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The South China Morning Post (SCMP) has an interesting recent piece focusing on how China’s COMAC C919 and future COMAC C929 airliners continue to rely on foreign, that is, primarily American and European, sourced components and subcomponents, down to products such as sealants and cleaning agents. None of this should come as any surprise to anyone remotely familiar with the current state of civilian aviation industry standards, or the rigorous challenge of obtaining a type certification for a new airframe from a highly regarded aviation safety authority such as the American Federal Aviation Administration (FAA) or the European Union Aviation Safety Agency (EASA). As a commercial product that will be pitched to export customers, Chinese airliners require a type certificate from at least one of the two aforementioned aviation safety authorities. Type certificates are not casually granted, and the entire aircraft, down to its assemblies, subassemblies, and essentially every single material to which these are exposed, are examined. Such is the state of affairs in a highly regulated industry, one that is not unlike, for example, the pharmaceutical industry and biomedical research (this is why there is such a robust market for used/second-hand equipment and components from retired airliner-type aircraft: even the food carts are highly regulated pieces of equipment that, as a result, are expensive and can be sold once the aircraft it itself retired).
To expedite the process, China and COMAC prudently brought foreign suppliers on board for the already flying—mainly in Chinese airspace—C919 and even the under-development C929. Established suppliers have a long pedigree for safety and quality control, which foreign regulators and foreign customers, such as airlines and airports—and their respective insurance providers—care about. None of this is to say that Chinese industry is not capable of providing most, if not all, of the relevant components and everything else, down to sealants and cleaning agents. Chinese industry will, however, have to stretch itself thin developing everything itself, thoroughly testing, all while still competing on price despite having neither the economies of scale nor the pedigree for quality control, reliability, and safety at the outset of the process.
When it comes to airliner-type aircraft that need to be approved for flights outside of China—unless these are to be limited to domestic flights, which makes little sense for even Chinese state-owned airlines—then the path of least resistance is to bring in foreign suppliers, at least in the interim, even if Chinese industry can readily provide some of the parts. In this sector of economic activity, which is exceptionally regulated, it is not enough to be able to build something and/or be the lowest bidder: one requires components and subcomponents that have been thoroughly tested and been certified by the competent authorities, above all those in Europe and the United States, which most other foreign regulators simply follow.
As things stand, observers will benefit from considering the existence, ongoing production, and expanding deployment and employment of the Chinese Y-20, which is a heavy military transport aircraft powered by four turbofan engines in the weight class of an Airbus A330 airliner. The latest version, the Y-20B, features four Chinese-designed and built WS-20 turbofan engines. As the flight hours and operating cycles accumulate, critical flaws in Chinese components, subcomponents, and everything else in the Y-20 and WS-20 will presumably become apparent (perhaps it is only a matter of time until a spectacular failure event occurs, although this appears to be unlikely). The point here is that Chinese industry is capable of providing most, if not all, of everything that goes into a modern airliner-type aircraft. They already do so for Chinese military aircraft, whether large and heavy A330-weight class-sized military transport aircraft or fighter jets. Whether COMAC can develop an “all-Chinese” airliner that not only “works,” but also receives approval from foreign regulators, above all EASA and/or the FAA, so as to allow for flights outside of China and orders from non-Chinese operators is another matter entirely.
For these and other reasons, observers should be cautious about reading too much into reports on the state of affairs concerning COMAC’s C919 and C929: the issue here is less what is in the realm of absolute possibility for China but what is in the realm of regulatory and market/sales possibilities. These are not remotely the same thing. For as long as that is the case, Chinese airliner-type aircraft are likely to feature at least some foreign-sourced components and subcomponents, even if Chinese alternatives can be incorporated upon request and where possible (as determined by the relevant competent aviation safety authority when it comes to non-Chinese customers and flights outside of Chinese airspace). There is a useful contrast to be found in the automobile industry, where Chinese electric vehicle manufacturers in particular are fast becoming dominant players on a global scale. It is not that automobiles are an unregulated area of industrial and economic activity, but the scope and intensity of regulation do not compare with aviation safety, especially for airliner-type aircraft, where the consequences of mistakes and failures are so much greater. Time will tell whether COMAC, or perhaps a more or less private/non-state owned enterprise Chinese corporation, will, like BYD in the automobile industry, come to be an internationally dominant player.