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This category contains 291 posts

U.S. Considers New China Sanctions – Could Affect Supply from China

If your company relies on materials, hardware, subcomponents or other supplies from China, then you need to examine the government’s latest investigation. The U.S. International Trade Commission (USITC) has opened a new factfinding investigation.  The investigation is examining the impact of revoking normal trade relations treatment for China. “Normal trade relations” is the term of … Continue reading

Carbon Border Adjustment Mechanism – Does It Apply to Aircraft Parts?

Most aircraft parts are NOT subject to CBAM, but there are several caveats to this statement. Continue reading

Demonstrating Eligibility

PMAs are unique, in that they are production approvals that also inherently include an eligibility (an installation for which the PMA is eligible).  The PMA application must identify the product onto which the PMA part will be installed (14 C.F.R. § 21.303(a)(1)).  Before 2009, the installation eligibility was required to be printed on the PMA … Continue reading

Join Us Online at Midweek MARPA to Discuss the 2026 Work Plan

The next Midweek MARPA is scheduled for 5:00 pm eastern time on Wednesday October 1, 2025. This is an opportunity for the members to comment on the MARPA meeting plan for 2026. Continue reading

FAA Issues Draft “Sample Size” Advisory Circular that Would Apply to PMA, STC, and RS-DER applications

The FAA has issued for comment a draft Advisory Circular focused on sample size for statistical analysis in PMA applications. As many of you remember, there was a draft on statistical analysis issued several years ago. MARPA objected to that draft because it implied that every PMA application needed to be based on statistical analysis, … Continue reading

FAA is Updating Alternative Methods of Compliance (AMOC) Guidance

The FAA has released for comment Draft Order 8110.103C. This is an update to the Alternative Methods of Compliance (“AMOC”) guidance. AMOC are typically used when an airworthiness directive (“AD”) provides one resolution to a safety problem, but the AMOC applicant has another approach that achieves the same level of safety. One example would be … Continue reading

Safran Cabin Named in Unapproved Parts Notice

When a company known as an “OEM” violates the FAA production approval rules, it is important for the industry to take notice. The industry is filled with PMA companies that strive for compliance perfection on a daily basis. A recent FAA unapproved parts notice (“UPN”) issued against Safran Cabin highlights the importance of obtaining PMAs … Continue reading

Tariffs Could Create New Opportunities for PMA

U.S. tariffs on Airbus parts could help increase the competitiveness of FAA-PMA parts that do not have to pay U.S. tariffs. Continue reading

MARPA Assists the Administration With Areas for Improvement

The Administration has pledged to reduce the regulatory burden and MARPA responded. We identified three special focus areas that reduce unnecessary burdens and increase safety. On April 3, the DOT published a Federal Register Notice entitled “Ensuring Lawful Regulation; Reducing Regulation and Controlling Regulatory Costs.” This notice sought public comment to aid the administration in its … Continue reading

FAA Issues Revised Production Approval Guidance for Public Comment

The FAA has released for comment an updated draft of 8120.22B (Production Approval Procedures). It is open for comment through April 21, 2025. A cursory review shows that the in-line sample documents have been removed from the PMA section. This is an opportunity to ask the FAA to address some industry concerns, like directions that … Continue reading