The Civil Aviation Administration of China (CAAC) Aircraft Airworthiness Certification Department published draft amendments to CCAR-21 (Civil Aviation Products and Parts Certification) and CCAR-45 (Aircraft Nationality Registration) on September 30, 2026, opening a public consultation that closes on October 30, 2026. The revisions target full-lifecycle airworthiness supervision and the continuous, dynamic oversight of aircraft nationality registration and airworthiness certificates.
Chinese aircraft and engine manufacturers (COMAC, AVIC, AECC), foreign OEMs seeking Chinese type or validation certification (Boeing, Airbus), Chinese transport and general airlines, and importers of aviation products and parts into China must review the two drafts and file the Airworthiness Certification Policy Feedback Form with CAAC by October 30, 2026, or forfeit the chance to shape the binding rules; once adopted, non-compliant certification or registration means refused type or airworthiness certificates, grounded aircraft, and administrative penalties under the Civil Aviation Law.
What do the draft amendments change?
CCAR-21 governs type certificates, production certificates, airworthiness certificates and design and production organisation approval for civil aviation products and parts; CCAR-45 governs aircraft nationality registration. CAAC states the drafts were built on a review of existing certification management experience and aim to strengthen and standardise full-lifecycle airworthiness management, with particular emphasis on the continuous, dynamic supervision of nationality registration and airworthiness certificates. The consultation letter was issued by the Aircraft Airworthiness Certification Department on September 30, 2026.
| Regulation | What it governs | Amendment focus |
|---|---|---|
| CCAR-21 (Civil Aviation Products and Parts Certification) | Type, production and airworthiness certificates; design and production organisation approval | Full-lifecycle airworthiness supervision; continuous dynamic oversight of certificates |
| CCAR-45 (Aircraft Nationality Registration) | Aircraft nationality registration | Continuous dynamic supervision of nationality registration certificates |
In practice, the amendments tighten how certificates stay valid across an aircraft's life rather than only at issuance, closing the gap between initial certification and ongoing airworthiness. CAAC frames the revision as part of its broader airworthiness reform aligned with ICAO, FAA and EASA practice and tied to domestic programs such as the COMAC C919 and ARJ21. The draft texts and revision notes are downloadable from CAAC's consultation column.
Who is exposed to the new requirements?
By market exposure, the consultation addresses the actors holding or seeking certificates under both regulations:
- Chinese aircraft and engine manufacturers (COMAC, AVIC, AECC), which hold type and production certificates and design organisation approvals under CCAR-21.
- Foreign OEMs (Boeing, Airbus) seeking Chinese type or validation certification for aircraft they want to sell or operate in China.
- Chinese transport and general airlines holding airworthiness and nationality certificates for their fleets.
- Importers of aviation products and parts into China, whose items pass through the CCAR-21 certification gate.
CAAC's consultation letter was sent directly to regional administrations, transport and general airlines, AVIC, AECC, COMAC, CAAC universities and institutes, and the airworthiness certification centres, confirming the manufacturer and operator focus.
What must affected actors do, and by when?
Feedback is due by October 30, 2026. Each organisation must study both drafts and submit a separate Airworthiness Certification Policy Feedback Form for each, by email to [email protected] with the subject "CCAR21和CCAR45部修订反馈意见". Individuals may also submit forms. The drafts and the feedback form are available on CAAC's consultation page.
For certificate holders, the substantive task is to assess how the strengthened lifecycle and nationality registration requirements affect their existing type, production and airworthiness certificates and their registration filings, and to flag operational or cost impacts in the response. Foreign OEMs should focus on the validation certification provisions and any bilateral recognition implications.
What happens if a company misses the consultation or later non-complies?
Missing the October 30, 2026 consultation forfeits a company's opportunity to shape rules that will bind it; the consultation is the only formal channel to request changes before adoption. Once the amendments are adopted and in force, non-compliant certification or registration carries the consequences of the Civil Aviation Law and the underlying regulations: refused type or airworthiness certificates, aircraft that cannot be registered or must be grounded, and administrative penalties.
What to do next
- Download the CCAR-21 and CCAR-45 draft texts and revision notes from CAAC's consultation page and circulate them to your airworthiness and certification leads.
- Map the strengthened lifecycle and nationality registration duties against your existing type, production and airworthiness certificates and registration filings.
- File the Airworthiness Certification Policy Feedback Form for each draft by October 30, 2026, flagging operational, cost or recognition impacts.
- Brief your certification, legal and fleet-management teams on the timeline toward adoption and entry into force.
Obsidian tracks CAAC consultations and the CCAR-21 and CCAR-45 reform as they move toward adoption, so a certificate holder sees each step without monitoring the regulator by hand.
