Guidance on Qualified Spare Parts
Guidance on Qualified Spare Parts
Advisory Circular
Issued by: MHG [2023] 32
No.: AC-120-FS-058 R4
Date of Issuance: Sep 27, 2023
Table of Contents
2. Applicability .................................................................................................................. 2
3. Repeal ............................................................................................................................ 2
4. Expositions .................................................................................................................... 2
2. Applicability
The requirements stipulated in this advisory circular are applicable to CCAR-121 and CCAR-135
approved airline operators, their maintenance and service providers and the spare parts suppliers.
3. Repeal
The advisory circular AC-120-FS-58 R3 "Qualified Spare Parts" dated February 25, 2020 becomes
invalid upon the issuance of this advisory circular.
4. Expositions
Aircraft maintenance activities often involve the use of spare parts. The use of the qualified spare
parts is a very important aspect for ensuring aviation safety and protecting airline operator’s legal
interests. Qualified spare parts own two significant attributes: one is the legality pertaining to the
completeness, validation and qualified certification documents are justified in compliance with the
civil aviation regulation airworthiness requirements; and the second one is to ensure that spare parts
are and maintained in airworthiness conditions during the storage and shipment processes.
Additionally, majority of the Civil Aviation Authorities (CAAs) across the board have established
their own traceability requirements in refraining the use of the illegal spare parts from aircraft
maintenance use.
(3) The holder of Type Certificate who manufactures spare parts solely in accordance with the
approved Type Certificate;
5.2 The CAAC approved parts: refers to the components and parts manufactured by the
production systems approved by CAAC in accordance with CCAR-21, or repaired by the
maintenance organizations approved by CAAC in accordance with CCAR-145, and in compliance
with the type certificate data approved or accepted by CAAC.
5.3 The CAAC accepted parts, mean components and parts accepted by the CAAC and can be
installed on type certified products:
(1) Components and parts which are in compliance with the requirements of CCAR-21 and
those manufactured in accordance with the requirements by other CAAs approved production
and manufacturing systems according to the bi-lateral airworthiness agreements;
(2) Components and parts repaired in compliance with the requirements of CCAR-145 and
those repaired by MROs approved by other CAAs in accordance with the maintenance
cooperation arrangements or accepted by the parties involved in separate agreements;
(3) Components and parts which are undergoing warranty repair in a method specified by the
aircraft and component manufacturers if the subject components and parts are under warranty,
or those components and parts which are undergoing mandatory repairs or modifications in
specified methods assigned by the aircraft and component and part manufacturers as a result of
design or manufacturing defeats;
(4) Standard parts (like nuts and bolts) certified along with aircraft and its components
certification processes;
(5) Components and parts fabricated by air operators in accordance with the relevant CAAC
approved procedures and used solely in supporting its own operation;
5.4 Standard parts: Parts fabricated in accordance with established industry or national standards
or specifications, which include the design, manufacturing, and identification requirements. The
standards or specifications must be publicly released, and specified in the aircraft or part
manufacturer’s Instruction for Continued Airworthiness documents (ICAs).
5.5 Raw materials: Materials used for fabrication or supplemental processing to aircraft or parts
maintenance purposes, and those standards or specifications must be publicly released, and
specified in the aircraft or part manufacturer’s ICAs.
5.6 Brand new aircraft parts: Aircraft parts with zero flight hour or flight cycle accumulated
(excepts the hours or cycles experienced on Type Certification or bench test purposes).
5.7 Used aircraft parts: Parts other than brand new aircraft parts.
5.8 Spare Parts Suppliers: Agencies who supply the CAAC approved or accepted aircraft parts,
standard parts and raw materials to airline operators, MROs and distributors. Spare parts suppliers
include the CAAC approved or accepted aircraft/part manufacturers or MROs. Any other
representatives or agents (include organizations) who only provide information or shipment are not
recognized as spare parts suppliers.
5.9 Spare parts distributor: Any agencies or individuals who purchase aircraft parts, standard
parts or raw materials from spare parts suppliers, in its own name, and resale those purchased items
to other buyers.
6.1.1 The Authorized Release Certificate/Airworthiness Approval Tag (AAC-038 form) issued
by the CAAC approved production system certificate holders, and are used for the piece-part
items or to a group/batch of aircraft parts.
6.1.2 Parts fabricated in accordance with the Technical Standard Order Authorization (TSOA)
must have permanent and legible marking containing the following information:
(2) Part and part nomenclature, model number, part number or category ID;
6.1.3 Aircraft parts made in accordance to Part Manufacturer Approval (PMA) authorization
must have the part number identification marking, and provide the following information on
the PMA letter:
(1) Nomenclature;
Note: If the size of the part is too small for the marking, provide the subject information in the
letter is acceptable as well.
6.2 Except the standard parts and raw materials, the CAAC accepted brand-new parts shall be those
which are attached with the airworthiness approval tag/authorized release certificate issued by the
local CAAs or its authorized production system certificate holder for single piece items or groups
of the brand-new aircraft parts.
Note: Typical airworthiness approval tag/authorized release certificate are FAA 8130-3 form and
EASA Form1. However, since the FAA 8130-3 form is designed and normally used for exporting
airworthiness approval, trading of such spare parts without the subject form is limited within the
jurisdiction of USA only. In addition, the airworthiness approval tag/authorized release certificate
for spare parts from Russia and Commonwealth of Independent States (CIS) countries, is presented
in the form of part logbooks, certificates or quality assurance certificates.
6.3 Manufacturers of standard parts and raw materials shall provide documents justifying their
products are in compliance with the requirements corresponding to the standards or specifications
listed in their Instructions for Continued Airworthiness (ICAs) documents published by the aircraft
or and parts manufacturers.
6.4 Except the parts are temporarily removed (it also be known of robbing parts) from an active
airplane (include parked airplane), the installation of those robbed parts on other aircraft for system
troubleshooting purpose is acceptable. For any other used aircraft parts installation, under any other
circumstances must satisfy the following conditions:
(1) Except warranty repairs and mandatory modifications, any other part removals from an
active operating aircraft (include schedule and unscheduled maintenance), the maintenance or
repair to the removed parts should only be accomplished by the CCAR-145 approved or
accepted MROs with authorization of issuance of the airworthiness approval tag/authorized
release certificate;
Note 1: Warranty repair shall be conducted following the aircraft and part manufacturers
assigned methods, the airworthiness approval tag/authorized release certificate shall be issued
by the agencies performing the warranty repair, and the repair contract shall be going along
with the returned units.
Note 2: The airworthiness approval tag/authorized release certificate issued by the CCAR-145
approved maintenance agency is the CAAC AAC-038 form. If the similar type of certificate
(like FAA8130-3 form or EASA Form1) was already issued for the prior completed repair
process, as long as the repair agency conducting the repair is able to justify their repair work
was performed in compliance with the CCAR-145 requirements, the CAAC AAC-038 form can
be re-issued again to supplement the issued certificates; However, the re-issued CAAC
AAC-038 form must be sticked together with the pre-issued forms (like FAA 8130-3 or EASA
Form1); The CCAR-145 accepted maintenance agency means the maintenance organizations
approved by Hong Kong Civil Aviation Department (HKCAD) or Civil Aviation Authority of
Macau (AACM) in light of the Joint Maintenance Management document. The airworthiness
approval tag/authorized release certificate issued by HKCAD is HKCAD Form1 and AACM is
AACM Form1.
(2) If the parts are derived from dismantle airplanes, the agencies conducting airplane
dismantle shall be the CCAR-145 approved maintenance organizations holding airplane
dismantling authorization, and be authorized to issue the "aircraft dismantle part tags". The
parts back to dismantling traceability data can be queried and justified from the publicly
accessible aircraft dismantle search platform/website stipulated by the Advisory Circular
AC-145-FS-017.
Note: For the parts derived from dismantle airplanes, prior installation, it is required that
maintenance work shall be performed by the CCAR-145 approved or accepted maintenance
organizations holding the authority on the issuance of the airworthiness approval
tag/authorized release certificate.
6.5 Except the above-mentioned certification and marking requirements, any aircraft parts shall
have the following applicable information helpful to the end users in determining its airworthiness
status:
(3) Time limit/Cycle life limit (include operation hours, time since overhaul, cycle sine
overhaul, records and documents justifying its history if the parts are used items/not
brand-new);
(5) Routine work completion status according to the ICAs while in storage;
(7) Any other abnormal circumstances, like overload, accidental stoppage, overheat,
significant system fault or incident/accident etc.
Note: The information mentioned-above is normally provided by spare parts suppliers use the
airworthiness approval tag/authorized release certificate or other documents along with the parts
according to specific aircraft parts applicability. However, special attention shall be paid to those
items that documents are not come along with the delivery components (for example, airline
operators controlled, installation items due to the implementation of service bulletins), airline
operator spares management department shall establish a separate system to control them.
(4) Direct shipment delivery justification documents issued by the CAAC approved or
accepted production systems.
Note: If the CAAC approved or accepted production systems utilize their formal documents or
website to announces their direct sale/retail channels of their aviation products or its related
standard parts, raw materials, trading of these spare parts are recognized as direct purchases from
suppliers. For example, Boeing Global Service (former Aviall), Airbus SATAIR, COMAC affiliated
Shanghai Airplane Customer Service Company Limited etc. However, trading of any other aviation
products and its related standard parts, raw materials by Boeing Global Service (former Aviall),
Airbus SATAIR, COMAC affiliated Shanghai Airplane Customer Service Company Limited are
classified in the category of distributor sales. In addition, the CAAC approved or accepted
production system authorized non-direct sales channel are classified in the category of distributor
sales as well.
7.2 The CAAC approved or accepted MROs are recognized as the used aircraft parts suppliers,
however, they shall have the following valid and applicable certification documents:
Note: The information on the spare parts distributors accreditation program of industry
associations accepted by the CAAC can be accessed via the CAAC Information Bulletin
IB-FS-MAT-001 and any future updates.
8.2 Spare parts distribution is normally accomplished in the way of distributors purchase spare
parts directly from other suppliers, and then resale them to airline operators and maintenance
organizations. During the distribution phase, besides the required documents stipulated in
paragraph 6 of this document, the distributors are required to provide the shipment packing list,
invoices or other delivery certification documents enabling the traceability of the suppliers.
8.3 Under the circumstances of multistage distribution, aka distributors purchase spare parts from
one another, and then resale them to airline operators, maintenance organizations, the following
conditions shall be satisfied:
(1) Distributors doing business at all phases distribution shall be ones that accredited by the
industry association accepted by the CAAC;
(2) Distributors doing distribution business at any phase, shall provide additional justifiable
shipment packing lists, invoices or other certification documents enabling the traceability of
the purchase sources on top of the documents stipulated in paragraph 6 of this documents.
8.4 If the following conditions are satisfied, spare parts distributors can resale then in
batches/groups in case of there is only one certificate of compliance (CoC) for that batch/shipment
of spare parts:
(1) The spare parts distributors keep the original copy of the CoC, provides one true copy of
the selling distributor’s stamped CoC to the purchasers;
(2) Spare parts distributors shall develop a system and be used to keep the distribution records
if the spare parts were batch sold.
Note: If multi-stage distribution circumstances arise, the purchasing distributor’s CoC original
copy for record shall be the selling distributor stamped copy of the original CoC. If the subject
distributor resale its purchased items, it is required for the subject resale distributor to stamp its
own control chop on the CoC copy provided by its suppliers/distributors, and provide them to the
purchaser.
9.2 Data elements of the purchase contract shall at lease contain the part number (or model),
quantity, name of the supplier or distributor, certification documents of the purchased spare parts. If
purchased items are used spare parts, data elements in the purchase contracts shall contain the
required information stipulated in paragraph 6.5 of this document.
9.3 Spare parts purchase contract, certificates and other required documents may be retained
separately, but have to ensure the traceability enabling the correlation of the purchase contracts,
spare parts certification records and the rest of the required documents.
Note: if an extremely remote circumstance encountered that customer has to order spare parts
which are not in compliance with the requirements stipulated in paragraph 8 of this document, the
quality system of airline operators or maintenance organizations have to justify the sources prior
processing the purchase orders, and the related records has to be retained along with the purchase
contracts.
9.4 When purchase spare parts, airline operators or maintenance organizations have to consider the
following airworthiness limitation requirements:
(1) Parts exposed to high temperature, fire, salty water or corrosive fluid are considered
unserviceable parts. Installation of those parts require the CAAC approved or accepted
maintenance agency’s appropriate repairs and tests prior to be installed.
(2) Fabricated un-qualified parts removed from uncompleted accident investigation airplanes
are considered permanent unserviceable spare parts, shall not be traded.
9.5 When processing part repair orders, airline operators shall stick to the related requirements
stipulated in AC-121-FS-066. The requirements are applicable to the type and category repairs of
maintenance organizations internal self-repair, and the repairs covered by part exchange programs
or hourly warranty programs.
Note: If airline operators purchase the part exchange program or power by hours, special attention
has to be paid that airline operator’s maintenance and information feedback responsibilities are
not automatically exempted.
Note: Unless there are special instructions available from aircraft and parts manufacturers, the
internationally accepted spare parts packing standard is ATA Spec300 - Specification for
Packaging of Airline Supplies.
10.2 Spare parts shall be stored in appropriate and suitable warehouse to ensure not be damaged or
mixed up by store keepers/staff, and shall at least satisfy the following requirements:
(1) Adequate storage space and suitable storage shelves available to ensure proper storage
arrangement/lay out, with clear identification marking to avoid spare parts positioning mix-up;
(2) Measures of proper humidity, fire prevention, protection of excess exposure to sunlight,
explosion protection, adequate ventilation, no direct exposure to heat radiation and protection
of insect attacks;
(3) For spare parts requires special storage requirements, like temperature and humidity
control, static free protection, the stock room/storage area has to satisfy these requirements as
well.
10.3 Shelf-life control system has to be established for spare parts with shelf-life requirements. In
addition, measures of effective identification and controlling of the shelf-life has to be put in place.
Segregate the shelf-life over-due spare parts in time to avoid any issuances of them to the
requesters.
11.2 In order to avoid purchasing and use the unauthorized spare parts, airline operators and
maintenance organizations shall establish a system to ensure only the approved or accepted spare
parts are used. The system shall at least include the following features:
11.2.1 Spare parts supplier/distributor evaluation: Spare parts suppliers/distributors evaluation shall
be conducted by airline operators or maintenance organizations quality management department.
Roles and responsibilities of the evaluation team members shall at least include the evaluation of
suppliers/distributors documents and make records of the evaluation results to ensure the supplied
spare parts are the CAAC approved or accepted. Special attentions are required to the following
area:
(1) Suppliers/distributors offer a much lower quote price to spare parts supplied by other
suppliers/distributors;
(2) Suppliers/distributors guarantee a much short delivery lead time while the rest of all other
suppliers/distributors are out of stock;
(3) Suppliers/distributors claim that they supply any required spare parts;
(4) Suppliers/distributors cannot timely provide the CAAC approved or accepted documents.
Note: As Regard to distributors evaluation and the multistage distributors identity confirmation,
refers to the CAAC Information Bulletin IB-FS-MAT-001.
11.2.2 Spare parts receiving inspection: Receiving inspection shall be conducted by persons
holding aircraft maintenance license, with extensive aircraft maintenance or spare parts
management experiences. Inspection scope shall at least include inspections of the following
contents and make inspection records accordingly:
(1) Verify supplier’s identification marking is in presence of the package, and there is no signs
of broken sealing or damage;
(2) Verify the received units are in consistent with the shipment delivery sheets and the
purchase orders, ensure the part number, serial number and the history log (if applicable) is in
consistent of the data recorded on the papers and the ones on the received units;
(3) Verify that there are no signs of marking be altered (for example, serial number is not
overlaid, wrong or missing of trademark or part number, signs of chemical etching or serial
number shown at unusual position/place etc.);
(4) Make sure shelf-life and/or life limits are within in limit (if applicable);
(5) Visually check spare parts and the related documents, make sure that they can be traced
back to the CAAC approved or accepted supplying sources;
(6) Evaluate any visible abnormal conditions (surface being altered or looks abnormal, plate
surface missing, sighs of being used, signs of abrade, new paint layer on top of the old paint
layer, signs of repairs from outside of the units, surface rusting or signs of corrosion etc.);
(7) Sampling check large batch packed spare parts to make sure the models and quantities are
in consistent of the purchase orders;
(8) For spare parts require special storage environment, there shall be manufacturer’s special
storage instructions available (for brand-new aircraft parts) and the similar storage instructions
available from MROs (for repaired spare parts). If preservation is applied to the received units,
there shall be information on the preservation fluid used and the preservation due date
available;
(9) Quarantine and verify the suspicious spare parts (for example, waiting for required
documents, verify and confirm the abnormal conditions were caused during transportation or
by shipment handling etc.).
Note: When receiving inspection was performed, attentions have to be paid on verifying the name
and address of the shipping entities that are in consistence of the suppliers/distributors accepted by
quality department.
11.2.3 Airline operators or maintenance organizations shall effectively control and manage their
suppliers, establish the spare parts supplier list controlled by quality department. The data elements
of the supplier list shall at least include the following: Name, address and contact information of
the suppliers, methods and types of supplying the spare parts etc.
11.2.4 If airline operators or maintenance organizations purchase spare parts removed from
dismantle aircraft, a spare parts sources query system has to be established so as to verify the
purchased spare parts are come from the distributors which are accredited by the industry
association accepted by the CAAC. Distributor authenticity can be verified through the public
accessible information platform assigned by the subject industry association mentioned above.
Note: Information on the CAAC accepted industry association assigned information platform are
stipulated in the current AC-145-FS-017.
11.3 If airline operators or maintenance organizations spot any suspicious spare parts
suppliers/distributors or any suspicious unapproved spare parts at any time, report to the CAAC in
time. The CAAC encourages any individuals to report suspicious unapproved spare parts in the
way of real name or anonymously. Reports can be submitted to the CAAC regional Administration
or directly submit to the following address:
(1) The spare parts used for lease, loan and resale are the CAAC approved or accepted parts
with the certificates stipulated in paragraph 6 of this document;
(2) Prior being used for installation, the lease, loan and resale spare parts must undertake
(3) When lease or loan spare parts from spare parts suppliers/distributors which are not
included in operator supplier/distributors list, and the lease or loan duration exceeds 10 days,
the subject suppliers/distributors documents are required to be available.
12.2 When lease or loan operation life controlled aircraft parts, the following conditions shall be
satisfied:
(1) Its operation time is within airline operators specified life limit;
(2) Its operation time is within the loaner/lessors specified life limit.
12.3 Under the following circumstances, airline operators can temporarily lease or loan aircraft
spare parts without the CAAC approved or accepted certification documents with the unit from
other operators:
(1) If un-expect circumstances emerge during operation (for example, flight delay or
cancellation at out-station), airline operators can lease aircraft spare parts with airworthiness
approval tags similar to the CAAC AAC-038 form, to fix the aircraft system fault, but it has to
be removed within 10 consecutive days;
(2) If aircraft cannot be put into operation because of performing the mandatory modifications,
aircraft or aircraft part manufacturer’s warranty assurance or warranty claimed repairs, the
qualified rotable parts attached with justifiable certificates provided by aircraft or aircraft part
manufacturer can be used on the subject airplane prior to the failed part restored into
airworthiness condition and returned;
(1) Spare parts involved in the pooling program are those of the CAAC approved or accepted
parts. Their certification documents used for determining the airworthiness condition and
logged information are in compliance with the requirements stipulated in paragraph 6 of this
document;
(2) Members of the spare parts pooling programs shall have a suspicious unapproved spare
parts control system established in accordance with the requirements stipulated in paragraph
11 of this advisory circular;
(3) Members of the spare parts pooling programs are definitely playing in dominating roles.
The contents of the formal pooling agreement signed among other members and the members
in domination shall not be in violation of the related civil aviation regulations requirements of
China.
13.2 Airline operators or maintenance organizations shall bring the spare parts pooling participants
into their spare parts suppliers/distributors evaluation candidate list and enlist them into the
suppliers/distributors list.
14.2 If there is any distributor not incompliance with the civil aviation regulations have been
engaged in supplying unapproved spare parts to airline operators, maintenance organizations or
other spare parts distributors either intentionally or due to negligence, the CAAC will bring the
subject dominant responsible person into the unethical behavior record/list.