Update on USM and China

Many of you were at the ASA/AFRA Annual Conference and got an update on the work we’ve been doing with the Chinese government to open their system to foreign (non-Chinese) USM.

USM, or Used Serviceable Material, is the term that is often applied to parts that have been disassembled from aircraft with the intent that they be overhauled and then subsequently installed in a different aircraft.

The Chinese government has legitimate concerns about unapproved and counterfeits parts being passed off as USM and entering their civil aviation system. They have decided that China should be open to USM, but that they want to control the flow of USM entering China to help protect China from unapproved and counterfeits parts. To this end, China has adopted a policy of requiring USM to have been removed by a qualified facility that is regulated under Chinese law. The USM is then recorded in a database that permits subsequent CCAR145 repair stations and performing service on the parts, as well as installers, to verify the provenance of the part before using it. This will help to better distinguish legitimate USM from counterfeit parts that might be passed-off as USM.

CAAC has been working closely with the Aircraft Fleet Recycling Association (AFRA) to develop a protocol for accepting USM that has been removed outside of China. AFRA is the leading trade association for aircraft end-of-life solutions, and focuses on safe disassembly practices that protect both airworthiness and environmental priorities.

We will provide our next public update on this CAAC-AFRA process at the Civil Aviation Materials and Maintenance Management Forum. Because of travel schedules and competing priorities, I will be joining the conference remotely. I will provide the update and I also plan to answer audience questions.

About Jason Dickstein
Mr. Dickstein is the President of the Washington Aviation Group, a Washington, DC-based aviation law firm. Since 1992, he has represented aviation trade associations and businesses that include aircraft and aircraft parts manufacturers, distributors, and repair stations, as well as both commercial and private operators. Blog content published by Mr. Dickstein is not legal advice; and may not reflect all possible fact patterns. Readers should exercise care when applying information from blog articles to their own fact patterns.

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