The global composite repair market is projected at USD 16.39 billion in 2026 and USD 22.82 billion by 2031, growing at a CAGR of 6.85%, according to Mordor Intelligence’s January 2026 market report. Carbon-fibre Reinforced Polymer commands 54.69% of that market share. The Boeing 787 Dreamliner and Airbus A350 XWB incorporate composite materials for over 50% of their structural weight. Early CFRP structures are reaching their 15-year inspection thresholds, and the MRO industry is executing composite repairs at scale for the first time.
The problem is that most Part 145 quality systems were built for metallic structure maintenance. Aviathrust Aviation News stated clearly in its December 2025 analysis: „Applying metal repair practices to composite structures may be inappropriate and risk the repair outcome.“ The GAO made the same point in its assessment of FAA composite oversight: experts expressed concern that while composite training is available to technicians, they may lack incentives to pursue it. That concern has not gone away in the years since.
The FAA updated Advisory Circular 20-107B in 2024, shortening structural-repair approvals by one-third — releasing deferred maintenance budgets and giving operators a faster route to keep high-value assets in service. More repairs, faster approvals, and an industry workforce built primarily on metallic maintenance experience: that is the quality risk environment for 2026.
1. Why CFRP Repair Is Structurally Different from Metallic Maintenance
Damage Characterization
In metallic structures, damage is visible or measurable with standard NDT methods calibrated for the material. In CFRP, impact damage can delaminate internal plies while leaving the surface essentially intact. The MRO industry standard for initial damage assessment — visual inspection and basic surface scanning — is insufficient for composite primary structure. EASA’s 2025 standards now mandate NDT for all primary-structure composite repairs, closing a gap in the previous regulatory text and raising entry barriers for repair stations that have not invested in the required NDT capability.
For quality managers auditing MRO suppliers, the specific question is whether the NDT equipment is present, calibrated, and operated by technicians qualified to the specific technique and material being inspected. A repair station with composite repair scope on their Part 145 capability list but no calibrated ultrasonic C-scan equipment and no qualified Level II NDT technician for composite inspection is operating a paper capability, not a real one.
Material Shelf Life and Storage Compliance
Prepreg repair materials — the carbon fiber/resin systems used for structural CFRP repairs — have defined out-time limits at room temperature and storage temperature requirements when frozen. Material that has been exposed slightly beyond its out-time limit may appear normal at layup. The consequences appear later: incomplete cross-linking that produces lower-than-specified interlaminar shear strength, or elevated void content detectable only by destructive testing or advanced NDT. A repair executed correctly in all other respects, but using material outside its process window, does not meet the approved repair data.
For Part 145 quality systems, the minimum traceable record for composite repair materials is: lot number, received date, frozen storage records with temperature log, cumulative out-time, and confirmation that out-time was within limits at the time of layup. DAS — a Part 145 structural MRO specialist — has identified material traceability as a primary documentation requirement in structural repair record packages. In practice, these records are often incomplete or reconstructed from memory after the repair rather than documented in real time during the operation.
Cure Cycle Validation and Documentation
Hotbonder cure cycles for composite repairs require thermocouple placement on the repair area, controlled temperature ramp rates, specific dwell temperatures and times, and vacuum bag integrity throughout the cure. The cure cycle chart — the printed or electronic record of temperature versus time — is a mandatory deliverable for composite repairs to primary structure. It is the primary objective evidence that the thermal process was executed within the approved data requirements.
In practice, cure cycle records are missing from a significant proportion of composite repair packages. In some cases the hotbonder data was not downloaded before the equipment was reset for the next job. In other cases the record was generated but not associated with the aircraft maintenance record. Either failure leaves the maintenance organization without the primary objective evidence that the repair conformed to approved data — which means the basis for the release-to-service entry is incomplete.
2. The Audit Question That Is Rarely Asked
When a Part 145 organization is audited for composite repair capability, the typical scope covers certification scope, tooling calibration, and training records. DAS’s structural repair guidance explicitly frames the requirement in terms of documentation and audit-ready records supporting compliant execution — not just procedure existence. The audit questions that reveal actual process compliance:
Show me the damage characterization record — the NDT output that defined the damage extent — for the last composite repair to primary structure your organization executed. Show me the material lot traceability record confirming the prepreg was within out-time limits at layup. Show me the cure cycle chart for that repair. Show me how that cure cycle chart is linked to the aircraft maintenance record.
If any of those records cannot be produced for a recent repair, the audit has identified a systemic documentation gap. The cure cycle either conformed to the approved data or it did not. Without the record, neither the maintenance organization nor the regulator can verify which outcome occurred.
3 Concrete Actions
1. If you are qualifying or re-qualifying a Part 145 MRO supplier that performs composite repairs to primary structure, add material traceability and cure cycle record review to your audit agenda as non-negotiable items. Request records for three recent composite repairs to primary structure. The records should be retrievable within minutes from the repair package file — not reconstructed from memory or assembled from multiple systems.
2. For Part 145 organizations executing composite repairs: review your procedure for cure cycle data download and retention. The most common failure mode is procedural — the process for downloading hotbonder data and associating it with the aircraft record is absent or not consistently followed. A one-page procedure with a specific step for data download and record linking, verified by a supervisor sign-off, addresses the majority of the gap.
3. For airline quality managers reviewing MRO supplier qualification: verify that your supplier’s composite repair scope under their Part 145 approval is supported by actual NDT capability and competency on-site. The 2024 FAA AC 20-107B update and EASA’s 2025 NDT mandate for primary-structure repairs are raising the baseline. A qualification audit that does not verify NDT capability at the technique-and-material level is not assessing the process that matters most.
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Sources
- Mordor Intelligence — Composite Repair Market Size, Growth, Trends and Share Report 2025-2031 (January 2026), mordorintelligence.com
- Aviathrust Aviation News — Building a World-Class Composite Repair Workshop for EASA Part-145 Organizations (December 7, 2025), aviathrust.com
- DAS (Diverse Aero Solutions) — Aircraft Composite Repair Guide for Decision Makers (April 2026), diverseaero.com
- DAS — Structural Repair Traceability in Part 145 Repair Stations, diverseaero.com
- FAA Advisory Circular AC 43-214A — Repairs and Alterations to Composite and Bonded Aircraft Structure
- FAA Advisory Circular AC 20-107B (Updated 2024) — Composite Aircraft Structure
- GAO-11-849 — Aviation Safety: Status of FAA’s Actions to Oversee the Safety of Composite Airplanes
- Fortune Business Insights — Aircraft Component MRO Market Size, Share, Growth to 2034 (2026), fortunebusinessinsights.com
- Stratview Research — Aircraft MRO Market Size and Trend Industry Analysis 2025-2035, stratviewresearch.com
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