China’s Crossover Gap: One Aircraft Has a Key

China has a Crossover Gap: The A220 and E2 Are Both Locked Out — But One Has a Key The A220 recently passed 1,000 orders. The E195-E2 has passed 500. Both aircraft are thriving in the global market. Neither has been ordered by a single Chinese airline. But one of them has already landed at Beijing's Daxing International Airport — and that distinction tells you a lot about how China manages its aviation market. The Wall Neither Aircraft Has Overcome Despite Airbus having significant manufacturing presence in China — a FAL in Tianjin, an A330 finishing line, and fuselage sections for the A220 itself being made in Shenyang — there have been no A220 orders from Chinese airlines or lessors. Airbus is planning a push to sell the A220 into China, where its only presence is the Shenyang fuselage work exported to Mirabel for final assembly. Our recent visit showed how the AirAsia deal is seen as a 'door opener'. The E195-E2 is in the same position. Despite Embraer running active sales campaigns in China since at least 2022, no Chinese carrier has placed an order for the type. The crossover segment — roughly 100-150 seats — that both aircraft own globally is, in China, a market that belongs to COMAC alone. The reason is straightforward and structural. The CAAC has been withholding administrative approvals required for foreign aircraft to formally enter service in China, a process that has become entangled with geopolitical and industrial competition as Beijing seeks to establish COMAC as a credible global competitor. The A220 sits between COMAC's ARJ21 and C919 in seat count — ordering it would expose the gap in COMAC's lineup that Beijing needs to paper over. The E195-E2 faces the same challenge. But One Aircraft Has Already Landed in Beijing Hunnu Air launched scheduled E195-E2 service from Ulaanbaatar to Beijing's Daxing International Airport — the first E2-generation jet to operate in mainland China. Embraer's own CCO explicitly marked the occasion. The airline plans to expand its footprint in China with this aircraft. Hunnu Air is Mongolian, not Chinese. That distinction matters enormously. The carrier operates the E195-E2 on routes to Haikou, Sanya, and Beijing, expanding services to Japan, China, Vietnam, India, and South Korea. China is allowing foreign operators to fly E2s into its airports. It is not allowing its own carriers to buy them. The wall is not about the aircraft — it's about who owns it. Crucially, the E2 is certified by China, but no orders as yet. Why the E2 Has the Better Political Hand The A220's path to China faces structural headwinds that extend beyond competition from COMAC. The aircraft originated as Bombardier's CSeries — a Canadian program. Canada-China relations have been severely strained since the Meng Wanzhou arrest in 2018 and the subsequent detention of two Canadian citizens. Airbus entered talks with the CAAC about A220 certification in September 2021, after airlines in western China expressed interest — but no certification has followed in nearly five years. That's not a slow bureaucratic process. That's a deliberate hold, and it's not the first time CAAC has flexed like this. The E195-E2's geopolitical position is cleaner. Embraer is Brazilian — operating under the BRICS umbrella rather than as a Western adversary. Brazil-China bilateral relations are strong and have no equivalent diplomatic rupture to navigate. Beijing has less leverage to extract from Embraer than it does from a European manufacturer whose regulator (EASA) controls C919 certification, or an American manufacturer whose government controls export licenses. The Hunnu Air Precedent Is the Signal to Watch After taking delivery of its second E195-E2 in December, Hunnu Air plans to further expand its E2 fleet, with executives in discussions with lessors for an additional aircraft. The airline's market share of Mongolia's international travel has risen from 5% in 2022 to 12% currently. Its China routes — Beijing, Haikou, Sanya — are the core of its international network. The E195-E2 is now a regular, certificated, operating presence at mainland Chinese airports. Not operated by a Chinese carrier, but present, recognized, and commercially viable on Chinese routes. That's a beachhead, not a breakthrough — but it's one the A220 doesn't have. The A220-500 Wildcard Airbus is now planning a push into China for the A220, with the prospective A220-500 stretch as a potential catalyst. A stretched A220 with 160 seats competes directly with the C919 — making it simultaneously more attractive to Chinese carriers hungry for capacity and more threatening to COMAC's domestic strategy. Beijing's calculus on that trade-off will determine whether the A220-500, if it's ever launched, gets a different reception than the current variants have. Bottom Line China is not closed to crossover segment — it's closed to Chinese carriers owning them. A Mongolian airline can fly an E195-E2 into Beijing today. A Chinese airline cannot order one. The A220 hasn't even reached that stage — no foreign carrier is flying it into Chinese airports either, and five years of CAAC certification talks have produced nothing. Both aircraft face the same structural wall. The E2 has found a side door. The A220 is still looking for one.

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China has a Crossover Gap: The A220 and E2 Are Both Locked Out — But One Has a Key

The Wall Neither Aircraft Has Overcome

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China has a Crossover Gap: The A220 and E2 Are Both Locked Out — But One Has a Key

The Wall Neither Aircraft Has Overcome

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