Major US-based original equipment manufacturers (OEM) have voiced opposition to a section 232 national security investigation into imports of commercial aircraft, jet engines and associated components, with most calling on the commerce department to commit to a tariff-free regime.
The probe, launched on 1 May, elicited input from 205 stakeholders — ranging from individuals to leading aerospace companies — during a three-week comment period.
The US is host to the largest aerospace and defence (A&D) industry in the world, and has maintained a positive trade surplus for over 70 years, according to the Aerospace Industries Association (AIA). The US exported $135.9bn worth of A&D goods in 2023, with a positive trade balance of $74.5bn, AIA data show. Respondents attributed this surplus to the World Trade Organization's 1979 Agreement on Trade in Civil Aircraft, which covers trade in civil aircraft, engines and parts between 33 signatory countries including the US, EU, UK, Canada and Japan.
Domestic OEMs warn of supply chain disruption
Boeing noted that while it relies heavily on domestic sources for its supply chain, around 75pc of its revenue comes from overseas customers, so "foreign market access is critical to Boeing's competitiveness". US carriers will account for only 18pc of the nearly 44,000 new aircraft projected to be built over the next 20 years to meet growing air travel demand, it added.
Boeing emphasised the need for diverse global supply chains, adding that quality and regulatory constraints make rapid onshoring of manufacturing capacity a challenge.
The critical nature of aviation requires articles to be subject to stringent safety and quality standards. "It may take up to 10 years to establish a new domestic supplier and ensure they meet necessary, rigorous safety certifications," the AIA said.
High standards make any short-term disruption to a suppliers' operations particularly damaging.
"The loss of one supplier can take many years to rectify," Boeing's head of government, global public policy and corporate strategy Jeff Shockey wrote. "There are often no viable alternative suppliers that can quickly meet the required certification standards, and compromises on those standards — many of which are grounded in aviation safety — are not an option."
Kansas-based fuselage manufacturer Spirit AeroSystems urged the commerce department to prevent the implementation of import tariffs because higher duties would increase operating costs, upend long-term supply negotiations and add financial burdens to the industry.
The firm highlighted the importance of its UK operations in supporting major aircraft programmes, and said any trade restrictions on that country would create risk for its production schedules.
Virginia-based engine maker RTX cautioned that any tariffs levied under section 232 could threaten investment in its domestic manufacturing operations. This includes more than $1bn earmarked for its Asheville facility in North Carolina to expand production capacity of engine blades and vanes, and to add foundry operations for castings in the next few years.
RTX warned that any undue pressure on its US supply network — comprising 20,000 companies — could result in small businesses, which are still recovering from Covid-19, to "close their doors". That would have a cascading effect on the wider multi-tiered supply chain, RTX said. RTX subsidiary Pratt & Whitney's PW1100G-JM geared turbofan engine helps power Airbus' A320neo family.
EU, UK stress ties with US partners, facilities
The investigation drew responses from several European and UK OEMs that have significant ties to US aerospace supply chains.
Europe-based Airbus, through its US subsidiary, stressed that commercial aircraft manufacturing depends on a global supply chain and onshoring that entirely to any single country is neither realistic nor sensible. Airbus' A320 aircraft has 340,000 unique parts, each requiring years of certification. Airbus operates a final assembly line for its A320 and A220 jets in Mobile, Alabama, and has already said tariffs have hit assemblies imported to this operation.
French engine manufacturer Safran pointed out that CFM International — its joint venture with GE Aerospace — produces the LEAP engine, which exclusively powers Boeing's 737 MAX aircraft. Safran also supplies the low-pressure compressor module to GE Aerospace for its GEnx engine fitted to Boeing's 787 Dreamliner.
Boeing's alternative engine for the 787 is the Trent 1000 supplied by UK manufacturer Rolls-Royce, which commented that 60pc of aircraft with its engines are based in the US. It further highlighted the negative effect that tariffs have already had on maintenance, repair and overhaul operations, leading customers to delay repair work or seek unapproved alternatives.
Ti forgings characterise broader tariff risks
Aerospace parts often rely on unique metals, alloys, composites, forgings and castings that have specific properties, Boeing wrote. Machinery to manufacture these items is purpose-built and limited in capacity. Large structural forgings require unique forging presses capable of exceeding 30,000t hydraulic force, located in the US, Russia, China, France, Japan and Austria.
Austrian forger Voestalpine Bohler Aerospace underlined that transatlantic reciprocity extends from finished aircraft and engines down to approved raw materials such as titanium and nickel-based alloys.
"The industry cannot rapidly replace suppliers without creating significant cost overruns, supply chain bottlenecks, and safety risks," Voestalpine wrote.
Pennsylvania-based Perryman, a key producer of titanium ingot and mill products, said continued access to global suppliers and aerospace-grade raw materials is crucial to avoid disruptions to domestic manufacturing.
Perryman also argued that the interconnected nature of the titanium and aviation industries requires balanced trade solutions. The US relies solely on imports of titanium sponge, a necessary input for ingot melting, while also drawing approximately 50pc of its scrap needs from overseas.
