China's C919 passenger jet might be vulnerable to U.S. sanctions

China’s C919 narrow-body passenger jet went into commercial operation this year, but relies on imported parts and technology, especially from the U.S., which has rolled out restrictions aimed at preventing U.S.-made civil aviation products from being diverted for military use. The United States has expanded its export controls and trade sanctions against China over advanced technology, including semiconductors and aviation, as relations between Beijing and Washington have deteriorated. The C919, which took more than 14 years to develop, relies on imported parts and technology. The C919’s LEAP engine is made by CFM International, a joint venture between American firm GE Aviation and France’s Safran Aircraft Engines. The U.S. government has said that restrictions are necessary to prevent U.S.-made civil aviation products from being diverted for military use. Since 2020, several subsidiaries of China’s biggest defense contractor, Aviation Industry Corporation of China (Avic), which is a key supplier to the C919, have already been designated as military end users.

A unit under the state-owned Aero Engine Corporation of China (AECC), AECC Commercial Aircraft Engine, which is designing a replacement engine for the CFM LEAP engine, has also been designated as a military end user. Under U.S. rules, designated entities are prohibited from receiving certain items unless the exporter secures a license. In 2022, the U.S. Department of Commerce’s Bureau of Industry and Security designated Shanghai Aircraft Design and Research Institute and Shanghai Aircraft Manufacturing as military end users. Both are under the Commercial Aircraft Corporation of China (Comac), the producer of the C919.

Comac currently produces two planes, the ARJ21 regional jet and the C919, both of which rely on foreign technology and parts. China Eastern Airlines began to fly the first C919 in May after ordering five of the planes that are designed to compete with Boeing’s 737 and Airbus’ A320. Comac’s Deputy General Manager, Zhang Yujin, told The Paper in January that the company would aim to produce 150 C919s every year in the next five years. In 2020, the Trump administration granted a license to GE to supply engines for the C919.

In a round table discussion arranged by Civil Aviation University of China in December last year, Le Wei, Director of the Legal and Compliance Department at the Shanghai Aircraft Design and Research Institute, acknowledged the U.S. export control changes had affected “security of the supply chain of China’s civil aviation manufacturing industry and the steady development of the industry”. To respond to the new rules, Le said Comac had established “complete traceability of upstream and downstream supply chain system and has strengthened the management of supplier compliance certification documents”. Le also expects U.S. efforts to “constrain China’s high-end manufacturing” to intensify and that China needs to increase the “degree of autonomy” in key technologies to counter any restrictions, the South China Morning Post reports.