China opens regulated path for overseas used aircraft parts

China’s civil aviation regulator has set a new route for qualifying used aircraft and engine parts dismantled outside the country to enter the Chinese market. The framework centers on enhanced traceability, a compliant registration platform and a December 31, 2026 transition deadline for affected organizations.

Why it matters: - The Civil Aviation Administration of China has created a regulated pathway for qualifying used serviceable material recovered from aircraft and engines dismantled outside China to be supplied for use on China-registered aircraft. - The framework gives Chinese airlines and maintenance, repair and overhaul providers a defined route to source overseas used parts with documented provenance. - The new rules raise the bar on traceability, registration and verification in a market facing parts shortages, longer repair turnarounds and higher maintenance costs.

What happened: - The CAAC issued Advisory Circular AC-145-FS-017 R1, “Aircraft Disassembly,” on September 7. - The CAAC issued Management Document MD-MAT-FS-009, “Procurement and Repair Management of Used Aircraft Parts and Materials,” on September 10. - The CAAC identified registry.afra.aero/caac, the AFRA-CAAC Registry, as the current compliant overseas registration platform for qualifying dismantled material. - The AFRA-CAAC Registry operates on Block Aero’s Aviation Blockchain Network.

The details: - AC-145-FS-017 R1 and MD-MAT-FS-009 together set requirements for overseas disassembly organizations, used-parts procurement, traceability, supplier controls and digital registration. - Qualifying dismantled material must be entered into an approved registration system and made available for industry verification before sale. - The registry captures records, images, documentation and provenance data in a controlled digital environment. - MD-MAT-FS-009 applies to CCAR-121 and CCAR-135 operators and to organizations supplying maintenance services and aircraft parts to them. - Foreign aircraft disassembly organizations must comply with AC-145-FS-017, register material on a compliant platform, keep the part history clear and verifiable, and make legitimacy and airworthiness checkable through a public information platform. - The management document also encourages digital systems that support end-to-end tracking across the part lifecycle. - The framework builds on a September 18, 2023 memorandum of understanding between CAAC’s Flight Standards Department and AFRA. - AFRA selected Block Aero in March 2024 to provide the registry technology infrastructure. - Under AC-145-FS-017 R1, qualifying disassembly organizations must maintain controlled registration systems with detailed information on source aircraft and recovered parts. - After teardown of return-to-service material is completed, the information is frozen against arbitrary alteration and sent to a compliant public platform so buyers can query its history before sale. - Provenance can be supported through digital records, photographs, dismantle tags and trace documentation. - Buyers and authorized stakeholders can verify registry information through the AFRA-CAAC public portal before completing transactions. - Registration establishes provenance but does not replace airworthiness release requirements. - Except for specified direct-return circumstances, dismantled parts still must be maintained by an appropriately approved organization and receive an AAC-038 Approved Release Certificate before returning to service. - Overseas applicants may qualify through applicable FAA or EASA maintenance approvals or AFRA accreditation meeting Best Management Practice standards. - CAAC implementation briefings have indicated that audit scheduling may be coordinated with existing regional audit activity where practicable. - The framework is already in effect, and applicable procedural, system and transition requirements must be completed by December 31, 2026. - Previously approved aircraft-disassembly maintenance organizations must meet the circular’s new requirements by December 31, 2026, except for the specified maintenance-experience requirement. - MD-MAT-FS-009 also requires procedural revisions and system-development work to be completed by December 31, 2026.

Between the lines: - The policy appears designed to let China expand access to overseas used parts while tightening control over documentation quality and chain-of-custody. - The registry requirement shifts the market from informal paper-based provenance toward a verifiable digital trail. - The framework also lowers a potential barrier for overseas disassembly organizations by removing the need for a letter of intent from a Chinese customer. - The rules suggest the CAAC wants provenance to be demonstrated before sale, not after a dispute or audit.

What's next: - Overseas disassembly organizations that want to serve China will need to complete registration, procedural updates and system changes before the end-2026 deadline. - Chinese buyers and approved overseas suppliers are likely to use the AFRA-CAAC portal as the main verification point for qualifying used parts. - The broader market will be watching whether the new model becomes a template for cross-border traceability in aviation parts supply chains.

The bottom line: - China has opened a formal channel for overseas used aircraft parts, but access now depends on a documented, digitally verifiable provenance chain.