Material Selection and Flammability Considerations for EWIS Compliance under CS-23 and CS-25
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Sofema Online (SOL) considers key requirements related to Aircraft Material Selection & Flammability Requirements
Introduction
Material selection for Electrical Wiring Interconnection Systems (EWIS) is fundamental to the design and continued airworthiness of both small and large aircraft.
The responsibility lies with the Design Organisation to validate and justify every EWIS material based on functional, environmental, and flammability performance.
This commitment ensures the long-term safety, maintainability, and certifiability of aircraft electrical systems throughout the aircraft lifecycle.
Under the modernized CS-23 (performance-based) and the prescriptive CS-25, compliance requirements related to flammability, durability, environmental protection, and electromagnetic compatibility (EMC) demand careful engineering judgment, backed by robust testing and documentation.
Regulatory Foundations
CS-23 (Small Aircraft) – Performance-Based Approach
With Amendment 5, EASA restructured CS-23 to eliminate many prescriptive design rules, including the former CS 23.1359 (Electrical System Fire Protection) and CS 23.1365 (Electrical Wiring Protection).
Instead, these requirements are now addressed under high-level objectives, such as:
>> CS 23.2510 – Equipment, Systems, and Installations
“The equipment, systems, and installations must be designed and installed to ensure they function as intended under any foreseeable operating condition.”
This includes wiring systems and their resilience to fire, overheating, electromagnetic interference, and mechanical/environmental damage.
Compliance is achieved through adherence to industry standards (e.g., AS50881, FAA AC 23-17C, CS 23.2500) and by leveraging CS-25 guidance where appropriate.
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Key Design Considerations Enabled by AS50881 AS50881 provides detailed tables and guidance for:
This is critical in CS-23/25 compliance, where wire characteristics must support system loads, environmental conditions, and longevity (especially under fatigue or vibration loads in CS-23 commuter aircraft and all CS-25 aircraft).
Updated Clarification – CS-23 and System Safety (Post-2017 Amendment) The traditional CS 23.1309, which mirrored FAA 14 CFR 23.1309, has been removed from CS-23 following the 2017 EASA reorganization of the Certification Specifications for Normal Category Aircraft (now titled: “Normal, Utility, Aerobatic, and Commuter Aeroplanes”).
Current and Applicable Structure – CS-23 Amendment 5 and Onwards As of Amendment 5 (20 July 2017) and subsequent amendments, EASA restructured CS-23 into a performance-based and objective-driven standard. The prescriptive requirements like 23.1309 were removed and replaced with broader safety objectives. Key Replacement Objective:
CS 23.2500 – Safety “The aircraft must be designed so that systems and equipment, considered separately and in relation to other systems, perform their intended function throughout the operating life of the aircraft, without causing unacceptable risk to the aircraft or its occupants.”
This is now the primary safety-driven objective covering what was formerly detailed under CS 23.1309 (system safety assessments, failure classification, etc.).
How AS50881 Supports Compliance with CS-23 Post-Amendment AS50881 remains highly relevant, but it now supports compliance with performance-based objectives rather than prescriptive rules.
AS50881 helps demonstrate:
For CS-25 Aircraft – CS 25.1309 Remains Valid & To avoid confusion:
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CS-25 (Large Aeroplanes) – Prescriptive Requirements
CS-25 remains more detailed and includes a dedicated Subpart H – EWIS, encompassing:
>> CS 25.869 – Fire protection of electrical components
>> CS 25.1701–25.1733 – Full scope of EWIS design, protection, installation, inspection, bonding, and flammability compliance
>> Appendix F to CS-25 – Flammability testing requirements for materials including wiring insulation
These rules mandate material-specific performance validation and apply to both new type designs and major design changes.
Core EWIS Material Selection Criteria
Flammability Resistance
Materials must:
>> Self-extinguish and not propagate flame
>> Limit smoke and toxic gas emission
>> Resist arc tracking, burn-through, and flame spread
>> Pass tests under Appendix F, Part I(a)(3) (12-second vertical burn test for wire insulation)
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Applicability to CS-23 Aircraft After the 2017 performance-based rewrite of CS-23:
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This is especially important for high-power circuits and areas with fire exposure risk.
Environmental and Chemical Resistance
Materials must be:
>> Resistant to hydraulic fluids, fuels, oils, and cleaning agents
>> Able to operate across a wide temperature range (−55°C to +200°C, depending on application)
>> Resilient against moisture, UV, ozone, and corrosive atmospheres
Qualification data must reflect installation zones—e.g., pressurized cabin, unpressurized bays, or near engines.
Mechanical and Physical Performance
Designers must ensure that materials:
>> Maintain flexibility and tensile strength throughout their service life
>> Are abrasion-resistant and do not suffer cold flow or brittle cracking
>> Tolerate vibration, bending, and repeated movement
Harnesses must be protected with clamps, grommets, and wear-resistant coverings at penetration and interface points.
- d) Electromagnetic Compatibility (EMC)
Material properties affect:
>> Shielding attenuation against EMI and HIRF (High-Intensity Radiated Fields)
>> Grounding and bonding effectiveness
>> Crosstalk prevention in signal and power wire bundles
EMC requirements are particularly critical in digital fly-by-wire and avionics-intensive aircraft.
- e) Aging and Long-Term Durability
Long-term performance must be proven through:
>> Accelerated aging tests and historical service experience
>> Evaluation of insulation breakdown, thermal degradation, and chemical interaction
>> Resistance to UV exposure, thermal cycling, and humidity ingress
Certification and Compliance Responsibilities
Design Organisations approved under Part 21 Subpart J must:
>> Define material specifications in the Type Design, referencing qualified materials (e.g., AS22759 for wiring)
>> Include flammability qualification reports in the EWIS Compliance Plan (especially for CS-25)
>> Apply Design Risk Assessment (DRA) and Functional Hazard Assessment (FHA) methods to identify and mitigate EWIS-specific risks
>> Incorporate guidance from AMC 20-21 regarding wiring installation, protection, and separation
>> Align CS-23 performance objectives with CS-25 best practices for flammability and fire resistance where prescriptive rules are lacking
Common EWIS Material Compliance Pitfalls
>> Substituting non-qualified components (e.g., automotive or consumer-grade wiring)
>> Failing to verify batch-to-batch flammability consistency
>> Overlooking installation environment limitations (temperature or chemical exposure)
>> Using outdated or unsupported material test data
>> Inadequate documentation of wiring insulation specifications or EMI testing results
Best Practices
To achieve and sustain EWIS compliance:
>> Adopt aerospace-qualified materials (e.g., AS22759, MIL-W-5088 equivalents)
>> Work with suppliers who provide EASA Form 1 or FAA 8130-3 traceability
>> Use digital harness design and routing software to simulate clearances, thermal loads, and separation
>> Retain flammability and material compliance documentation in the compliance archive
Link material performance data with safety reporting and continuous improvement loops
Next Steps
For EWIS Classroom, Webinar or online training please see www.sasssofia.com and www.sofemaonline.com or email team@sassofia.com

