I’ve created a high level summary table which compares the rules applicable to each Class drone side by side. The parts in bold identify key differences I’ve spotted in the regulation. I’ve also mapped the Open Categories at the top of the table.
Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.
In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:
Weight / Dimension / Speed / Height
Controllability / Design / Power / Battery Alerting
Noise Emissions / Serial ID / Lighting
Remote ID
Geo-Awareness
System Intervention and Follow-Me
Data Link Failure Behaviour
User Manual and Box Content
Class Marking Symbol
The following symbol will be used to show this class of drone
Weight / Dimension / Speed / Height
The Maximum Take-Off Mass must be no more than 25kg.
There is no maximum size.
There is no maximum speed.
There is no maximum attainable height.
Controllability / Design / Power / Battery Alerting
The drone will need to be safely controllable and maneuverable by an RP following manufacturer instructions and under all anticipated operating conditions including failure of one or more systems.
There are not Design / Power / Battery Alerting requirements.
Noise Emissions / Serial ID / Lighting
There are no Emissions / Serial ID / Lighting requirements.
Remote ID
There are no Remote ID requirements.
Geo-Awareness
There are no Geo-Awareness requirements.
System Intervention and Follow-Me
There are no System Intervention or Follow-Me requirements however the aircraft must not have any automatic control modes except for flight stabilisation (with no direct effect on the trajectory) and lost link assistance.
Data Link Failure Behaviour
There are no Data Link Failure Behaviour requirements.
User Manual and Box Content
The User Manual shall clearly identify:
Class
Mass (with reference config) and MTOM
Allowed payloads (mass, dimensions, interfaces and restrictions)
Equipment and S/W to control UA Remotely
Behavior in case of loss of data link
Clear Operational instructions
Limitations (including meteorological, day/night)
Risks related to UAS operation
Maintenance instructions
Troubleshooting Procedures
The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.
Based on the above my interpretation is that these drones are more likely to be traditional uremote-controlled aircraft such as a fixed-wing Super Cub or Spitfire. However, it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.
Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.
In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:
Weight / Dimension / Speed / Height
Controllability / Design / Power / Battery Alerting
Noise Emissions / Serial ID / Lighting
Remote ID
Geo-Awareness
System Intervention and Follow-Me
Data Link Failure Behaviour
User Manual and Box Content
Class Marking Symbol
The following symbol will be used to show this class of drone
Weight / Dimension / Speed / Height
The Maximum Take-Off Mass must be no more than 25kg.
The maximum size specified is 3m.
There is no maximum speed.
The maximum attainable Height 120 m above the take-off point OR the height can be user selectable in relation to the TO point or surface of the earth but this must display data to RP about current height.
Controllability / Design / Power / Battery Alerting
The drone will need to be safely controllable in stability, maneuverability, and data link performance by an RP with competency (as per the Implemented Regulation) and under all anticipated operating conditions including failure of one or more systems.
The drone will need to be designed and constructed to minimise injury, minimising sharp edges and if equipped with propellers, limit injury that may be inflicted by them.
The drone must have the mechanical strength (incl. Safety Factor) and stability to withstand stress without breakage or deformation that might interfere with safe flight.
If tethered, the tensile length must be <50m and have the mechanical strength no less than 10x weight of aerodyne at max mass for heavier than air or 4x force exerted by maximum thrust and aerodynamic force of maximum allowed wind speed for lighter than air.
The drone will need to be powered by electricity with all voltages (Nominal, Accessible, Internal) <48V DC or AC Equiv. Internally this can be more if the voltage and the current combination has no risk and no harmful electric shock (even when damaged)
The drone must alert the RP when battery of Drone or Control station is low, this must give sufficient time to land.
Noise Emissions / Serial ID / Lighting
Unless fixed wing, it must have an A-weighted sound power level LWA (measured as per Part 13 of Delegated Regulation). There is not specified limit on the sound level. The sound power level indication shall be affixed (as per Part 14 of Delegated Regulation)
The drone shall have a serial number as per the standard - ANSI/CTA-2063 Small Unmanned Aerial Systems Serial Numbers
Lights wll need to be fitted for Controllability and Conspicuity at Night (person on ground should be able to distinguish UA from Manned). From the 1st July 2022 a green flashing light must be activated when flying at night.
Remote ID
The drone shall be equipped with Remote ID that allows upload of the UAS operator registration number.
The Remote ID shall work in realtime and with direct periodic broadcast (using open and documented protocol that can be received directly by existing mobile devices within range) the following:
the UAS operator registration number;
ANSI/CTA-2063 serial number
the geographical position and height above the surface or take-off point;
true course and ground speed
the geographical position of the remote pilot or, if not available, the take-off point;
It shall also prevent user from modifying last 4 bullets above.
There is no requirement for Remote ID if the drone is tethered.
Geo-Awareness
The drone shall have Geo-Awareness which shall be equipped with
an interface to load and update airspace limitation and altitude data imposed by geographical zones. Process of loading/updating must not degrade data integrity and validity
RP alerts when potential breach detected
Information to RP on UA status and alert when position/nav systems can’t ensure proper geo-awareness functionality
System Intervention and Follow-Me
Any function limiting access to certain airspace shall interact smoothly without affecting flight safety and this shall provide clear information to the RP when this is happening
Follow-me mode shall not exceed 50m and shall allow RP to regain control
Data Link Failure Behaviour
The drone shall have a reliable and predictable method for the UA to recover the data link or terminate flight in a way that reduces the effect on air and ground 3rd parties
Data link shall be protected against unauthorised access to command and control functions.
User Manual and Box Content
The User Manual shall clearly identify:
Class
Mass (with reference config) and MTOM
Allowed payloads (mass, dimensions, interfaces and restrictions)
Equipment and S/W to control UA Remotely
Behavior in case of loss of data link
Clear Operational instructions
Limitations (including meteorological, day/night)
Risks related to UAS operation
Transmission Protocol of Remote ID
Sound Power Level
Procedure to upload airspace limitation
Maintenance instructions
Troubleshooting Procedures
The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.
Based on the above my interpretation is that these drones are going to be professional grade drones, in today’s world this might be a DJI S1000 or Matrice. However it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.
DJI Matrice Series
Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.
Updated 9th June 2020: to reflect the clarification on how night time conspicuity lighting should be achieved.
In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:
Weight / Dimension / Speed / Height
Controllability / Design / Power / Battery Alerting
Noise Emissions / Serial ID / Lighting
Remote ID
Geo-Awareness
System Intervention and Follow-Me
Data Link Failure Behaviour
User Manual and Box Content
Class Marking Symbol
The following symbol will be used to show this class of drone
Weight / Dimension / Speed / Height
The Maximum Take-Off Mass must be no more than 4kg.
There is no maximum size specified for this type of drone.
There is no maximum speed but the drone must be fitted with a selectable low speed mode (unless fixed wing).
The maximum attainable Height 120 m above the take-off point OR the height can be user selectable in relation to the TO point or surface of the earth but this must display data to RP about current height.
Controllability / Design / Power / Battery Alerting
The drone will need to be safely controllable in stability, maneuverability, and data link performance by an RP with competency (as per the Implemented Regulation) and under all anticipated operating conditions including failure of one or more systems.
The drone will need to be designed and constructed to minimise injury, minimising sharp edges and if equipped with propellers, limit injury that may be inflicted by them.
The drone must have the mechanical strength (incl. Safety Factor) and stability to withstand stress without breakage or deformation that might interfere with safe flight.
If tethered, the tensile length must be <50m and have the mechanical strength no less than 10x weight of aerodyne at max mass for heavier than air or 4x force exerted by maximum thrust and aerodynamic force of maximum allowed wind speed for lighter than air.
The drone will need to be powered by electricity with all voltages (Nominal, Accessible, Internal) <48V DC or AC Equiv. Internally this can be more if the voltage and the current combination has no risk and no harmful electric shock (even when damaged)
The drone must alert the RP when battery of Drone or Control station is low, this must give sufficient time to land.
Noise Emissions / Serial ID / Lighting
Unless fixed wing, it must have an A-weighted sound power level LWA (measured as per Part 13 of Delegated Regulation). The level should be limited (as defined in Part 15 of Delegated Regulation - note this gets more stringent with time). The sound power level indication shall be affixed (as per Part 14 of Delegated Regulation)
The drone shall have a serial number as per the standard - ANSI/CTA-2063 Small Unmanned Aerial Systems Serial Numbers
Lights wll need to be fitted for Controllability and Conspicuity at Night (person on ground should be able to distinguish UA from Manned). From the 1st July 2022 a green flashing light must be activated when flying at night.
Remote ID
The drone shall be equipped with Remote ID that allows upload of the UAS operator registration number.
The Remote ID shall work in realtime and with direct periodic broadcast (using open and documented protocol that can be received directly by existing mobile devices within range) the following:
the UAS operator registration number;
ANSI/CTA-2063 serial number
the geographical position and height above the surface or take-off point;
true course and ground speed
the geographical position of the remote pilot or, if not available, the take-off point;
It shall also prevent user from modifying last 4 bullets above.
There is no requirement for Remote ID if the drone is tethered.
Geo-Awareness
The drone shall have Geo-Awareness which shall be equipped with
an interface to load and update airspace limitation and altitude data imposed by geographical zones. Process of loading/updating must not degrade data integrity and validity
RP alerts when potential breach detected
Information to RP on UA status and alert when position/nav systems can’t ensure proper geo-awareness functionality
System Intervention and Follow-Me
Any function limiting access to certain airspace shall interact smoothly without affecting flight safety and this shall provide clear information to the RP when this is happening
Follow-me mode shall not exceed 50m and shall allow RP to regain control
Data Link Failure Behaviour
The drone shall have a reliable and predictable method for the UA to recover the data link or terminate flight in a way that reduces the effect on air and ground 3rd parties
Data link shall be protected against unauthorised access to command and control functions.
User Manual and Box Content
The User Manual shall clearly identify:
Class
Mass (with reference config) and MTOM
Allowed payloads (mass, dimensions, interfaces and restrictions)
Equipment and S/W to control UA Remotely
Behavior in case of loss of data link
Clear Operational instructions
Limitations (including meteorological, day/night)
Risks related to UAS operation
Transmission Protocol of Remote ID
Sound Power Level
Procedure to upload airspace limitation
Maintenance instructions
Troubleshooting Procedures
The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.
Based on the above my interpretation is that these drones are going to be slightly bigger, in today’s world this might be a DJI Phantom. However it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.
DJI Phantom
Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.
Updated 9th June 2020: to reflect the clarification on how night time conspicuity lighting should be achieved.
In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:
Weight / Dimension / Speed / Height
Controllability / Design / Power / Battery Alerting
Noise Emissions / Serial ID / Lighting
Remote ID
Geo-Awareness
System Intervention and Follow-Me
Data Link Failure Behaviour
User Manual and Box Content
Class Marking Symbol
The following symbol will be used to show this class of drone
Weight / Dimension / Speed / Height
The Maximum Take-Off Mass must be no more than 900g unless is can be demonstrated that the drone transfers no more than 80J of energy when colliding with a human head a terminal velocity.
There is no maximum size specified for this type of drone.
The maximum speed allowed is 19 m/s (42 mph or 36 knots)
The maximum attainable Height 120 m above the take-off point OR the height can be user selectable in relation to the TO point or surface of the earth but this must display data to RP about current height.
Controllability / Design / Power / Battery Alerting
The drone will need to be safely controllable in stability, maneuverability, and data link performance by an RP following manufacturer instructions and under all anticipated operating conditions including failure of one or more systems.
The drone will need to be designed and constructed to minimise injury, minimising sharp edges and if equipped with propellers, limit injury that may be inflicted by them.
The drone must have the mechanical strength (incl. Safety Factor) and stability to withstand stress without breakage or deformation that might interfere with safe flight.
The drone will need to be powered by electricity with all voltages (Nominal, Accessible, Internal) <24V DC or AC Equiv. Internally this can be more if the voltage and the current combination has no risk and no harmful electric shock (even when damaged)
The drone must alert the RP when battery of Drone or Control station is low, this must give sufficient time to land.
Noise Emissions / Serial ID / Lighting
Unless fixed wing, it must have an A-weighted sound power level LWA (measured as per Part 13 of Delegated Regulation). The level should be limited (as defined in Part 15 of Delegated Regulation - note this gets more stringent with time). The sound power level indication shall be affixed (as per Part 14 of Delegated Regulation)
The drone shall have a serial number as per the standard - ANSI/CTA-2063 Small Unmanned Aerial Systems Serial Numbers
Lights wll need to be fitted for Controllability and Conspicuity at Night (person on ground should be able to distinguish UA from Manned). From the 1st July 2022 a green flashing light must be activated when flying at night.
Remote ID
The drone shall be equipped with Remote ID that allows upload of the UAS operator registration number.
The Remote ID shall work in realtime and with direct periodic broadcast (using open and documented protocol that can be received directly by existing mobile devices within range) the following:
the UAS operator registration number;
ANSI/CTA-2063 serial number
the geographical position and height above the surface or take-off point;
true course and ground speed
the geographical position of the remote pilot or, if not available, the take-off point;
It shall also prevent user from modifying last 4 bullets above.
Geo-Awareness
The drone shall have Geo-Awareness which shall be equipped with
an interface to load and update airspace limitation and altitude data imposed by geographical zones. Process of loading/updating must not degrade data integrity and validity
RP alerts when potential breach detected
Information to RP on UA status and alert when position/nav systems can’t ensure proper geo-awareness functionality
System Intervention and Follow-Me
Any function limiting access to certain airspace shall interact smoothly without affecting flight safety and this shall provide clear information to the RP when this is happening
Follow-me mode shall not exceed 50m and shall allow RP to regain control
Data Link Failure Behaviour
The drone shall have a reliable and predictable method for the UA to recover the data link or terminate flight in a way that reduces the effect on air and ground 3rd parties
User Manual and Box Content
The User Manual shall clearly identify:
Class
Mass (with reference config) and MTOM
Allowed payloads (mass, dimensions, interfaces and restrictions)
Equipment and S/W to control UA Remotely
Behavior in case of loss of data link
Clear Operational instructions
Limitations (including meteorological, day/night)
Risks related to UAS operation
Transmission Protocol of Remote ID
Sound Power Level
Procedure to upload airspace limitation
Maintenance instructions
Troubleshooting Procedures
The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.
Based on the above my interpretation is that these drones are going to be again fairly small, in today’s world this might be a Mavic Spark or Air. However it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.
DJI Spark
Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.
In order to maintain some consistency between classes I’m going to cover the following areas of the Delegated Regulation requirements for each class in the same order:
Weight / Dimension / Speed / Height
Controllability / Design / Power / Battery Alerting
Noise Emissions / Serial ID / Lighting
Remote ID
Geo-Awareness
System Intervention and Follow-Me
Data Link Failure Behaviour
User Manual and Box Content
Class Marking Symbol
The following symbol will be used to show this class of drone
Weight / Dimension / Speed / Height
The Maximum Take-Off Mass must be no more than 250g
There is no maximum size specified for this type of drone, but obviously the weight will limit this quite significantly.
The maximum speed allowed is 19 m/s (42 mph or 36 knots)
The maximum attainable Height 120 m above the take-off point
Controllability / Design / Power / Battery Alerting
The drone will need to be safely controllable in stability, maneuverability, and data link performance by an RP following manufacturer instructions and under all anticipated operating conditions including failure of one or more systems.
The drone will need to be designed and constructed to minimise injury, minimising sharp edges and if equipped with propellers, limit injury that may be inflicted by them.
The drone will need to be powered by electricity with all voltages (Nominal, Accessible, Internal) <24V DC or AC Equiv. Internally this can be more if the voltage and the current combination has no risk and no harmful electric shock (even when damaged)
There are no requirements for battery alerts, but that’s not to say it can’t be included. Many basic drones nowadays have this, even if it’s just a flashing light to say the power is low.
It should be noted that if the drone in this class is being sold a toy (as per regulation 2009/48/EC) then the requirements on Controllability, Design and Power do not apply. I’ve not read into why exactly, but I suspect the regulation for toys is more stringent in terms of ensuring safety to the user.
Noise Emissions / Serial ID / Lighting
There are no requirements specified for Noise, Unique Serial Identification, or Lighting in this category.
Remote ID
There are no requirements specified for Remote ID in this category
Geo-Awareness
There are no requirements specified for Geo-Awareness in this category
System Intervention and Follow-Me
There are no requirements specified for system intervention (i.e. auto control or intervention from the drone itself overriding the human input) in this category
Follow-me mode shall not exceed 50m and shall allow RP to regain control
Data Link Failure Behaviour
There are no requirements specified for data link failure behaviour in this category
User Manual and Box Content
The User Manual shall clearly identify:
Class
Mass (with reference config) and MTOM
Allowed payloads (mass, dimensions, interfaces and restrictions)
Equipment and S/W to control UA Remotely
Behavior in case of loss of data link
Clear Operational instructions
Limitations (including meteorological, day/night)
Risks related to UAS operations adapted for the age of the user
The box shall contain an EASA Info Notice detailing laws etc. applicable to the drone.
Based on the above my interpretation is that these drones are going to be quite small, low risk, in today’s world this would be anything ranging from a really simple toy through to a Hubsan x4 or something like a Spark or a Tello. However it’s important to know that drones placed on the market prior to these regulations can’t be claimed to fall into any of these Classes. They fall under a different set of rules that have been set up to cover the use of legacy drones.
DJI Tello
Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.
At this stage I haven’t covered everything in the IR (particularly the Specific and Certified sections) but it felt like a good time to go to the DR temporarily to understand the Classes of Drones that relate to the Open Category A1, A2 and A3 operations.
The delegated regulation does more than just define the classes of drones, it also sets the rules for:
production of Remote Identification add-ons in the market
UAS operators that have their principal place of business, are established or reside in a third country
supply chain obligations (including manufacturer, distributor, and importer)
For this post I’m going to give a very high-level overview of the drone classes, I’m pointing this out because there is so much more to the definition of a class than weight so please don’t think this is everything. I’ll have to cover each class in an individual post to cover everything. I’ll also cover the other aspects of the DR later. From 1st July 2022, all aircraft placed on the Market targetting the Open Category will need to comply with the DR. I’ve put a summary table together:
|
CO |
C1 |
C2 |
C3 |
C4 |
|
|
Maximum Take Off Mass (MTOM) including payload |
Less than 250g |
Less than 900g OR <80J energy transmitted to human head at terminal velocity |
Less than 4kg |
Less than 25kg |
Less than 25kg |
|
Maximum Dimensions |
Not Specified |
Not Specified |
Not Specified |
3 metres |
Not Specified |
|
Maximum Flight Speed |
Less than 19 m/s 42 mph 36 knots |
Less than 19 m/s 42 mph 36 knots |
No Max Speed Specified but there must be a Selectable Low Speed Mode to <3m/s (Unless fixed wing) |
No Max Speed Specified |
No Max Speed Specified |
|
Maximum Attainable Height |
120 m above take-off point |
120 m above take-off point OR Equipped with system that limits height above surface or take-off point to 120 m or value set by RP. If value set by RP clear height shall be provided to RP |
120 m above take-off point OR Equipped with system that limits height above surface or take-off point to 120 m or value set by RP. If value set by RP clear height shall be provided to RP |
120 m above take-off point OR Equipped with system that limits height above surface or take-off point to 120 m or value set by RP. If value set by RP clear height shall be provided to RP |
No Max Height Specified |
|
Lighting |
No Lighting Specified |
Lighting to support RP Controllability and Night Lights which should be distinguishable from Manned Aircraft. |
Lighting to support RP Controllability and Night Lights which should be distinguishable from Manned Aircraft. |
Lighting to support RP Controllability and Night Lights which should be distinguishable from Manned Aircraft. |
No Lighting Specified |
|
Remote ID |
Not Specified |
Yes |
Yes |
Yes |
Not Specified |
|
Geo-Awareness |
Not Specified |
Yes |
Yes |
Yes |
Not Specified |
|
Sound/Noise Restrictions |
Not Specified |
Yes |
Yes |
Yes |
Not Specified |
If I cross-reference back to my post on the Open Categories. A1 was about flying over people and allowed the use of C0 and C1 aircraft which as you can see are the lowest weighted aircraft and have a maximum speed thus reducing the potential kinetic energy of the drone to a safe level, so this mapping makes sense.
A2 was about flying close to people, this permitted the use of C2, now although this is a heavier aircraft don’t forget you’re not allowed to overfly people, just close to them horizontally and only when in low-speed mode. Hence the C2 aircraft must have a low-speed mode embedded.
A3 was about flying far from people, i.e. 150m from a congested area, this allows for C2, C3, and C4. C3 and C4 are considerably heavier and so it makes sense that these would only be allowed far from people. Also, the requirements on C4 are much less rigorous and are more akin to traditional model aircraft hence they are unlikely to have things like height, GPS, lighting, Geo-Awareness, etc.
It’s worth noting that any drones with high-risk operations can not be used in the open category and will be subject to certification this includes situations involving transporting people, dangerous goods, more than 3m in dimension and designed to operate over people or anything else that a risk assessment deems it necessary to seek certification.
One final point. The EC are proposing some additional classes (C5 and C6) I will review this proposal soon and update this as necessary.
Small Print: These posts are a summary only, include my personal interpretation and is not intended to be a replacement for reading the actual rules.
