Template for Requesting CAAC Special Approval

In December, the Civil Aviation Administration of China (CAAC) issued a notice to U.S. repair stations that it would no longer consider Special Approval applications for certificate extension. Pending new on-site audits for repair station approvals in 2024, repair stations were provided two avenues to continue work for Chinese customers:

(1) File a request before the end of December 2023 to continue work already under contract. ARSA has heard from multiple members that followed the procedures provided by the CAAC to file this request that certification extensions were provided for the related work; these extensions are valid through 2024 or until full certification is restored after audits are complete.

(2) Have Chinese operators apply for special approval for use of the repair station as an “unlicensed repair unit,” which would allow for work to be performed on items not already covered under a special exemption, i.e., for new work under contract. ARSA has produced a template letter for use by members – to complete and route through the appropriate maintenance-related office of a Chinese operator for submission to the CAAC – and delivered it to regulators for review.

The template letter includes instructions for use and is formatted as a letter for inclusion under the Forms Manual of ARSA’s RSQM Compilation. As explained in the instructions, it’s purpose is to provide the format and information necessary for a Chinese operator with approval under CCAR-121 or CCAR-135 to request Special Approval from CAAC to use the repair station as an unlicensed repair unit (i.e., non-certificated contract maintenance provider under the Chinese regulations) following the temporary expiration of the repair station’s CAAC maintenance organization certificate (MOC) pending renewal. This letter must be approved and submitted to the CAAC by the operator, signed by its maintenance management, e.g., Maintenance Department Vice President (CCAR-121) or Supervisor (CCAR-135). The repair station may prepare it for delivery to assist its customers in requesting Special Approval allowing continuation of work.

Interested members may download the template letter, which is now included in the association’s “tools for members,” by completing the form below. ARSA will provide updates based on feedback or policy guidance from the CAAC. Repair stations with questions or comments based on CAAC certification should contact the association.

After submission of the form, a download of the .docx file will initiate.

  • This field is for validation purposes and should be left unchanged.

Previous updates involving Chinese oversight...

4/5/22 - CAAC Seeks Comments on 145 Guidance

April 5, 2022

The Civil Aviation Administration of China (CAAC) is collecting comments on three documents related to CCAR-145R4. The draft guidance materials cover certificate applications as well as personnel qualification and safety management under the Chinese maintenance rules. 

The following Advisory Circulars are open for comment (click the document identifier to download an English language Word document version): 

(1) “Guidelines for Domestic Maintenance Unit Application and Approval” (AC-145-FS-001R1). 

(2) “Development of Maintenance Unit Training Syllabus” (AC-145-FS-013R2). 

(3) “Quality and Safety Management System for Maintenance Units” (AC-145-FS-015R1). 

ARSA encourages impacted members to submit comments, feedback, and suggestions to, with the subject line “CCAR-145R4 related AC feedback.” The deadline is April 15. 

Note: The original announcement from the CAAC included a sample comment matrix in Mandarin. Contact the authority for English-language guidance related to submission (if necessary). 

5/19/20 - CAAC Updates 'Simplified Approval Process for OEM’s MROs'

May 19, 2020

A member was kind enough to point out temporary guidance issued by the Civil Aviation Administration of China (CAAC) regarding its “Simplified Approval Process for OEM’s MROs.”

While, unfortunately, the process only applies to “OEM MROs,” it will help the owners and operators obtain services from approved maintenance organizations of other nations.

The document is accessible through a link on one of CAAC’s websites

Click the image to expand; the highlighted areas direct to relevant guidance updates provided via the portal.

3/20/18 - FAA Provides Follow Up on Written Questions from China IPA Training

March 20, 2018

Update: On March 20, the FAA provided responses and follow up information to all questions submitted in writing during the live session.

Click the image to register for the training session.

A PDF document containing these responses has been uploaded into the session materials available through the training platform (this document contains no information regarding who asked each question, in order to protect participant privacy). Participants in the live session may access this document by going to their account page on New registrants will get access to this material along with the session recording. 

On Jan. 17, ARSA hosted an online training session led by FAA personnel on the Implementation Procedures for Airworthiness (IPA) established under the Bilateral Aviation Safety Agreement between the United States and China. This session mirrored the presentation delivered to FAA staff in November 2017, focusing on the use of the IPA when the FAA is acting as the certifying authority.  It was intended to provide industry with the background and major concepts of the agreement, and highlight specific areas relevant to CAAC validation of U.S. products.

The on-demand version of the session is available for registration and immediate access (registrants for the live session also get access to the recording for 90 days).


Tom Groves is a Supervisory Aerospace Engineer in the FAA’s Aircraft Certification Service Transport Standards Branch.  He is currently working on temporary assignment with the International Division, providing technical expertise to support development of high-priority bilateral agreements such as the EASA TIP and the IPAs with both China and Brazil.

Daniel Commins is a Foreign Affairs Specialist in the FAA’s Aircraft Certification Service International Division.  As the focal point for AIR’s international engagement with China, he manages the bilateral relationship and manages projects such as IPA development and other bilateral activity.


(1) FAA – CAAC IPA Status and Background
(2) FAA – CAAC IPA Change Management Plan
(3) Q&A
(4) FAA – CAAC IPA Key Validation Concepts
(5) Validation Process Overview – FAA as the Certifying Authority
(6) Summary
(7) Q&A

Target Audience

Aviation industry professionals and stakeholders with interest in the FAA’s administration of international aviation agreements.


Special Session Price: $30 (ARSA Members and Non-Members)

Click here to register and get unlimited access for 90 days.

Registration for this ARSA-provided training session includes:

  • Unlimited access to the recording for 90 days.
  • A copy of the presentation and all reference material with links to relevant resources and citations.

The association’s training program is provided through Obadal, Filler, MacLeod & Klein, P.L.C., the firm that manages ARSA. To go directly to OFM&K’s online training portal, visit To learn more about the association’s training program and see course availability, visit


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