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Re:

Will Trump’s Sanctions Affect COMAC’s C919 Development?

U.S. export licensing on LEAP-1C engines reportedly disrupted C919 output in 2025, but the evidence does not show the program was halted.
From TheFinanceBase Team5 min to read
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Yes, U.S. export restrictions can slow the C919’s near-term production, but the available evidence does not show that they have halted its development. The clearest documented effect runs through engines. The C919 uses LEAP-1C engines, which GE Aerospace and France’s Safran build jointly and which contain U.S.-controlled technology. Exporting them to China therefore requires U.S. export clearance. Associated Press reporting says the United States suspended export licenses for these engines around May 2025, resumed them in July 2025, and that the interruption disrupted COMAC’s output plans.

Two parts of the title need correcting. Trump was president-elect only until his January 20, 2025 inauguration, so the measures discussed below date from 2025 and 2026. “Sanctions” is also loose shorthand. The policy tools that touch the C919 work differently, and only one of them has a documented effect on production.

Where the C919 program stands

COMAC reports that the C919 received a type certificate from China’s Civil Aviation Administration on September 29, 2022. The first aircraft was delivered on December 9, 2022, and the first commercial flight took place on May 28, 2023. The program is an operating one, not a paper project. The open questions are how fast production can scale and whether the aircraft can win approvals and customers outside China. Those are the areas where foreign policy has the most leverage.

“Sanctions” covers four different tools

Commentary often lumps every U.S. measure under “sanctions.” For the C919, four instruments matter, and they point in different directions. The table compares them on the axes that determine whether a measure can reach a Chinese production line.

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Instrument Direction of flow Target Status as of October 2026 Documented effect on the C919
Export license requirement (LEAP-1C engines) U.S. to China Engine technology and engines Suspended around May 2025; resumed July 2025 Output plans disrupted during the suspension, according to AP citing IBA’s Dan Taylor
Entity or financial sanction Varies by designation Named persons or entities No C919-specific designation identified in the sources cited None established for the C919
Section 232 proclamation (July 2026) Imports into the United States Commercial aircraft, engines and parts Directs negotiations with trading partners; the proclamation itself imposes no immediate Section 232 tariffs None documented; the measure does not govern exports to China
Outbound investment review (January 2025 presidential memorandum) U.S. investment into Chinese entities Investment, with aerospace among the sectors named for possible new or expanded restrictions Review discussed; no C919-specific restriction identified Not stated; any effect is prospective

Only the first row has a documented production effect. That is why “export controls” describes the mechanism more accurately than “sanctions” does.

How an engine license reaches the production line

The engine pathway is the one place where the reporting traces a complete chain. As AP describes it:

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  1. The LEAP-1C engine is built jointly by GE Aerospace and France’s Safran.
  2. Because the engine incorporates U.S.-controlled technology, exports to China need U.S. export clearance.
  3. Around May 2025, the United States suspended export licenses for these engines, according to IBA’s Dan Taylor as cited by AP.
  4. The licenses resumed in July 2025.
  5. Output plans were disrupted during the gap.

The documented shock is a roughly two-month license gap. The reporting does not put a number on the aircraft affected or on any resulting development delay, so the effect on delivery schedules cannot be separated from other causes.

Beyond the engine: avionics and other foreign content

The U.S.-China Economic and Security Review Commission describes C919 avionics supplied through AVIAGE Systems, a joint venture involving GE and AVIC. It also reports continued imports of components including communications equipment, flight-control systems, and tires. AP reports major suppliers from the United States and Europe, including GE, Honeywell, and Collins Aerospace.

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AP’s supplier counts come from Bank of America analysts, not from an official registry:

Supplier origin Count Attribution
United States 48 major suppliers Bank of America analysts, as reported by AP, 2025
Europe 26 suppliers Bank of America analysts, as reported by AP, 2025
China 14 suppliers Bank of America analysts, as reported by AP, 2025

Dan Taylor, head of consulting at aviation consultancy IBA, put the exposure this way: “Engine and avionics dependence on Western suppliers continues to expose the program to policy decisions beyond COMAC’s control.”

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The domestic engine alternative

China’s answer to the engine problem is the CJ-1000A, a domestic engine developed over a decade-long effort. The Commission’s 2025 assessment says the effort had not yet produced a commercialized C919 engine. AP, citing IBA, reports that the CJ-1000A was still under testing. Neither source gives a dependable date for a production-ready replacement, so the engine exposure remains a current issue rather than a settled one.

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Delivery performance has several causes

The figures below show the scale of the ramp-up and how each one is attributed.

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Metric Figure Source and date Qualification
C919 deliveries in 2024 13 aircraft U.S.-China Economic and Security Review Commission, 2025 Calendar-year count
Share of domestic demand met by 2024 deliveries 7 percent, against a 10 percent target U.S.-China Economic and Security Review Commission, 2025 As reported by the Commission
Deliveries against the 2025 target 7 by October 2025, against a reported target of 30 Associated Press, citing Cirium, 2025 Dated snapshot; the target is AP’s reported figure and the count does not reflect later 2025 or 2026 output

Export restrictions are one cause of the shortfall, not the whole explanation. Max J. Zenglein, Asia-Pacific senior economist at The Conference Board, told AP: “COMAC faces significant risk from the volatile policy environment, with its supply chains vulnerable to export restrictions and tit-for-tat measures between the U.S. and China.” He also said COMAC’s cautious focus on quality and safety may contribute to the slower ramp-up. Any account that attributes every missed delivery to sanctions goes beyond what the reporting shows.

Certification limits exports separately

The Commission’s 2025 assessment reports that the C919 had not pursued U.S. Federal Aviation Administration type certification. It also says the European Union Aviation Safety Agency was not expected to certify the type before 2028 at the earliest. That was the Commission’s outlook, not a guaranteed date. Richard Aboulafia, managing director of AeroDynamic Advisory, told AP: “For the C919 to succeed, it ‘needs to have each one of three things: good economics, a prompt global product support network, and certification from safety agencies’.” Certification gaps limit where the aircraft can be sold, regardless of how component controls play out.

What the July 2026 proclamation does and does not change

A July 2026 White House proclamation under Section 232 addresses U.S. imports of commercial aircraft, engines, and parts. It directs negotiations with trading partners. The proclamation itself imposes no immediate Section 232 tariffs. Because its text addresses imports into the United States, it does not restrict component shipments to China and should not be read as a tariff on C919 components entering China.

What this means for investors

Most readers who ask this question hold an aerospace company, not an aircraft. The reporting names GE Aerospace, Safran, Honeywell, and Collins Aerospace as part of the supply chain, but it does not quantify how much revenue any of them earns from the C919. Being listed as a supplier is therefore not evidence of material exposure. Company filings, rather than aviation trade reporting, are the place to check that.

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The developments most likely to change the picture are:

Quick Recap

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  • Changes to U.S. export licensing for LEAP-1C engines, the one mechanism with a documented production effect.
  • The outcome of the trade negotiations directed by the July 2026 Section 232 proclamation.
  • Any European Union Aviation Safety Agency certification milestone, since 2028 is the earliest date reported.
  • Updated delivery counts measured against COMAC’s 2025 target of 30, using the same kind of tracking data AP cited from Cirium.
  • Whether an outbound investment rule is finalized with aerospace named as a sector.

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