Timothy Pinto

Senior Counsel

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Timothy Pinto

Senior Counsel

Read More

2 September 2019

Drone SAFETY! EU manufacturing requirements

This is the fourth article in our five part series covering UK and EU drone regulation. You can read Part 1 (introduction) here, Part 2 (UK regulation) here, Part 3 (EU regulation introduction) here and Part 5 (EU requirements) here.

The EU Regulations classify drones as categories C0, C1, C2, C3 or C4 according to their weight or the amount of energy released on impact. There are various manufacturing requirements including around labelling, maximum speeds, sound levels, lighting and safety features for each category. In short, drones will be tightly regulated.

Open category – manufacturing requirements

Drones in the open category must be designed and manufactured in accordance with specific rules. For example, drones which weigh less than 250g (class C0) must for example:

  • bear the class identification label:
  • have a maximum speed of 19 m/s
  • have a maximum height of 120m
  • be safely controllable following the manufacturer's instructions
  • be designed and constructed to minimise injury to people
  • if equipped with a 'follow-me' mode and when this is on, be in a range not more than 50m from the pilot
  • come with a user manual detailing specific information.

The next class up of open category drones (C1) must weigh less than 900g or where, in the event of an impact at terminal velocity with a human head, less than 80 J of energy is transmitted to the head. Either way, such a drone falling out of the sky onto someone's head would be likely to cause a serious injury or possibly kill them. In addition to the requirements for class C0 drones, C1 drones must, for example:

  • bear the class identification label:
  • in the case of a loss of data link, have a reliable and predictable method for the drone to recover the link or terminate the flight in a way which reduces the effect on third parties
  • have a certain guaranteed maximum sound level, an indication of which is affixed to the drone and/or its packaging
  • have a unique and specified serial number
  • provide the pilot with a clear warning when a battery is low
  • have lights to assist in the controllability and conspicuity of the drone at night.

Further, C1 drones must have a direct remote identification that allows the upload of the drone operator's registration number, and be capable of broadcasting, in real time during the flight, data that includes:

  • the drone operator's registration number
  • the unique drone serial number
  • the geographic position of the drone and the pilot
  • the route course.

Finally, C1 drones must be equipped with a geo-awareness system that provides:

  • an interface to upload data on airspace limitations
  • a warning to the pilot when a potential breach of airspace limitations is detected
  • a warning to the pilot when the drone's systems cannot ensure the proper functioning of the geo-awareness system.

As the drones in the classes get heavier and more capable, the safety requirements generally increase. The other open category classes are:

  • C2 – drones weighing less than 4kg which must bear the label:
  • C3 – drones weighing less than 25kg with a maximum characteristic dimension of less than 3m which must bear the label:
  • C4 – drones weighing less than 25kg which must bear the label:

Manufacturers must, amongst many other things, put their name and email and postal address on the drone or its packaging and, when appropriate, keep a register of non-conforming products and product recalls. There are also obligations on importers and distributors.

Next time: PART 5 – EU requirements for flying drones

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Drone SAFETY! EU requirements for flying drones

9 September 2019

by Timothy Pinto

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