The European Union Aviation Safety Agency (EASA) defines “unmanned aircraft systems (UAS)” as drones, their systems, and controlling equipment. Such products are subject to specific regulations such as Regulation (EU) 2019/945 on Unmanned Aircraft Systems. Drones are also subject to regulations relevant to machinery, electronics, and batteries.
Non-compliant drones may pose a danger to humans and property. For example, a defective drone could suddenly stop functioning and crash. Drones can also interfere other radio equipment.
In this guide, we focus on the product compliance requirements for drones, not on the operations requirements such as the minimum age for remote pilots. Note that you can find more information on the EASA’s page dedicated to Drone Regulatory Systems.
Content Overview
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Regulation (EU) 2019/945 on Unmanned Aircraft Systems
This regulation establishes design, manufacturing, and operations requirements for Unmanned Aircraft Systems, or UAS.
Importers and manufacturers must also comply with the following aspects of the regulation:
- Documentation requirements
- Labelling requirements
- Lab testing requirements
- Certification requirements (if applicable)
Classification
The regulation categorises UAS into the “open,” “specific”, and “certified” categories. Further, it also classifies UAS operated under the “open” category into seven classes.
While the three UAS categories establish the types of compliance procedures the UAS should undergo, the UAS classes set requirements (e.g. labelling) that are specific to the type of drone.
Categories
Per Article 2 of the regulation, there are three categories of unmanned aircraft systems – the “open” category, “specific” category, and “certified” category. The different categories are defined in Articles 4, 5, and 6 of Regulation (EU) 2019/947, which we cover in the next section of this guide.
The definitions of the different categories are complex and include parameters such as take-off mass, whether the UAV is designed to transport dangerous goods and many others. When it comes to the requirements set by this regulation, it is important to understand that:
a. Chapter II covers conditions and rules for UAS operated under the “open” category, and the “specific” category
b. Chapter III covers certification requirements for UAS operated under the “certified” and “specific” categories (except when they are conducted under a declaration).
Classes
UAS operated under the “open” category are further classified into seven classes, according to their technical and operational requirements, such as maximum take off mass and ground speed.
Each class of UAS has different technical and labelling requirements, as set out in the Annex of the regulation. Here we list the different classes and one example of requirements for each class:
- C0 UAS: maximum take-off mass (MTOM) of less than 250 g
- C1 UAS: MTOM of less than 900 g
- C2 UAS: MTOM of less than 4 kg
- C3 UAS: MTOM of less than 25 kg
- C4 UAS: MTOM of less than 25 kg
- C5 UAS: Maximum ground speed of 5 m/s
- C6 UAS: Ground speed of 50 m/s
Note that UAS of all classes should be equipped with a “geo-awareness” function that sends a warning alert to the remote pilot in the case a breach of airspace limitations set by a member state is detected.
Standards
We could only find one standard harmonised under the UAS Regulation, namely EN 4709-002 – Aerospace series – Unmanned Aircraft Systems – Part 002: Direct Remote identification.
The CENELEC website also lists seven standards that are under approval and should be harmonised under the regulation:
FprEN 4709-001 – Aerospace series – Unmanned Aircraft Systems – Part 001: Product requirements and verification
FprEN 4709-003 – Aerospace series – Unmanned Aircraft Systems – Part 003: Geo-awareness requirements
FprEN 4709-004 – Aerospace series – Unmanned Aircraft Systems – Part 004: Lighting requirements
FprEN 4709-005 – Aerospace series – Unmanned Aircraft Systems – Part 005: Verification method for the geocaging function
FprEN 4709-006 – Aerospace series – Unmanned Aircraft Systems – Part 006: Means to terminate flight, requirements, and verification
prEN 4709-007 – Aerospace series – Unmanned Aircraft Systems – Part 007: General product requirements for UAS of classes C5 and C6
prEN 4709-008 – Aerospace series – Unmanned Aircraft Systems – Part 008: C5 Accessories kits
Documentation
The regulation requires you to provide several pieces of documentation for UAS covered by the requirements set in Chapter II, that is for UAS in the “open” category and “specific” category.
| Title | Description |
| Declaration of Conformity | The Declaration of Conformity is a mandatory document for unmanned aircraft systems covered by Chapter II and should contain the items listed in Part 11 or Part 12 of the Annex. |
| Technical documentation | You should provide technical documentation, which should contain the items listed in Part 10 of the Annex, such as test reports and instructions. |
| Instructions | You should ensure that you include the following types of instructions with the drone product:
|
| Test report | As specified in Part 10 of the Annex, the regulation requires you to provide test reports as part of your technical documentation. |
Labelling requirements
Here we list the key labelling requirements set by the regulation. Note that most of the requirements (e.g. CE marking) only applies to products that are covered by the requirements set by Chapter II. A serial number is required also for products that are covered by the requirements set by Chapter III.
| Title | Description |
| CE marking | 
Products that are subject to the requirements of Chapter II need to bear the CE marking. You should permanently and clearly affix the CE marking to the product, its data plate, or its packaging. If a conformity assessment procedure that requires a notified body was carried out, you should include the notified body’s identification number after the CE marking. |
| Traceability information | You should indicate the following traceability information on the product, its packaging, or an accompanying document:
|
| Identification label | You should ensure the UAS bears a UA class identification label, which should be:
Parts 1 through 5 of the regulation’s Annex provide the label requirements for the different classes of UAS. |
| Serial number | UAS should carry a unique serial number that complies with the standard ANSI/CTA-2063-A-2019 – Small Unmanned Aerial Systems Serial Numbers |
Certification
According to Chapter III, UAVs that meet any of the following conditions should undergo certification:
a. It has a dimension of at least 3 meters and is designed for operation over assembled people
b. It is designed for transporting humans, or
c. It is designed for transporting dangerous goods and requires a high level of third-party risk mitigation
d. It is designed to be used in the “specific” category of operations as set in Article 5 of Regulation (EU) 2019/947
The regulation mandates that UAS subject to certification comply with relevant requirements established in the following regulations:
a. Regulation (EU) 748/2012 laying down implementing rules for the airworthiness and environmental certification of aircraft and related products, parts and appliances
b. Regulation (EU) 2015/640 on additional airworthiness specifications for a given type of operations
c. Regulation (EU) 1321/2014 on the continuing airworthiness of aircraft and aeronautical products, parts and appliances
In this guide, we do not go into details of these regulations. Note that you also find more information concerning the certification procedure on the “Certification of products and organisations” guidance page of the EASA’s website.
Regulation (EU) 2019/947 on the rules and procedures for the operation of unmanned aircraft
This regulation sets requirements for UAS and personnel (e.g. organisations and remote pilots) involved in operating UAS.
The requirements include the following:
- Operational limits and conditions
- Minimum age
- Airworthiness
- Cross-border operations
- Registration and certification
- Safety
Note that the regulation also requires compliance with the safety requirements set out in Regulation (EU) 2019/945. We do not explain the details of this regulation, as in this guide we focus on product safety requirements, not operations.
Regulation (EU) 2018/1139 on common rules in the field of civil aviation
This regulation sets common rules in the field of civil aviation for aircraft, its parts, and control equipment, as well as safety-related equipment for use at aerodromes. It also applies to unmanned aircraft, its personnel, and remote pilots, as well as its:
- Engines
- Propellers
- Parts
- Non-installed equipment
- Remote control equipment
According to the EASA website, the regulation applies to all drones. Specifically, unmanned aircraft and their operators are subject to certification, registration, and marking requirements.
Essential requirements
The regulation requires the design, production, maintenance, and operation of unmanned aircraft to comply with the essential requirements set out in Annex IX.
Here are several examples of the requirements:
a. The unmanned aircraft should be designed and constructed to function, be operated, maintained, and adjusted as intended without harming anyone.
b. The unmanned aircraft should, by default, have the capability to respect the environment and the safety, privacy, security, and protection of personal data protocols.
c. The production, marketing, or maintenance organisations should provide clear information regarding the following of the unmanned aircraft:
- Safe operation
- Operational performance
- Airworthiness limitations
- Emergency operations
Certification
Unmanned aircraft, as well as personnel involved in operating such products, may require certification regarding how they are designed, produced, maintained, and operated.
The regulations claim that certification requirements are set according to the delegated acts mentioned in Article 58 and the implementing acts mentioned in Article 57. Thus, it does not specify what types of drones require certification. Although we were not able to find any delegated or implementing acts, it is possible that some of such acts already exist.
A certificate:
a. Is issued to the applicant when they can prove the compliance of their unmanned aircraft
b. May be altered to add or remove conditions, limitations, and privileges
c. May be limited, suspended, or revoked when the holder of the certificate does not comply with the relevant requirements
Marking
Section 4 of Annex IX of the regulation requires unmanned aircraft to be properly marked and identified. That said, the regulation does not explain how you should mark an unmanned aircraft.
Article 57 states that the European Commission should implement acts that specify how unmanned aircraft should be marked.
Registration
Section 4 of Annex IX states that unmanned aircraft should undergo registration. It also states that unmanned aircraft operators should be registered if they operate unmanned aircraft that:
- Transfer more than 80 Joules of kinetic energy to a human upon impact
- Pose privacy, security, personal data protection, or environmental risks
- Are subject to certification requirements
Toy Safety Directive
The Toy Safety Directive applies to children’s toys. The EASA claims that drones are regarded as toys when children may be attracted to them. It also specifies that, in case of doubt, market surveillance authorities would assess a product to determine if it is a toy based on characteristics regarding how attractive a child may find it, how accessible is the product to kids and more.
As such, you may need to comply with the Toy Safety Directive if you think that your drone has characteristics that may attract children, even if you think your drone is not a children’s toy. If you sell a non-compliant drone that the authorities decide to classify as a toy, you may face fines or even product bans and recalls.
Products covered by the Toy Safety Directive should:
- Comply with harmonised standards (e.g. EN 71-1)
- Not pose chemical, physical or other harm to children
- Undergo testing
- Be accompanied by documentation (e.g. declaration of conformity, instructions)
- Bear proper labelling (e.g. CE marking, traceability information, warnings)
Machinery Regulation
The Machinery Regulation defines machinery as an assembly that is fitted with a drive system comprising moveable and linked components or parts that are joined together for a specific purpose.
According to Regulation (EU) 2019/945 on Unmanned Aircraft Systems, drones that are not toys should adhere to the applicable health and safety requirements established in the Machinery Directive. This requirement only applies to risks not related to the safety of unmanned aircraft flight.
Here, we focus on the key requirements of the Machinery Regulation, as it is due to replace the Machinery Directive. The regulation requires covered products to:
- Comply with relevant harmonised standards and technical specifications
- Bear proper labelling (e.g. CE marking, traceability, warnings)
- Be accompanied by documentation (e.g. instructions, declaration of conformity)
Batteries Regulation
The Batteries Regulation establishes safety and environmental requirements for batteries and waste batteries sold in the EU. It covers many types of batteries, including those that are relevant to drones, such as portable batteries. Here are some types of portable batteries:
- Nickel cadmium (NiCad) batteries
- Lithium polymer (LiPo) batteries
- Lithium-ion (Li-ion) batteries
The regulation sets several requirements, including the following:
a. Substance restrictions (e.g. for lead, cadmium, and mercury)
b. Compliance with harmonised standards
c. Labelling (e.g. CE marking, traceability information, separate collection symbol)
d. Documentation (e.g. instructions, declaration of conformity)
e. Compliance with EPR requirements
National regulations for drones
Some EU member states have their own country-specific regulations regarding drones. Here we list several examples of such regulations:
a. France – Order of 3 December 2020 Respecting the Use of Airspace by Unmanned Aircraft on Board
b. Germany – Civil Aviation Act (Luftverkehrsgesetz)
c. Spain – Royal Decree 517/2024 of 4 June, which regulates the civil use of unmanned aircraft systems (UAS)
Lab testing
You should have your drones or unmanned aircraft systems undergo testing to prove they are safe to use and comply with relevant directives, regulations, and standards.
If your products pass the relevant tests, you receive a test report containing evidence that your products adhere to regulatory requirements. While some regulations such as the Toy Safety Directive mandate you to test your products and produce a test report, for others you should still have tests done as a matter of practical safety (e.g. not containing substances above permitted levels).
| Regulation | Lab testing |
| Regulation (EU) 2019/945 on Unmanned Aircraft Systems | You should have your drones undergo testing to ensure factors such as the following comply with the regulation:
|
| Toy Safety Directive | The Toy Safety Directive requires covered products to undergo tests such as the following:
|
| Machinery Regulation | The Machinery Regulation requires you to provide a test report as part of your documentation. As such, you have to test your product to determine if it complies with the relevant mechanical, health, and safety requirements. |
| Batteries Regulation | The Batteries Regulation requires you to have your products tested to ensure the substances in the batteries do not exceed established restrictions.
You should also have your batteries undergo testing such as:
|
Drone testing companies
Here are several companies that claim to test drones to the regulations:
- TÜV Rheinland
- TÜV SÜD
- Alter
- SGS
- UL Solutions
Additional Requirements
You should also consider complying with regulations such as those in the table below, as they may have requirements that are relevant to drones.
| Regulation | Description |
| RoHS Directive | The RoHS Directive sets substance restrictions for electric and electrical components and products. |
| EMC Directive | The EMC Directive sets requirements for the electromagnetic compatibility of electronic and electric equipment.
This is relevant to drones because such products may interfere with the radio signals of larger and more critical infrastructure equipment, or be affected by the same. |
| Radio Equipment Directive | The Radio Equipment Directive applies to products that have capabilities such as Bluetooth, Wifi, and GPS. However, the directive exempts unmanned aircraft that are certified under Article 56 of Regulation (EU) 2018/1139 on common rules in the field of civil aviation |
| Low Voltage Directive | The Low Voltage Directive’s requirements cover electrical devices with input or output voltages that fall between 50 – 1,000 V for alternating current (AC), and 75 – 1,500 V for direct current (DC).
While most UAVs may have a voltage that is lower than 50 V, this directive would apply to their charger, for example. |
| General Product Safety Regulation | The General Product Safety Regulation covers product safety aspects that are not already covered by other regulations. The regulation generally requires that products undergo safety testing before being sold. |
| REACH | The REACH Regulation sets restrictions on dangerous substances used in articles. The regulation is relevant to drones because drones may contain restricted substances such as phthalates, lead, and more. |
Recommended articles
- EU Restriction of Hazardous Substances Directive (RoHS): An Essential Guide
- Electromagnetic Compatibility (EMC) Directive: An Essential Guide
- Radio Equipment Directive (RED): An Essential Guide
- Low Voltage Directive (LVD): An Essential Guide
- General Product Safety Regulation (GPSR): An Essential Guide
- An Essential Guide to the REACH Regulation in the EU
