Starting from August 12th, China National Airlines' CA723/724 flights to Ulaanbaatar will be operated by the C919 aircraft. This is the first time since the C919 was put into commercial operation that it has been used for regular international commercial flights, marking the official entry of the C919 into international markets.
On July 17th, prior to this, Cambodia National Airlines and Commercial Aircraft Corporation of China signed a purchase agreement for 20 C909 aircraft in the presence of Prime Minister Hun Manet of Cambodia. As a result, Cambodia National Airlines became the first foreign airline to purchase a large number of C909 aircraft, and it is also the airline flying the flag of the country.
One in the south, one in the north; one based in China, one overseas. Both involve moving forward. On one side, the C919 makes its first appearance on international regular routes, while on the other side, the C909 receives its first batch of overseas orders. These two events may seem similar, but they actually represent two different stages in the process of domestic large aircraft going global. The C919 aims to determine how domestic airliners can fly overseas, while the C909 focuses on how domestic aircraft can truly establish a foothold overseas.
The China Southern Airlines flight CZ6786, operated by the C919 aircraft, landed at Haikou Meilan International Airport. Photo: Xinhua News Agency
The C919 taking off into the sky
Since its commercial operation started in 2023, "when the C919 will fly overseas" has been one of the most concerned issues among the public. Previously, the C919 has participated in air shows in Singapore, Vietnam, and the UAE, and has also operated on commercial routes between the Chinese mainland and Hong Kong. Flight demonstrations at air shows have proven that this aircraft can fly abroad. Static displays overseas have also given foreign airlines, regulatory agencies, and ordinary spectators the opportunity to enter the cabin, sit in seats, and get a close look at this Chinese-made airliner.
But an airshow is still just an airshow, not a real flight abroad. The airplanes participating in the airshow are backed by strict safety measures and thorough preparations. What they actually perform are merely transhipment flights and flight demonstrations. Such special activities can be supported with concentrated resources as 'special tasks'.
Commercially operated regular international flights are a different matter. They test the support capabilities of overseas locations, as well as whether a complete operating system can function continuously under normal overseas conditions. Can ground crew members proficiently carry out maintenance tasks at other stations? Can faulty aviation supplies be delivered in time? Can domestic bases provide quick and effective remote support? These issues are much more complex than simply completing a flight transition at an air show.
A successful flight at an air show can be ensured by focusing efforts to eliminate any risks. However, a regular flight must operate repeatedly over more than 300 days of the year, facing weather changes, crew rotations, fuel consumption, and various unexpected failures. The former demonstrates that the C919 can fly successfully; the latter tests whether the C919 can truly integrate into the international civil aviation system.
Therefore, choosing Beijing-Ulaanbaatar as the first international flight route for the C919 was a carefully considered decision.
This flight route covers a distance of only about 1200 kilometers, which is comparable to the distance between Beijing and Shanghai. This is precisely the comfortable range for narrow-body aircraft like the C919. With short distances and frequent flights, the entire journey is within the maintenance radius of Air China’s Beijing headquarters. Common issues are handled directly by the outstation mechanics, while in case of complex faults, Air China’s Beijing base can quickly send support to Ulaanbaatar. Moreover, compared to airports like Tokyo or Seoul, where flights are highly dense and the apron operations are busy, the operating environment at Ulaanbaatar is relatively simple, making it an ideal “novice village” for C919 aircraft.
In fact, for the C919, which country it flies to is not the key issue. Going global itself is of great significance. Looking at the development patterns of the global civil aviation industry, a new generation of airliner requires substantial investment in research and development, maintenance of supply chains, and support for subsequent improvement of models. The entire lifecycle typically requires production volumes in the four-digit range. China has the world's largest civil aviation market, and domestic demand is sufficient to support the C919 in completing initial mass production, fleet expansion, and accumulating operational experience. However, to become a truly successful world-class airliner, relying solely on the domestic market is not enough; it must also go global.
The “going overseas” mentioned here does not refer to flying an aircraft abroad, nor does it mean simply adding an international destination to the schedule as a completion of the task. For a commercial aircraft, true internationalization means its ability to enter the aviation regulatory systems of different countries, be purchased and operated by foreign airlines, and receive stable aircraft parts, maintenance, training, and technical support in locations far from the manufacturer’s home country. It is only when the C919 is painted with the livery of a foreign airline, piloted by foreign crew members, and operates under the supervision of local authorities that it truly enters the international market. Currently, Air China’s C919 flying to Ulaanbaatar is just the first step in a long journey, but this step is valuable.
In domestic operations, a smooth coordination mechanism has been established among airlines, airports, maintenance units, and Commercial Aircraft Corporation of China. Even in the event of complex faults, technical support and aircraft materials can be rapidly dispatched. When flying abroad, aircraft face completely different climatic conditions, airport facilities, operating rules, and regulatory procedures. Are the technical documents suitable for use overseas? Can aircraft materials be cleared through customs in time? Can the maintenance staff at foreign airports accurately diagnose problems? Can Commercial Aircraft Corporation of China provide round-the-clock cross-border technical support? These questions do not have complete answers when operating domestically.
It is precisely because of this that the C919 flying over Ulaanbaatar has far more significance than simply adding an international flight destination. It represents the first time the C919 has been put into a real and continuous external operating environment, allowing the aircraft, airlines, and Commercial Aircraft Corporation of China to be tested together. What might be tested today is just the sand and dust at Ulaanbaatar Airport; tomorrow, we may face high temperatures and humidity in Bangkok, high-density operations in Singapore, complex island-line networks in Jakarta, and even the hot sandstorms in the Middle East.
Overlooking Ulaanbaatar - Photo: Xinhua News Agency
Internationalization is not achieved in domestic offices, but through a series of overseas routes, repeated maintenance at foreign stations, and the training of batches of foreign maintenance personnel. The operational data accumulated during this process is the best demonstration—showing potential customers how the C919 operates overseas, using facts to dispel concerns.
Therefore, for the C919, which country it flies to may not be the most important thing. What matters is that it has finally started to expand its operations overseas. Only by going global can problems that arise during domestic operations be identified, and a truly international customer service and aviation cooperation capability be established. Only then will the C919 have the opportunity to grow from an domestic aircraft designed primarily for the Chinese market into a commercial aircraft that serves the world market.
Of course, at this point, we have to return to that old problem: hasn’t the C919 still not received airworthiness certification from the FAA or EASA? How can it fly abroad then? This is actually a misunderstanding. There is no regulation stating that airworthiness certification from Europe or America is required for aircraft to fly on international routes. According to the Convention on International Civil Aviation, as long as an aircraft’s country of registration has obtained airworthiness certification and meets the minimum standards set by the ICAO, other contracting states should recognize it and allow it to operate on their territories. In other words, as a contracting state, the C919 registered in China can fly anywhere within the contracting states. However, for foreign airlines to purchase the C919 and register it in their own countries, they must first obtain airworthiness certification in their home country.
This time, the Sino-Mongolian air route is based on this arrangement: Mongolia accepts the airworthiness documents issued by the Chinese Civil Aviation Administration, allowing Chinese-registered C919 aircraft to operate on Sino-Mongolian international flights. If Mongolian airlines want to purchase C919 aircraft and operate them in Mongolia, they need to obtain airworthiness certification for C919 separately, or go through the VTC (Type Certification) process—that is, the TC (Type Certificate) issued by the Chinese Civil Aviation Administration must be reviewed and approved, and then a domestic TC should be issued. Only after completing this step can C919 be sold to foreign customers.
Historic twenty orders
This is the first time the C919 has flown abroad, but for the C919, going overseas is already a common occurrence. In fact, it has been operating regularly among overseas customers for several years.
In December 2022, Indonesia Airlines introduced the first C909 aircraft (then still called ARJ21) through a lease arrangement, marking the beginning of the C909's journey overseas. Over the course of more than three years, the C909 has achieved excellent operational results with Indonesia Airlines. It has flown continuously for several days at a time, setting a record with six flights per day (15.88 hours).
This data, which shows that the C909 performs even better overseas than in China, fully demonstrates the quality of the C909. Moreover, its excellent flying performance makes it particularly effective in Southeast Asia, where conditions are hot and humid and runways may be poor. As a result, the number of C909s operated by Indonesia Airlines has increased from one to five. This change serves as a good example for the overseas promotion of the C909.
Therefore, over the past two years, the C909 has been exported to many countries, including Laos and Vietnam. However, these exports were all in the form of leases. Some of these leases were even wet leases, meaning that the aircraft were rented to foreign customers along with their entire equipment. Although this arrangement significantly reduced the barriers to introducing and using the C909, it still felt like a lease rather than a purchase. The purchase of 20 C909s by the Cambodian National Airlines is meant to finally address this issue of “purchase”.
Yue Jie Aviation leases aircraft model C909.
Buying 20 aircraft means that the Cambodian national airline is preparing to establish a long-term fleet around the C909 model of aircraft. For an airline that isn’t very large, 20 C909s would be sufficient to make them the main aircraft for its regional flight network. The challenges faced by the C909 abroad have shifted from simply whether it can fly, to whether it can fly over a long period of time and on a large scale.
One or two aircraft can be fully supported by the manufacturers’ on-site staff. However, 20 aircraft require a complete overseas support system. The support mentioned here does not simply refer to sending several engineers to repair the aircraft when it breaks down. It involves a comprehensive system that includes training for pilots and maintenance personnel, preparation of operating manuals, development of maintenance capabilities, as well as provisions for aviation materials, technical support, and feedback on faults. When the C909 aircraft entered Laos for operation, Commercial Aircraft Corporation of China dispatched teams specialized in flight operations, cabin services, operation control, and maintenance to assist the customer with personnel training, manual preparation, material provision, and maintenance capacity building.
The most crucial aspect is to enable overseas customers to gradually develop the ability to independently maintain aircraft. Routine station inspections, minor fault repairs, and replacement of common components should be carried out by local maintenance personnel. For more complex issues, Commercial Aircraft Corporation of China (COMAC) needs to provide round-the-clock technical support and promptly send engineers when necessary. In the initial stage, it is normal to rely on COMAC’s dispatched personnel for training. However, if in a few years, even replacing tires or handling a fault requires waiting for domestic personnel, then this fleet cannot be considered truly autonomous.
Aviation materials support is another issue that is often overlooked. Aircraft are valuable assets, and depreciation, loans, or rent payments do not stop regardless of whether the aircraft is in flight or not. If an aircraft is grounded for half a month due to the lack of a common component, the loss can far exceed the cost of that component itself. Therefore, a mature overseas support system should not only have maintenance personnel, but also include a ready stock of aviation materials, stable international transportation and customs clearance channels, as well as the ability to provide emergency support during AOG situations after the aircraft is grounded.
Whether an aircraft has a malfunction and thus requires several weeks of waiting for domestic delivery, or whether parts can be found at the regional maintenance depot on the same day, this often has a greater impact on airlines' purchasing decisions than the price differences in aircraft catalogs. This is precisely where Boeing and Airbus have advantages. Their decades-long experience has led to highly refined MRO systems, with a service network that covers the entire globe. For Commercial Aircraft Corporation of China, however, all of this requires starting from scratch and establishing pilot projects.
As the size of the Cambodian fleet expands, more extensive maintenance and repair work must be planned in advance. It is important to determine which tasks can be completed in Cambodia and which need to be sent to Southeast Asian regional repair centers. Once problems occur with engines, landing gears, and avionics equipment, it is crucial to decide where these repairs should take place, rather than waiting until the aircraft are delivered on a large scale before finding temporary solutions.
This is also the key aspect of MRO. It isn’t simply about building a hangar, but rather a complex system composed of personnel qualifications, technical documents, maintenance licenses, supply of aircraft materials, and quality management.
In the long term, Commercial Aircraft Corporation of China cannot send personnel and deliver aircraft parts separately for every C909 in Southeast Asia. A more reasonable approach would be to rely on an expanding fleet in Cambodia, Indonesia, Laos, and Vietnam. Gradually establish regional aircraft parts storage facilities, training centers, and maintenance stations in Southeast Asia, allowing operators from different countries to share some of the support resources. This would not only shorten the time required to handle faults but also reduce the cost for individual customers to acquire C909 aircraft.
Therefore, the order for 20 aircraft from Cambodia represents both a market breakthrough for COMAC and a significant test of its ability to serve overseas customers. Delivering the aircraft is not difficult; what is challenging is ensuring that the aircraft can maintain high daily utilization rates and normal flight schedules even after five or ten years. Previous leasing operations have proven that the C909 can be flown overseas, but the bulk purchase in Cambodia will test whether COMAC can bring training, aircraft parts, maintenance, and technical support with it, so that the C909 can truly establish itself in the market.
The C919 has flown overseas, and the C909 has received batch orders. This means that the two domestic large aircraft have progressed from demonstration flights to commercial operations, and from individual aircraft testing to a larger fleet operation. But flying overseas is just the beginning. The real challenge lies in whether these aircraft can fly long-term, stably, and at low cost overseas. If COMAC truly wants to create a tripartite competition with Airbus and Boeing, then going overseas is not just an added bonus; it’s a position that must be secured. The step taken by the C919 and C909 is a crucial lesson for domestic large aircraft as they go global. And there is no make-up exam, nor any shortcuts in this journey.
