On July 23, 2026, the Civil Aviation Administration of China (CAAC) Aviation Safety Office opened a public consultation on proposed amendments to the Civil Aviation Safety Management Provisions (CCAR-398-R1). The draft would elevate the main clauses of the Major Civil Aviation Safety Hazard Determination Standard (2025 Revision) into an annex of the CCAR-398 departmental rule, turning a soft identification standard into binding industry regulation for Chinese aviation operators.
Comments are due by August 23, 2026. Organisations and individuals may submit the feedback form to [email protected], with the subject line "398部分条款修订意见". The official notice and draft revision text are published on the CAAC consultation page.
What exactly changes in CCAR-398-R1?
CAAC is revising selected provisions of CCAR-398-R1 so that the major safety-hazard determination criteria sit inside the rule as an annex, not only as a standalone standard. The stated policy driver is the Three-Year Action Plan for Fundamental Work Safety Improvements (2024-2026): elevate civil-aviation major hazard determination into industry regulation.
Until now, operators applied the 2025 Major Civil Aviation Safety Hazard Determination Standard as guidance when identifying and grading hazards under their safety management systems. Once the annex is adopted, those determination criteria become part of the binding CCAR-398 rulebook. Non-alignment would then be a regulatory compliance gap, not merely a soft-standard deviation.
Two downloadable attachments accompany the notice: the proposed revision text for CCAR-398-R1 selected clauses, and the official feedback form. The consultation does not yet set an entry-into-force date for the final annex; that comes after CAAC closes comments, finalises the text, and issues the revised departmental rule.
Who is exposed, and how far does the rule reach?
The amendment targets the full Chinese civil-aviation safety-management population already subject to CCAR-398: air carriers, airports, maintenance and repair organisations (MROs), and other CAAC-approved aviation organisations that run SMS and hazard-identification programmes.
Foreign OEMs, lessors and MRO providers that operate through CAAC-approved Chinese entities, or that support Chinese operators' SMS programmes, should treat the annex as a downstream compliance driver even if they are not the primary rule addressees. The consultation is China-wide: it is a national departmental-rule revision, not a regional pilot.
| Milestone | Date / status | What operators must do |
|---|---|---|
| Consultation opens | July 23, 2026 | Download draft annex text and map against current SMS hazard catalogues |
| Comment deadline | August 23, 2026 | File feedback to [email protected] with the required subject line |
| Final rule / annex | Not yet set | Track CAAC issuance; prepare SMS and training updates for entry into force |
What should compliance teams do before August 23, 2026?
First, obtain the draft revision attachment from the CAAC notice and run a gap analysis: compare each proposed annex criterion against the organisation's current major-hazard identification procedures, SMS manuals, and occurrence-reporting workflows under China's aviation safety-management lineage.
Second, decide whether to file comments. Material friction points typically include definitional mismatches between the 2025 standard wording and existing internal severity matrices, overlap with occurrence-reporting duties, and the practical burden of reclassifying open hazard registers once the annex binds. Feedback must use the official form and reach CAAC by August 23, 2026.
Third, brief SMS owners, quality directors and local CAAC liaison contacts now. Continuous, per-jurisdiction monitoring surfaces this class of CAAC departmental-rule consultation the day it publishes, so compliance teams are not waiting on trade-press lag.
Fourth, plan the post-adoption workstream early: update hazard catalogues, retrain inspectors and line managers, and document how annex criteria feed into corrective-action and management-review cycles. Binding status will raise the cost of informal workarounds.
Take advantage of this real-time watch
Next steps are concrete: verify whether your organisation falls under CCAR-398, download the draft annex, complete the gap map before August 23, 2026, and assign an owner for the final-rule watch. Obsidian keeps Chinese aviation safety-rule changes visible as they move from consultation to issued departmental rule, so the annex does not arrive as a surprise on the effective date.
