-linked suppliers are progressively receiving the necessary licenses, the months-long delays incurred have created a cumulative impact on Comac's production schedule. This situation is particularly concerning given that the C919 relies heavily on Western components, including its engines and avionics systems. A slow production ramp-up would mean the C919 will not be a near-term competitor to established global aircraft manufacturers like Airbus and Boeing, which have monthly production rates in the dozens. China Eastern Airlines, which has a firm order for five jets, expects its first delivery by the end of the year, underscoring the pressure on Comac to accelerate its output.
Vulnerability Due to Reliance on Western Components

The C919's heavy dependence on foreign-sourced components, particularly engines and avionics, makes it inherently vulnerable to US export control policies. The addition of Comac subsidiaries to a US military-linked list in December 2020 specifically highlights this vulnerability, introducing complex licensing requirements that can impede the flow of critical technology. While China is actively pursuing domestic alternatives, such as the CJ-1000 engine, these solutions are still years away from full implementation. The current situation underscores the challenges Comac faces in navigating geopolitical restrictions while trying to bring its flagship aircraft to market.

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How are US export licenses impacting C919 certification?

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