COMAC’s Advantages Isn’t Delivering

Conversations about COMAC invariably are about its potential. The OEM has a captive market. It is state-owned and serves state-owned customers - lots of patience all around. Customers outside its home market receive favorable financing from other state-owned financial institutions. This is a great environment. But COMAC struggles all the same. Even with its structured and protected environment, production seems very slow by comparison with its peers. This lethargic production rate has a material impact on its captive customer base. Backlog COMAC's backlog for C909 and C919 is ~1,500 undelivered aircraft, focused on domestic demand. The C929 has memorandums of understanding but no firm backlog yet. COMAC's overall production is ramping up, but delays persist due to certification hurdles (e.g., EASA certification potentially 3-6 years away) and supply constraints. Of particular concern is the C919, now the jewel in COMAC's product lineup. Approximately 1,150 aircraft in backlog, predominantly for Chinese airlines and lessors such as China Eastern Airlines (105), Air China (105), and China Southern Airlines (100). Customer Frustration China's airlines are facing the same pressure as all airlines: rising traffic and a need for more capacity. In December 2025, Airbus secured a series of significant orders for A320 Family aircraft from several Chinese airlines and lessors, totaling around 148 aircraft. These deals, announced primarily on December 30 and 31, reflect strong demand for fuel-efficient narrowbody jets amid China's aviation recovery and fleet modernization efforts. The orders are dominated by the A320neo variant, which offers reduced emissions and operating costs. The A320neo focus speaks directly to the C919, which is almost identical in capacity. Chinese airlines with MAX orders are also taking delivery of them. With its huge backlog, COMAC is clearly not delivering what its customers ordered. Moreover, the commercial aviation backlog is now reaching levels not seen before. [caption id="attachment_186518" align="aligncenter" width="580"] AirInsight[/caption] Ignoring the pandemic spike, the trend is unmistakable. Lessors and airlines must place orders or be left behind using relatively fuel-inefficient aircraft. Given duopoly constraints, this should be COMAC's moment. The Duopoly Shadow COMAC cannot attract the level of attention that Airbus and Boeing can. This means living in the duopoly's shadow. The table below lists the first flights by OEM. In 2025, the duopoly outpaced COMAC by more than 45. If you operate an airline, what would you do? [caption id="attachment_186516" align="aligncenter" width="346"] AirInsight[/caption] CFM, COMAC's engine supplier, will obviously focus on the duopoly first. The same with other Western inputs. This is the driver behind COMAC's switch to Chinese suppliers. This is what UAC did in Russia. But notice how long it took the Russians to develop local engines, even though the country has a long history of engine development. China may have the same level of talent pool, but it takes time. Nonetheless, China is working hard at it. It's not clear what the pacing item is for the C919. But engines are a good bet, as we saw at Airbus, where they were the pacing item. Production Shortfall COMAC can reasonably blame the US for its failure to meet the 2025 target. Politics was brutal, and it took months for the sanctions and other disruptions to be lifted. [caption id="attachment_186517" align="aligncenter" width="580"] AirInsight[/caption] The decline in 2025 also suggests that COMAC did not keep sufficient stockpiles of the Western inputs it needed. The new US administration signalled its thinking throughout its campaign. There's a lesson here for more than COMAC. COMAC should have learned this lesson from Russia, though. The Learning Curve Finally, let's look at the learning curve proxy, delivery days. This is the period between the first flight and the delivery flight. What we see in every program is a high start, followed by a steady decline over time. This curve reflects the maturity of industrialization and, essentially, the learning curve. [caption id="attachment_186515" align="aligncenter" width="580"] AirInsight[/caption] COMAC has been building the C909 (formerly ARJ21) for a long time. The ARJ21 regional jet program was announced in 2002, with development beginning that March. Its first flight occurred in 2008. The aircraft entered commercial service in 2016. Such a timeline is eye-poppingly long. The C909 should be the program that teaches COMAC how to do better. Indeed, we see that the C919 curve is descending over time. But the C919 curve flattened out in 2025. Was the due to the political disruptions? Most probably. That said, why does the C909 program not show the kind of maturity other programs do? We would expect that curve to be lower than the C919 by now. Summary COMAC has almost all the advantages an OEM could ask for. Its Achilles Heel is the absence of a Chinese supply chain. That is being worked on. However, our data suggest that COMAC might be facing other issues that are not supply chain-dependent. Delivery days begin with the first flight. That means the aircraft is produced, it has engines and cabin fixtures. Yet this metric is not declining at expected rates. Why do their aircraft take so long to be accepted and delivered? Chinese airlines see the same level of this metric from Airbus Tiajin FAL as they do from European FALs. Airbus Tiajin clearly has a talent pool that has moved down that learning curve to match its peer group. COMAC remains woefully behind, and this slow progress is to its detriment. By all the other metrics, it should be producing and delivering at much better rates.

US Flight Planner - US DoT On-Time Data	Airbus vs Boeing - Official OEM Data
US Airline Schedule Performance - US DoT Data	Daily OEM Production & Deliveries -

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