Questions & Answer Webinar UAS Regulation (EU) Conformity Evaluation Process

Q.// Are all the Part 4709-00** available? 

prEN4709-002, prEN4709-003 and prEN4709-004 are already available at ASD STAN. prEN4709-001 hasn’t been published yet. The remaining parts, corresponding to the standard scenarios, are not published yet. 


Q.// What about CE marking? will it also become mandatory on 1/1/24? 

CE Marking is always mandatory for every product that is placed in the European Market. DR 2019/945 will be mandatory to place a product in the market after 01/01/2024. 


Q.// If we certify a drone, and then the Standards change, we must certify the drone again? 

Depending on the change, if the compliance of the equipment could be compromised, a reevaluation of the certification would be required.  


Q.// If you operate your own drones, do you have to pass CIL and CE?  

CE Marking is always mandatory for every product that is placed in the European Market. DR 2019/945 will be mandatory to place a product in the market after 01/01/2024. Privately built drones are exempt of DR 2019/945. 


Q.// Can you obtain a Class Identification Label if you don’t have CE marking?  

Yes, CIL is affixed by the manufacturer upon compliance with the DR 2019/945. CE Marking is the responsibility of the manufacturer. Using a Notified Body to analyze DR 2019/945 will result in an EU Type Exam Certificate, where the UAS could be marked with the CIL but doesn’t turn the UAS into a CE Marked product. 

Q.// Do manufacturers selling class-marked devices need to provide their customers with a class certification document? The reason for my question is that the document is not available by DJI for Mavic 3 Classic, but it is Mavic 3 retromarked. 

This is covered by the DoC (Declaration of Conformity) where the manufacturer states the regulations its system is compliant with. 


Q.// Is it mandatory that a CE conformity assessment is supervised by a conformity assessment body, or can the manufacturer make the tests and declaration himself? 

For a product to bear the CE marking, the product manufacturer must declare, under its sole responsibility, the product’s conformity with all the requirements laid down in the applicable Community Directives. In the case of DR 2019/945, a Notified Body is required for classes C1, C2 and C3. 


Q.// From an EMC point of view, are there product standards applicable to UAS, or would generic standards be used for testing? 

Generic standards are used, there are no specific EMC standards for UAS. 


Q.// The long-range operations of more than bvlos operations (for example 10 km from the pilot) are foreseen at any CE or in the regulation?? 

Yes, the operation would fall under the Specific Category, where an operational authorization will be probably required. 


Q.// Do you also provide consultation for certification in other continents? 

Notified Bodies don’t offer consultation. 


Q.// What if a part of the UAS change post certification? 

An evaluation will be needed to see if the system is still compliant with the regulation or if it needs additional testing to verify its compliance. 


Q.// Do the batteries of a drone need to be certified separately? 



Q.// How certification refers to different payloads on a drone – for example a drone can have a camera, gas detector etc. payloads with different sizes and purposes. does the certification need to be for the different payloads in addition to the drone, and if a new payload will come later then is it needed to be recertified as part of the drone regulation? 

The drone will be certified under the most critical conditions (usually those corresponding to MTOM). Also, if new payloads are introduced, a technical analysis shall be carried out by the notified body to assess if these changes imply any problems with the issued certification. 


Q.// In other words, the certification includes the payloads that the drone can carry, and no other payloads are part of the certified drone and can violate the certification of the drone? 

If any of the ‘other’ payloads puts the drone at risk when it comes to meeting the requirements laid down in DR2019/945, yes. This might be part of the re-certification assessment process of the notified body involved in the certification. 


Q.// So if I understand well, you cannot have a CE, without having a CIL? 

Yes. Some applicable directives set by the DR2019/945 are also shared with those directives for CE Marking (MD/RED….) 


Q.// In terms of what is mandatory, is having C label marking mandatory in 2024 or CE? Can we sell a drone that has a C label but not CE? 

CE Marked is always required to sell a product in the European market. DR 2019/945 is one of the regulations that UAVs need to be compliant with for the manufacturer to affix the CE Marking. The Class Label will be required if the UAV falls under one of the categories for which the UAV will fly. 


Q.// Do you need a notified body for CE? or you can do it on your own? 

You need to check if your product must be tested by a notified body. You can find this information in the relevant legislation applicable to your product: check the rules by product category. For the case of UAS, you currently need a NOTIFIED BODY except for the cases shown above in the images. 


Q.// Will we get the webinar recording? 

Yes, the recording is now available. Click the link below.