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Russia Files Complaint To ICAO Over International Sanctions


  • Sanctions against Russian aviation have had a significant impact, with major manufacturers cutting support and foreign lessors canceling leases.
  • Efforts to divest from Western suppliers have led to the development of Russified variants of aircraft models like the Sukhoi SuperJet 100 and the Irkut MC-21.
  • Some parts smuggling has occurred to keep Russian-operated aircraft flying, but it has not been sufficient, as evidenced by frequent breakdowns and reliance on domestic flights.
  • Russian complaint about sanctions’ impact on aviation safety has been submitted to ICAO.

The Russian Federation, seeking relief from sanctions in response to Russia’s unprovoked invasions of Ukraine, has contacted the United Nations’ aviation regulatory body, the International Civil Aviation Organization (ICAO), asking for ICAO relief.

Why sanctions against Russian aviation

In any discussion about sanctions against Russian aviation, one must remember why. On February 24, 2022, the Russian Federation began an unprovoked assault on Ukraine after eight years of warfare and occupation against disputed territories in Crimea and the Donbas. Russia’s choice of violence to resolve political problems has led to international condemnation.

In response, Airbus and Boeing cut Russian-operated aircraft from all product support, followed by Embraer. Therefore, Airbus, Boeing, and Embraer will not supply maintenance, parts, or technical support to keep their aircraft operational.

Sanctions’ cumulative impacts on Russian aviation

After 20 months of sanctions on Russian aviation, the aviation sanctions have had their impact. For instance, as Simple Flying suggested in March 2022, based on manufacturer documentation, sanctions impacted the Sukhoi SuperJet 100 (aka SSJ100) program. Notably a Russified SJ-100 variant is being developed, with a first flight in September.

The Irkut MC-21 is also being Russified. These efforts at divesting from Western suppliers have led to Rostec receiving orders for 18 MC-21s and 34 SJ-100s.

Leases and dual registration

Additionally, one of the first sanctions against Russian aviation has been the cancellation by European lessors of leases to Russian airlines in response to sanctions that started on March 28, 2022. Russia did respond by allowing Russian airlines to dual-register aircraft, with one registration being Russian. Back in March 2022, analytics firm Cirium found that out of 980 commercial aircraft in Russia, 515 were leased from foreign leasing companies.

Read our ongoing coverage of leasing.

Dual registration, however, is against ICAO rules. Namely, Article 18 of the 1944 Convention on International Civil Aviation (aka the Chicago Convention) states, “an aircraft cannot be validly registered in more than one state.”

Ural Airlines, RA-73843, Airbus A321-231 at Domodedovo Airport (UUDD/DME)

Moreover,, non-Russian airlines have been caught up in these sanctions. Qatar Airways happened to use a Russian leasing firm with an Irish adjunct to lease two Airbus A330ceos. Now, Qatar Airways has two A330ceos parked indefinitely.

Some smuggling of parts is happening, but insufficient

However, there have been efforts to the tune of over $1.2 billion in smuggled Airbus & Boeing parts between February 2022 and September 2023 to keep Russian-operated aircraft flying. The smuggling is enabled by nations like Tajikistan, the United Arab Emirates (UAE), Turkey, China, and Kyrgyzstan, which do not recognize sanctions against Russian aggression.

shutterstock_2333442343 - Moscow, Sheremetyevo International Airport, Russia - Jul 05, 2023: Airbus A350-900 B308-T China Southern Airlines landing at Sheremetyevo International Airport in front of Boeing 747-8f

Photo: Telsek | Shutterstock

The aircraft parts smuggled to Russia range widely from electronic devices, cabin pressure valves, cockpit displays, landing gear, and telephone headsets to toilet seats. Such is Russian dependency on Western aviation supply.

shutterstock_2369946087 - Moscow, Russia - 12 September 2023: Boeing 777-300ER RA-73150 Aeroflot Russian airlines taking off from Sheremetyevo airport.

Photo: imfaydez | Shutterstock

Nonetheless, according to an October 2 Moscow Times report, three Aeroflot aircraft broke down in one day. One was damage to the landing gear of a Boeing 777. Another was due to an engine fire. The third had an unspecified breakage.

The Moscow Times also reports;

Of the 817 foreign aircraft owned by Russian airlines as of April 2022, at least 72 (9%) have already experienced at least one breakdown, which was repaired by uncertified services using spare parts of unknown origin. One source of parts could be the “cannibalization” of aircraft. By January 2023, 25–30% of the fleet was dismantled for spare parts.

Hence, the Russian efforts to persevere have come to a breaking point. Additionally, as the Kyiv Independent reports, the Carnegie Endowment has found that domestic flights accounted for 90% of all routes flown by Russian airlines in 2022 versus 2019 57%.

Russian complaint to ICAO

As such, the Russian Foreign Ministry has submitted a statement to ICAO about the cumulative impact of the sanctions. According to the Russian News Agency TASS, the Russian Foreign Ministry said,

“The basis for initiating the proceedings was the defendants’ use of unlawful unilateral restrictive measures of discriminatory nature in relation to Russia and its aviation enterprises. In particular, we are referring to a ban on the use of airspace by aircraft of Russian air carriers, a ban on the supply of aircraft and spare parts for them, a ban on maintenance and provision of aircraft insurance services, detention of aircraft abroad, and restrictions on access to meteorological information for air navigation.”

TASS shared the Russian Foreign Ministry’s conclusion that the cumulative sanctions are a threat to aviation safety. The ministry said,

“By their actions, the defendant states have jeopardized the safety of international civil aviation flights and seriously undermined mutual trust, which has been the basis of the international aviation system for almost 80 years.”

Bottom line

It is as if Russians believe ICAO should permit Russians to enjoy civil aviation with full Western leasing and technical support. In contrast, Ukrainian aviation has lost that “mutual trust” to the point that Ukrainian civil aviation has been paused, and third parties like Qatar Airways have been harmed.

According to AviationSource Newqa on May 15, Oleksiy Dubrevskyy, Boryspil International Airport (KBP)’s general director, shared with the Routes Europen2023 Conference that Kyiv’s main airport, among other Ukrainian civil airports, has been closed since February 24, 2022, due to Russia’s War on Ukraine.

IrAero, RA-89078, Sukhoi Superjet 100-95LR on final against blue sky and clouds at Domodedovo Airport (UUDD/DME)

Altogether, ICAO has plenty to consider amid this complaint.

Do you support sanctions against Russian aviation? Please share in the comments.

Sources: AviationSource, Kyiv Independent, Moscow Times, TASS


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