China Updates Commercial Space Regulation
"Notice on Strengthening the Quality Supervision and Management of Commercial Space Projects"
The China National Space Administration released its “Notice on Strengthening the Quality Supervision and Management of Commercial Space Projects” earlier today, updating laws around quality control, accountability, and requirements for the nation’s growing commercial space sector.
According to the notice, it was approved a few days ago on July 16th, then released publicly on July 21st.
Xinhua reports that the notice establishes comprehensive quality management standards covering multiple aspects, including quality management systems, research and production, ground testing, launch implementation, on-orbit operations, services, recovery and decommissioning, and product quality supervision. Officials from the China National Space Administration told Xinhua that the notice standardizes primary responsibilities across all these areas.
Notably, for commercial space projects with low technical maturity or high flight safety risks, such as first flights and return to flight missions, the notice requires additional investigation of major reliability hazards and mission risk assessments before launch vehicle delivery, with national space industry management departments authorized to organize independent assessments when necessary.
Since Space Pioneer’s Tianlong-3 incident in June 2024, there have been murmurs around new additions to China’s space regulations. Signs of the new regulation were hinted at in a lengthy post by Space Pioneer earlier this month, following a long silence.
At the moment, the China National Space Administration has only released the notice in Chinese. As such, I’ve prepared an unofficial translation of the notice and provided it below. Any errors present are my own, if you find any problems with this translation please reach out and correct me. If you are looking to reference any part of the transcript, please refer to the Chinese one posted by the China National Space Administration.
Notice on Quality Supervision and Management of Commercial Space Projects
To relevant departments (units) and commercial space enterprises:
In order to improve the quality level of commercial space projects, promote the standardization of commercial space quality management, and facilitate the orderly development of commercial space activities, in accordance with China's current policies and regulations related to space activities, the following matters regarding quality supervision and management of commercial space projects are hereby notified:
I. General Requirements
(1) This notice applies to the quality supervision and management of the entire life cycle activities of commercial space projects, including research and development, production, testing, launch, operation, services, recovery, and decommissioning.
Commercial space projects referred to in this notice are space projects that are not included in national and military research plans, do not use central government funds, follow market models, and are invested and implemented by local governments, enterprises, institutions, social organizations, and individuals or other legal persons or natural persons who bear the main responsibilities and risks. Other types of space projects may follow this notice as reference.
(2) The basic goal of quality supervision and management for commercial space projects is to establish a quality supervision and management system for commercial space projects involving industry regulatory departments, project contractors, project undertakers, and third-party professional institutions, improve the industry quality ecology, supervise and manage the formation, maintenance, restoration, and improvement processes of commercial space project quality, strictly control quality risks, and achieve expected objectives in accordance with relevant laws, regulations, and standards.
(3) Adhere to high-quality development requirements, pursue excellence and innovative development, establish the concept that quality equals efficiency, follow the principles of coordinated promotion, ecosystem improvement, orderly supervision, and continuous improvement, and continuously enhance the quality and efficiency of commercial space projects.
(4) Relevant national departments are responsible for guiding the quality supervision and management of commercial space projects, formulating relevant policies, standards, and specifications for quality supervision and management of commercial space projects, and improving the quality supervision and management system and mechanisms for commercial space projects.
Commercial space project undertakers are the main responsible parties for commercial space project quality, responsible for quality management and self-quality supervision of commercial space project activities throughout the entire life cycle.
Commercial space project contractors are the main stakeholders affected by commercial space project quality risks and may selectively plan and implement external quality supervision activities for commercial space project undertakers based on specific risk levels.
Third-party professional institutions are entrusted to undertake quality review, independent assessment, quality supervision, and supervision evaluation work for commercial space projects.
II. Quality Management Systems
(5) Commercial space project undertakers should establish and operate verifiable quality management systems based on their actual circumstances, implement effective quality management for their commercial space project activities throughout the entire life cycle, implement quality requirements in all aspects of commercial space projects, and achieve organic integration and continuous improvement of quality management and business operations.
(6) Quality management by commercial space project undertakers should follow the principle of capability enhancement and strict risk control, carry out quality infrastructure construction, establish quality information systems, strengthen process control, and ensure traceability of activities throughout the entire life cycle.
(7) Commercial space project undertakers should conduct quality management system planning based on actual circumstances, formulate quality policies and quality objectives, and develop implementation plans for quality management systems.
(8) Commercial space project undertakers should establish and improve commercial space business processes, clearly define their inputs, activities, outputs, resources, performance indicators, and other elements, ensure that all business processes are controlled, and ensure stable operation of the quality management system.
(9) Commercial space project undertakers should evaluate the effectiveness of their quality management systems and identify system improvement needs.
(10) Commercial space project undertakers should identify weak links in quality management based on commercial space project quality conditions, quality management system certification results, and other information, take effective measures to resolve them, and promote continuous improvement of quality management systems.
(11) Commercial space project undertakers are encouraged to open up quality work resources such as testing, inspection, evaluation, and certification, promote resource sharing, and achieve complementary advantages.
III. Research and Development and Production
(12) The task of quality management for commercial space project research and development and production is to ensure that commercial space product quality and service activities meet expected or specified requirements.
(13) Commercial space projects should clearly specify expected quality requirements, acceptance criteria and methods, and quality responsibilities through effective means as input and basic basis for commercial space project quality management.
(14) For commercial space projects involving subcontracting, the overall quality work is the responsibility of the general contractor, and subcontractors should be responsible for the quality of their undertaken tasks. General contractors should transfer or refine quality requirements item by item and clarify subcontractor quality responsibilities.
(15) Commercial space project research and development and production undertakers are encouraged to establish supporting institutional document systems and standard systems, formulate standard selection catalogs, actively implement industry-recognized standards, and ensure products and projects meet national and industry requirements.
(16) To ensure the quality of commercial space project research and development and production processes, project undertakers should carry out process quality management related work.
The research and development process should comprehensively implement quality management requirements, which can be achieved through technical configuration management, strengthening quality risk identification and control, arranging necessary process inspections, reviews, test verification, and evaluation confirmation activities to ensure that specified requirements are fully met.
The production process should strengthen quality control, which can be achieved through establishing product inspection systems, batch management systems, and product identification systems, implementing process flow control, and ensuring consistency and stability of product quality.
(17) Commercial space project research and development and production undertakers should establish factory evaluation rules and procedures based on relevant standards and clarify factory release criteria.
Commercial space project undertakers should review the quality work conditions and results of the research and development and production processes according to established rules, procedures, and release criteria before product factory delivery.
Products that do not meet factory release criteria requirements shall not be delivered from the factory.
For commercial space projects with low technical maturity and high flight safety risks such as first flights and return flights, before product factory delivery, major quality hazards should be further investigated and mission risks controlled based on the aforementioned review work. When necessary, relevant national space industry management departments may organize independent assessments.
(18) Commercial space project research and development and production undertakers are encouraged to establish failure reporting, analysis, and corrective action systems, conduct zero-defect work on failures and quality problems that occur during research and development and production processes, and promptly take corrective and preventive measures.
IV. Ground Testing
(19) The task of implementing quality management in commercial space project ground testing processes is to ensure that tests achieve their intended purposes and guarantee the safety of test personnel, products, facilities, equipment, and locations.
(20) Commercial space project undertakers should plan and implement quality management work for testing processes based on the potential risk levels of various ground tests to ensure that testing activities meet specified mission requirements and related safety production requirements. Zero-defect work should be conducted on quality problems that occur during testing processes. Tests conducted using military testing facilities should be organized according to relevant regulatory procedures.
V. Launch Implementation
(21) During the commercial space project launch implementation phase, launch site (mission) command organizations should uniformly organize and carry out quality management work according to quality system document requirements to ensure controlled product quality, safe launch processes, and achievement of expected mission objectives.
(22) Commercial space project undertakers should complete product research and development and production according to quality management requirements and relevant procedures, obtain civilian space launch project licenses according to requirements such as the "Interim Measures for the Management of Civilian Space Launch Project Licenses," "Notice on Promoting the Standardized and Orderly Development of Commercial Launch Vehicles," and "Notice on Promoting the Orderly Development of Microsatellites and Strengthening Safety Management," and then proceed to execute launch test activities according to procedures.
(23) Launch site (mission) command organizations should organize commercial space project undertakers to comprehensively implement quality management requirements, organize overall and technical document consistency reviews, carry out mission preparation and implementation work according to technical document requirements, and ensure that product functional performance meets indicator requirements. Commercial space project undertakers should review whether products meet release criteria requirements before major nodes such as product transfer, fueling, and launch. When necessary, independent assessments can be implemented by entrusted third-party professional institutions to provide a basis for launch site (mission) command organization decision-making.
(24) When quality problems occur with products during launch mission preparation processes, commercial space project undertakers should strictly conduct zero-defect work according to standards. For cases where zero-defect conditions are not available during launch mission preparation periods, clear conclusions that do not affect testing or launch flight should be formed (with problem zero-defect completion afterward) to provide a basis for launch site (mission) command organization decision-making. When quality problems occur with products during mission implementation processes that lead to launch failure, relevant national departments may guide commercial space project undertakers to complete zero-defect work as appropriate. Only after zero-defect conditions are recognized by national space industry management departments can testing or return flight work be reorganized.
VI. On-Orbit Operations, Services, Recovery, and Decommissioning
(25) The task of quality management for commercial space project on-orbit operations, services, recovery, and decommissioning processes is to ensure that on-orbit management and application services continuously meet requirements while achieving expected functional and performance requirements without safety accidents.
(26) Commercial space project on-orbit operation undertakers should implement quality responsibilities for on-orbit operation activities, establish operational standards, strengthen operational training, and implement effective management of on-orbit operation personnel and equipment to meet relevant requirements.
(27) Commercial space project service undertakers should clarify quality standards for the services they provide, establish standardized service processes, allocate service resources, optimize and continuously improve service capabilities, and ensure service quality.
(28) When commercial space projects complete predetermined missions and meet recovery conditions, the quality and safety of the recovery process should be ensured to prevent adverse effects on other on-orbit spacecraft, space environment, and ground safety.
(29) When commercial space project on-orbit operation products reach their service life, project undertakers should implement decommissioning by taking disposal measures such as deorbiting and passivation to meet national space debris mitigation policy requirements and related standards, ensuring the quality and safety of decommissioning and disposal processes. For cases where deorbiting and related information reporting requirements are not implemented, relevant national departments may take necessary measures as appropriate.
(30) Quality problems that occur during commercial space project on-orbit operations, recovery, and decommissioning activities should be promptly reported to relevant national departments, and corrective measures should be taken as required for resolution.
VII. Product Quality Supervision
(31) Product quality supervision for commercial space projects should adhere to the principles of independence, authority, effectiveness, standardization, and timeliness, with commercial space-related policies, regulations, standards, and specifications as basic basis.
(32) Product quality supervision for commercial space projects includes user supervision, undertaker self-supervision, and third-party supervision.
Product quality supervision for commercial space projects is mainly on-site quality supervision, which can be conducted through dispatching quality supervision representatives, quality supervisors, or other types of quality supervision personnel.
(33) Promote the establishment of commercial space project certification and evaluation mechanisms, conduct graded certification and evaluation based on different risk levels of various commercial space projects, and improve the effectiveness and efficiency of commercial space project quality management.
(34) Major quality problems and major safety hazards discovered during quality supervision should be promptly reported to relevant national departments, and necessary disposal measures should be taken.
VIII. Accident Investigation and Disposal
(35) When quality accidents occur in commercial space projects, undertakers should promptly report to local defense science and technology industry management departments, superior supervisory departments, and relevant national departments, and cooperate with regulatory departments to complete subsequent investigation and disposal work. Concealment, false reporting, or delayed reporting is not permitted.
(36) Investigations should be conducted on commercial space project accidents. Major accidents involving serious economic losses and safety should be investigated and organized by relevant national departments.
(37) Relevant national departments should classify accidents based on investigation results. Personnel directly responsible for causing accidents should be disciplined according to regulations; those who constitute crimes should be held criminally responsible according to law.
IX. Other Provisions
(38) Quality responsibility for commercial space project undertakers implements lifetime accountability.
When commercial space project undertakers cause major quality problems due to poor management or dereliction of duty; conceal, falsely report, or delay reporting commercial space project quality problems, causing serious consequences; engage in fraud in commercial space projects, concealing major design defects, manufacturing defects, quality problems, or safety hazards; provide counterfeit and inferior products in commercial space projects, using inferior products as superior ones or fake products as genuine ones; or provide false data or conclusions in commercial space projects, they shall be punished according to relevant laws and regulations.
Third-party professional institutions that maliciously collude with commercial space project undertakers, engage in fraud, forge supervision results, or issue false certifications shall be punished according to relevant laws and regulations.
(39) Quality management activities for commercial space classified business should comply with relevant requirements of national confidentiality regulations and shall not leak state secrets.