Drone classes C0 to C6: which EASA label for which drone
C0 to C6 are the seven EU drone classes defined in the Annex to Delegated Regulation (EU) 2019/945: C0 under 250 g, C1 under 900 g (or under 80 J on impact), C2 under 4 kg, C3 and C4 under 25 kg, plus C5 and C6 for the Specific-category standard scenarios STS-01 and STS-02. The class identification label is a product mark chosen and declared by the manufacturer; Implementing Regulation (EU) 2019/947 then uses it to decide where and how the drone may be flown. This page sets out what each Part of the Annex actually requires, which conformity assessment route each class may use, the only harmonised standard cited so far, the dates that matter, and the readings the texts contradict.
TL;DR:
- The Annex numbering is Part 1 = C0, Part 2 = C1, Part 3 = C2, Part 4 = C3, Part 5 = C4, Part 6 = direct remote identification add-on, Part 16 = C5, Part 17 = C6.
- Module A (self-declaration) is open to C0, C4, C5, C6 and the remote ID add-on, provided the cited harmonised standards are applied; C1, C2 and C3 need a notified body (Modules B and C, or H).
- Direct Remote ID: C1, C2, C3, C5, C6. Geo-awareness: mandatory for C1, C2, C3, optional for C5 and C6. Neither for C0 or C4.
- One harmonised standard is cited under 2019/945: EN 4709-002:2023 (direct remote identification), since 1 August 2024, with a restriction on reception by existing mobile devices.
Two regulations, two responsibilities
Section titled “Two regulations, two responsibilities”Delegated Regulation (EU) 2019/945 was published in OJ L 152 of 11 June 2019 and entered into force twenty days later. It is a product regulation built on the New Legislative Framework model: manufacturers, authorised representatives, importers and distributors, CE marking, notified bodies. Its Chapter II covers drones intended for the Open category or for operational declarations in the Specific category (class-marked UAS, C5 accessories kits and remote identification add-ons); Chapter III (Article 40) covers drones that need certification; Chapter IV covers third-country operators. It does not apply to UAS intended to be operated exclusively indoors (Article 2(4)).
Implementing Regulation (EU) 2019/947 was published the same day and applies from 31 December 2020 (Article 23(1), as amended by Regulation (EU) 2020/746). It addresses operators and remote pilots: the three categories, registration, competency, operational authorisations and declarations.
| Regulation | Addressed to | Subject | Document produced |
|---|---|---|---|
| (EU) 2019/945 | Manufacturer, importer, distributor | Requirements per class (Annex Parts 1 to 6, 16, 17), conformity assessment, CE marking and class label | EU declaration of conformity, technical documentation |
| (EU) 2019/947 | UAS operator, remote pilot | Open / Specific / Certified categories, competency, registration | Registration, proof of competency, declaration or operational authorisation |
The two texts meet in the operator duties. Under UAS.OPEN.050(6), an operator flying a class-marked drone in the Open category must ensure it is accompanied by the EU declaration of conformity referring to its class and that the class label is affixed. UAS.STS-01.030 and UAS.STS-02.030 impose the same check for C5 and C6.
For the neighbouring regimes, see the CE pillar and the RED pillar: the radio directive applies to the command and control link, the video link and the Remote ID transmitter.
What are the seven drone classes C0 to C6?
Section titled “What are the seven drone classes C0 to C6?”Summary table
Section titled “Summary table”| Class (Annex Part) | Mass and size | Speed | Remote ID | Geo-awareness | Other distinctive requirements |
|---|---|---|---|---|---|
| C0 (Part 1) | MTOM < 250 g including payload | max 19 m/s in level flight | Not required | Not required | height limited to 120 m above take-off point; electric only; follow-me within 50 m |
| C1 (Part 2) | MTOM < 900 g, or < 80 J transmitted to a human head at terminal velocity | max 19 m/s in level flight | Yes (point 12) | Yes (point 13) | height limit or selectable limiter; guaranteed sound power level (Part 15); green flashing light; ANSI/CTA-2063-A serial number |
| C2 (Part 3) | MTOM < 4 kg | low-speed mode ≤ 3 m/s unless fixed-wing | Yes (point 14) | Yes (point 15) | C2 link protected against unauthorised access; tether < 50 m if tethered; sound limits (Part 15) |
| C3 (Part 4) | MTOM < 25 kg, characteristic dimension < 3 m | no speed cap | Yes, unless tethered (point 9) | Yes (point 10) | sound power level indicated (not capped); C2 link protection unless tethered |
| C4 (Part 5) | MTOM < 25 kg | no speed cap | Not required | Not required | no automatic control modes except flight stabilisation assistance and lost-link assistance |
| C5 (Part 16) | Part 4 limits (< 25 kg, < 3 m) | low-speed mode ≤ 5 m/s unless tethered | Yes (via Part 4) | Only if fitted | not fixed-wing unless tethered; flight termination means that reduces the impact dynamics; C2 link quality monitoring |
| C6 (Part 17) | Part 4 limits (< 25 kg, < 3 m) | max 50 m/s ground speed in level flight | Yes (via Part 4) | Only if fitted | programmable operational volume containment; independent flight termination; programmable trajectory; electric-only rule of Part 4 lifted |
Part 1 sets an MTOM below 250 g including payload, a maximum speed in level flight of 19 m/s, a maximum attainable height of 120 m above the take-off point, exclusively electric power, and a follow-me range not exceeding 50 m. It also requires the EASA information notice and manufacturer instructions adapted to the age of the user. There is no Remote ID, no geo-awareness and no lighting requirement.
When the C0 is also a toy within the meaning of Directive 2009/48/EC, points 4, 5 and 6 of Part 1 (controllability, injury minimisation, electric power) do not apply under point 10, the toy directive covers those risks, and Module H is not available (Article 13(2)(c)). For a C0 that is not a toy, Article 4(2) sends non-flight risks to the machinery legislation (see below).
Part 2 offers two alternatives for the first criterion: an MTOM below 900 g, or materials and characteristics such that the energy transmitted to a human head in an impact at terminal velocity is less than 80 J. The level-flight speed is capped at 19 m/s. On top of C0, C1 adds mechanical strength, a predictable behaviour on loss of the command and control link, a guaranteed sound power level (non fixed-wing), direct Remote ID, geo-awareness, a low-battery warning, lights for controllability and at least one green flashing light so the drone can be distinguished from a manned aircraft at night, and a unique serial number compliant with ANSI/CTA-2063-A-2019.
Part 3 sets an MTOM below 4 kg. A non fixed-wing C2 must offer a low-speed mode selectable by the remote pilot that limits ground speed to no more than 3 m/s; that mode is what lets the A2 pilot reduce the 30 m distance to uninvolved persons down to 5 m (UAS.OPEN.030(1)). Unless tethered, the command and control link must be protected against unauthorised access. A tethered C2 must have a tether shorter than 50 m with the mechanical strength set in point 5.
Part 4 sets an MTOM below 25 kg and a maximum characteristic dimension below 3 m. There is no speed limit and no low-speed mode. Direct Remote ID is required unless tethered, geo-awareness is required, and the guaranteed sound power level is indicated on the drone or packaging but Part 15 sets no maximum for C3. C3 drones fly in subcategory A3, at least 150 m from residential, commercial, industrial or recreational areas (UAS.OPEN.040(2)).
Part 5 is short: MTOM below 25 kg, safe controllability, and no automatic control modes except flight stabilisation assistance with no direct effect on the trajectory and lost-link assistance with a pre-determined fixed position of the flight controls. No Remote ID, no geo-awareness, no lights. This is the class for traditional radio-controlled model aircraft placed on the market.
Part 16 makes a C5 comply with Part 4 except point 2 (height limiter) and point 10 (geo-awareness, which applies only if fitted). It adds: no fixed-wing unless tethered; clear height information to the remote pilot; a low-speed mode of not more than 5 m/s unless tethered; a means to terminate the flight that is reliable, predictable and independent from the automatic flight control and guidance system, forces the descent, prevents powered horizontal displacement and includes means to reduce the effect of the impact dynamics; and continuous monitoring of the C2 link with alerts before and at loss. A parachute is one possible way to meet the impact-dynamics point; the text does not name one.
Point 8 allows a C5 to be a C3 fitted with a C5 accessories kit. The kit must not change the C3 software or alter its compliance with Part 4, must be installable by the UAS operator following the kit manufacturer instructions, and must come with the list of the C3 models it fits. The C5 label goes on every accessory.
Part 17 makes a C6 comply with Part 4 except points 2 (height limiter), 7 (exclusively electric power) and 10 (geo-awareness, again only if fitted). It adds a ground speed in level flight of not more than 50 m/s; position, speed and height information to the remote pilot; means to prevent the aircraft from breaching the horizontal and vertical limits of a programmable operational volume; a flight termination means independent both from the automatic flight control and from that containment function; a means to programme the trajectory; and C2 link monitoring. The manufacturer instructions must give the contingency volume needed and the distance most likely to be travelled after flight termination, which the operator uses to size the STS-02 ground risk buffer. There is no C6 accessories kit.
Per-requirement cross-reference
Section titled “Per-requirement cross-reference”For engineers who build a test plan, here is where each recurring requirement sits in the Annex.
| Requirement | C0 | C1 | C2 | C3 | C4 | C5 | C6 |
|---|---|---|---|---|---|---|---|
| MTOM limit | Part 1(1) | Part 2(1) | Part 3(1) | Part 4(1) | Part 5(1) | via Part 4(1) | via Part 4(1) |
| Speed limit or low-speed mode | Part 1(2) | Part 2(2) | Part 3(9) | none | none | Part 16(4) | Part 17(1) |
| Height limit 120 m | Part 1(3) | Part 2(3) | Part 3(2) | Part 4(2) | none | excluded, height info Part 16(3) | excluded, info Part 17(3) |
| Exclusively electric | Part 1(6) | Part 2(10) | Part 3(12) | Part 4(7) | none | via Part 4(7) | excluded |
| ANSI/CTA-2063-A serial number | none | Part 2(11) | Part 3(13) | Part 4(8) | none | via Part 4(8) | via Part 4(8) |
| Direct Remote ID | none | Part 2(12) | Part 3(14) | Part 4(9) | none | via Part 4(9) | via Part 4(9) |
| Geo-awareness | none | Part 2(13) | Part 3(15) | Part 4(10) | none | if fitted, Part 16(2) | if fitted, Part 17(2) |
| Flight termination | none | none | none | none | none | Part 16(5) | Part 17(5) |
| Sound power level | none | limit, Parts 13 to 15 | limit, Parts 13 to 15 | indication only | none | indication via Part 4(6) | indication via Part 4(6) |
2019/947 operating categories and product classes
Section titled “2019/947 operating categories and product classes”Open category
Section titled “Open category”Article 4 of Regulation 2019/947 limits the Open category to drones that belong to a class, are privately built, or meet Article 20; with an MTOM below 25 kg; kept in VLOS; within 120 m of the surface; without dangerous goods or dropping material.
| Subcategory | Main operational limit | Class-marked drones | Without class label | Remote pilot competency |
|---|---|---|---|---|
| A1 | C0 and the unclassified cases may overfly uninvolved persons but never assemblies; with a C1, the pilot must reasonably expect that no uninvolved person is overflown | C0; C1 with active and updated Remote ID and geo-awareness | privately built < 250 g and < 19 m/s (UAS.OPEN.020(5)(a)); placed on the market before 1 January 2024 and < 250 g (Article 20(a)) | C0 and unclassified: familiarity with manufacturer instructions; C1: online training and 40-question online exam, 75% pass mark |
| A2 | no overflight of uninvolved persons, at least 30 m from them, down to 5 m with active low-speed mode | C2 with active and updated Remote ID and geo-awareness | not admissible | certificate of remote pilot competency: A1/A3 exam, self-practical training, additional exam of at least 30 questions |
| A3 | no uninvolved person endangered; at least 150 m from residential, commercial, industrial or recreational areas | C2, C3 (with Remote ID and geo-awareness), C4 | privately built < 25 kg (UAS.OPEN.040(4)(a)); placed on the market before 1 January 2024 and < 25 kg (Article 20(b)) | online training and 40-question online exam |
The online competency and the A2 certificate are valid for five years (UAS.OPEN.070). At night, the green flashing light must be on (UAS.OPEN.060(2)(g), applicable since 1 July 2022 under Article 23(3)).
Specific category
Section titled “Specific category”Article 5 of Regulation 2019/947 gives three routes:
- Operational authorisation under Article 12, after a risk assessment under Article 11. The JARUS SORA methodology is the reference method used for that assessment. The drone need not carry any class label, but Article 40(3) of 2019/945 requires it to have the technical capabilities set in the authorisation, and Article 40(5) requires a remote identification system for any Specific operation below 120 m.
- Declaration against a standard scenario of Appendix 1 (Article 5(5), applicable from 1 January 2024): STS-01 requires a C5, STS-02 requires a C6, each operated with active and updated direct Remote ID. National standard scenarios accepted until 31 December 2023 under Article 23(4) ceased to be valid on 1 January 2026.
- Light UAS operator certificate (LUC) under Article 5(4)(b) and Part C of the Annex: an approval of the operator, whose privileges under UAS.LUC.060 can remove the need for an authorisation or declaration (Article 5(6)(a)). It is not a scenario.
| Standard scenario | Flight | Ground area | Class | Main numerical limits |
|---|---|---|---|---|
| STS-01 | VLOS at all times | controlled ground area in a populated environment | C5 | < 5 m/s ground speed if untethered; contingency area at least 10 m; ground risk buffer from 10 m to 60 m depending on height and on MTOM up to or above 10 kg; operational volume no more than 30 m above the 120 m limit |
| STS-02 | BVLOS, VLOS at launch and recovery | controlled ground area entirely in a sparsely populated environment | C6 with active containment system | flight visibility > 5 km; without observers, within 1 km of the remote pilot on a pre-programmed trajectory; with observers, within 2 km of the pilot and 1 km of the nearest observer, observers within 1 km of the pilot |
Both scenarios require a certificate of theoretical knowledge for standard scenarios (valid five years) and an accreditation of the scenario practical skill training.
Certified category
Section titled “Certified category”Article 6 of Regulation 2019/947 classifies an operation as Certified when the UAS is certified under Article 40(1)(a), (b) or (c) of 2019/945 and the operation is over assemblies of people, transports people, or carries dangerous goods that may result in high risk for third parties, or when the authority decides the risk cannot be mitigated otherwise. Article 3(c) then requires certification of the UAS and of the operator and, where applicable, licensing of the remote pilot; it does not refer to an AOC. Delegated Regulation (EU) 2024/1108, applicable from 1 May 2025, rewrote Article 40: certified UAS now follow Regulation (EU) No 748/2012, Regulation (EU) 2015/640 and Delegated Regulation (EU) 2024/1107, lighter-than-air drones are carved out of the 3 m over-assemblies trigger, and research or experimental UAS in very limited numbers fly under a permit to fly. No C0 to C6 class applies here.
Marking and documentation
Section titled “Marking and documentation”CE marking and class label
Section titled “CE marking and class label”The CE marking follows Article 30 of Regulation (EC) No 765/2008 (Article 15). Under Article 16, the class identification label is affixed visibly, legibly and indelibly to the UA, or to each accessory of a C5 kit, and to the packaging, at least 5 mm high, before placing on the market. The notified body number follows the CE marking only when Module H (Part 9) is applied (Article 16(5)). C1, C2, C3, C5 and C6 non fixed-wing drones also carry the guaranteed sound power level indication of Part 14.
Other Union acts stack on top where they apply, in a single EU declaration of conformity (Article 14(4)): the radio equipment directive for the radio functions, RoHS 2011/65/EU, and the toy directive for a toy C0. For non-flight risks of a drone that is not a toy, Article 4(2) points to Directive 2006/42/EC; from 20 January 2027 that directive is repealed and references to it are construed as references to Machinery Regulation (EU) 2023/1230 (Article 51(2) of that regulation).
Technical documentation (Article 17 and Part 10)
Section titled “Technical documentation (Article 17 and Part 10)”Part 10 lists the minimum content: a complete description of the product (photographs, versions of software or firmware involved in compliance, instructions), design and manufacturing drawings with explanations, the list of harmonised standards applied (in full or in part) or the alternative solutions used, a copy of the EU declaration of conformity, the EU type-examination certificate where Part 8 was used, design calculations, test reports, documents sent to the notified body, supporting evidence for the design solution, and the addresses of places of manufacture and storage. The manufacturer keeps the documentation and the declaration for 10 years after the product has been placed on the market (Article 6(3)). Manufacturers and importers of C5 or C6 drones or C5 kits must also inform the market surveillance authority of the Member State of their principal place of business (Articles 6(11) and 8(10)). See EU Declaration of Conformity for the template logic.
Harmonised standards
Section titled “Harmonised standards”As of this update, the Commission list for Regulation 2019/945 contains a single reference: EN 4709-002 (EN 4709-002:2023, direct remote identification), published by Commission Implementing Decision (EU) 2024/2103 in the OJEU of 1 August 2024. It is cited with a restriction: it gives no presumption of conformity with Part 2(12)(b), Part 3(14)(b), Part 4(9)(b) and Part 6(3), the requirement that the broadcast can be received directly by existing mobile devices within the broadcasting range. Other parts of the EN 4709 series, such as EN 4709-001, confer no presumption of conformity until their references are cited.
Conformity assessment modules (Article 13)
Section titled “Conformity assessment modules (Article 13)”Article 13(2) designates the procedures; Parts 7 to 9 of the Annex describe them. There are three:
| Procedure | Annex Part | Notified body | Restriction |
|---|---|---|---|
| Internal production control, Module A | Part 7 | No | only for Parts 1, 5, 6, 16 or 17, and only if the cited harmonised standards are applied for all requirements they cover |
| EU-type examination (Module B) followed by conformity to type based on internal production control (Module C) | Part 8 | Yes, for the type examination | none |
| Full quality assurance, Module H | Part 9 | Yes | not for a product that is a toy under Directive 2009/48/EC |
| Product | Available procedures |
|---|---|
| C0 (Part 1) | A, or B + C, or H (no H for a toy) |
| C1, C2, C3 (Parts 2 to 4) | B + C, or H |
| C4 (Part 5) | A, or B + C, or H |
| Remote ID add-on (Part 6) | A, or B + C, or H |
| C5, C6 and C5 kit (Parts 16 and 17) | A, or B + C, or H |
Since 1 August 2024 a harmonised standard exists for direct remote identification, so the Module A condition of Article 13(2)(a) now bites on products carrying that function (the add-on, C5 and C6): the cited standard has to be applied for the requirements it covers, and the restricted reception point needs its own evidence. There is no Module D, E or F in this regulation. See Self-declaration vs notified body for the general logic.
Which classes require Remote ID and geo-awareness?
Section titled “Which classes require Remote ID and geo-awareness?”Direct Remote ID
Section titled “Direct Remote ID”Article 3(31) defines direct remote identification as a system that ensures the local broadcast of information about a UA in operation, including its marking, without physical access to it. For C1, C2 and C3 the requirement has the same structure (Part 2 point 12, Part 3 point 14, Part 4 point 9; Part 6 for the add-on):
- upload of the UAS operator registration number, with a consistency check and an error message if the string is inconsistent;
- a direct periodic broadcast from the UA, in real time for the whole flight, using an open and documented transmission protocol, receivable directly by existing mobile devices within the broadcasting range;
- broadcast content: operator registration number and verification code; unique serial number of the UA (ANSI/CTA-2063-A); time stamp, position and height above the surface or take-off point; route course from true north and ground speed; position of the remote pilot or, if not available, the take-off point; emergency status (the add-on list in Part 6 stops at the pilot position);
- measures that reduce the ability to tamper with the function.
The regulation names no radio technology and no range. If the drone also has network remote identification, C1, C2 and C3 must transmit the same data set over the network.
Geo-awareness
Section titled “Geo-awareness”Article 3(32) defines geo-awareness as a function that, based on data provided by Member States, detects a potential breach of airspace limitations and alerts the remote pilot. Parts 2 to 4 require an interface to load and update UAS geographical zone data (Article 15 of 2019/947) without degrading its integrity, a warning on a potential breach, and a status warning when positioning cannot support the function. Geo-awareness alerts; it does not have to block. If a drone does have a function limiting access to airspace volumes, it must interact smoothly with the flight control and tell the pilot when it prevents entry. The C6 containment of Part 17(4) is a different requirement: it keeps the aircraft inside its programmed operational volume.
Software updates
Section titled “Software updates”Article 4(3) allows updates of software on products already on the market only if they do not affect compliance. Article 6(4) requires series production to take changes in design, characteristics or software into account, and Part 10 requires the documentation to identify the software or firmware versions involved in compliance. Any update touching Remote ID, geo-awareness, speed modes or flight termination therefore needs a documented compliance check before release.
Key dates
Section titled “Key dates”| Date | Event | Source |
|---|---|---|
| 1 July 2019 | 2019/945 and 2019/947 enter into force (20 days after OJ L 152 of 11 June 2019) | Article 42 of 2019/945, Article 23 of 2019/947 |
| 9 August 2020 | Classes C5 and C6, C5 kits and new Parts 16 and 17 in force | Delegated Regulation (EU) 2020/1058 |
| 31 December 2020 | 2019/947 applies | Article 23(1) of 2019/947 |
| 16 July 2021 | Article 4(1) to (4) of Regulation (EU) 2019/1020 (EU-based responsible person) applies to drones | Article 5(3) of 2019/945 |
| 1 July 2022 | Green flashing light at night (Open) required | Article 23(3) of 2019/947 |
| 31 December 2023 | End of the Article 22 transitional period for drones not compliant with Parts 1 to 5 | Article 22 of 2019/947 |
| 1 January 2024 | Standard scenario declarations (STS-01, STS-02) apply; unclassified drones placed on the market from this date lose the Article 20 route | Articles 20 and 23(2) of 2019/947 |
| 1 August 2024 | EN 4709-002:2023 cited with restriction | Implementing Decision (EU) 2024/2103 |
| 1 May 2025 | Amended Article 40 and CMU terminology apply | Delegated Regulation (EU) 2024/1108 |
| 1 August 2025 | RED Article 3(3)(d)(e)(f) cybersecurity requirements apply to the radio equipment in scope | Delegated Regulation (EU) 2022/30 |
| 1 January 2026 | Declarations under national standard scenarios cease to be valid | Article 23(4) of 2019/947 |
| 20 January 2027 | Machinery Regulation (EU) 2023/1230 replaces Directive 2006/42/EC in the Article 4(2) reference | Article 51(2) of 2023/1230 |
EU and United States comparison
Section titled “EU and United States comparison”| Element | European Union | United States (FAA) |
|---|---|---|
| Product framework | (EU) 2019/945: classes C0 to C6, CE marking, notified bodies | No class system; Part 107 subpart D lets a manufacturer submit a declaration of compliance for Category 2 or 3 operations over people, and Part 89 sets producer requirements for standard Remote ID drones and broadcast modules |
| Operations framework | (EU) 2019/947: Open / Specific / Certified | 14 CFR Part 107: small unmanned aircraft below 55 lb |
| Registration threshold | operator registration under Article 14 of 2019/947 | registration required unless operated under 49 U.S.C. 44809 and 0.55 lb or less (14 CFR 48.15) |
| Remote ID | direct broadcast in Annex Parts 2 to 4 and 6; Article 40(5) for Specific | 14 CFR Part 89: standard Remote ID or broadcast module, required for operations after 16 September 2023 (89.105) |
| Serial number | ANSI/CTA-2063-A (Parts 2 to 4 and 6, Article 40(4)) | ANSI/CTA-2063-A (89.505) |
| BVLOS | STS-02 with a C6, or operational authorisation | waiver of 107.31 under 107.205 |
| Mutual recognition | No drone MRA | No automatic recognition |
A manufacturer targeting both markets runs both paths, and handles the radio side under FCC Part 15 or other applicable FCC rules (for Wi-Fi, BLE or other command links) as well as under the European RED. The EU + US dual certification guide details which tests can be shared.
Claims the texts contradict
Section titled “Claims the texts contradict”| Common claim | What the text says |
|---|---|
| "Part 5 of the Annex is class C0 and Part 6 is class C4" (an earlier version of this page said so) | Article 2(1)(a) and Parts 1 to 6: Part 1 is C0, Part 5 is C4, Part 6 is the direct remote identification add-on |
| "C5 and C6 need a notified body because they are Specific-category drones" (also on an earlier version of this page) | Article 13(2)(a) opens Module A to Parts 16 and 17, under the harmonised-standard condition |
| "C6 must have an active geo-cage instead of geo-awareness, and redundant flight termination" | Part 17 requires containment within a programmable operational volume and a flight termination independent from it; geo-awareness is optional; nothing says redundant |
| "STS-02 requires airspace observers" | UAS.STS-02.020(5) and (6): without observers the drone stays within 1 km on a pre-programmed trajectory; observers extend that to 2 km |
| "Every Open pilot needs a competency certificate" | UAS.OPEN.020(4) and UAS.OPEN.060(1)(a): with a C0 or an unclassified drone below 250 g, familiarity with the manufacturer instructions is enough; the certificate is the A2 one |
| "Technical documentation is kept 10 years after the last unit" | Article 6(3): 10 years after the product has been placed on the market |
| "C4 allows nothing beyond basic stabilisation" | Part 5(3) also allows lost-link assistance with a pre-determined fixed position of the flight controls |
| "The Remote ID broadcast includes a session identifier and must reach a set range" | Part 2(12)(b): the UA serial number, not a session ID; no range is set, only reception by existing mobile devices within the broadcasting range |
| "Regulation 2019/947 is in force since 31 December 2020" | It entered into force in 2019; 31 December 2020 is its date of application (Article 23(1)) |
| "The US has no product-side drone rules" | 14 CFR Part 107 subpart D and Part 89 both contain producer declarations of compliance |
Common pitfalls
Section titled “Common pitfalls”Confusing product class and operating category
Section titled “Confusing product class and operating category”A buyer asking for an A2 drone needs a C2. A manufacturer cannot sell a "Specific drone": the operation is Specific, and the drone is either a C5 or C6 (for STS) or an unclassified drone with the capabilities set in an operational authorisation.
Assuming Module A is unconditional
Section titled “Assuming Module A is unconditional”Module A for C0, C4, C5, C6 and the add-on depends on applying the cited harmonised standards for every requirement they cover. Since EN 4709-002:2023 was cited, a Module A file for a drone with direct Remote ID must show that standard applied, plus separate evidence for the restricted reception requirement.
Overlooking the radio equipment directive
Section titled “Overlooking the radio equipment directive”The command link, video link, Remote ID transmitter and GNSS receiver are radio functions under Directive 2014/53/EU: Article 3(1)(a) health and safety, 3(1)(b) EMC, 3(2) spectrum. Since 1 August 2025, Article 3(3)(d)(e)(f) also applies to radio equipment within the scope of Delegated Regulation (EU) 2022/30, typically equipment that can communicate over the internet, whatever its drone class. See RED pillar and RED tests.
Importing an unmarked drone
Section titled “Importing an unmarked drone”An unclassified drone placed on the market from 1 January 2024 has no Open-category route unless it is privately built. Article 20 of 2019/947 only covers drones placed on the market before that date (A1 below 250 g, A3 below 25 kg). Importers carry the obligations of Article 8 of 2019/945, and Article 10 turns an importer or distributor into a manufacturer if it rebrands or modifies the product in a way that may affect compliance.
Confusing C4 with an unclassified model
Section titled “Confusing C4 with an unclassified model”A C4 is a declared class with technical documentation, CE marking and a C4 label. A model below 25 kg without a label is unclassified: privately built, it flies in A3 under UAS.OPEN.040(4)(a); placed on the market before 1 January 2024, under Article 20(b); otherwise, the Specific category (or an Article 16 authorisation for model aircraft clubs and associations).
C5 by kit: who is the manufacturer
Section titled “C5 by kit: who is the manufacturer”Article 2(1)(b) puts C5 accessories kits in scope as products in their own right. The kit manufacturer runs the conformity assessment, labels every accessory C5, and issues the EU declaration of conformity, which may rely on the C3 certificate and names the C3 type converted (Part 11, points 3 and 4). The operator who fits the kit is not a manufacturer; UAS.STS-01.030 requires it to hold the declarations referring to C3 and to the kit, and the C5 label on the kit.
See also
Section titled “See also”- ISO 10218 and ISO/TS 15066: robotics and cobot safety
- Solar PV modules: IEC 61730 safety and IEC 61215 performance
- CPR (305/2011) and EN 50575 cable reaction-to-fire
- HAC: Hearing Aid Compatibility (FCC 20.19, C63.19)
- Machinery Directive 2006/42/EC and Regulation 2023/1230
- EN 71 toy safety in the EU
- EU market surveillance and Safety Gate
Cross-links
Section titled “Cross-links”- CE marking for the applicable general requirements.
- RED directive for radio links, remote control, radio Remote ID, GNSS.
- Self-declaration vs notified body for the module choice.
- EU Declaration of Conformity for the template format applicable to drones.
- EU + US dual certification for products targeting both markets.
- Glossary for definitions of SORA, OSO, GRC, ARC, SAIL, STS, BVLOS, VLOS.
Sources & references
- Delegated Regulation (EU) 2019/945 on unmanned aircraft systems (consolidated text), EUR-Lex eur-lex.europa.eu/eli/reg_del/2019/945/oj
- Delegated Regulation (EU) 2020/1058 introducing classes C5 and C6, EUR-Lex eur-lex.europa.eu/eli/reg_del/2020/1058/oj
- Delegated Regulation (EU) 2024/1108 amending Regulation 2019/945 (applies from 1 May 2025), EUR-Lex eur-lex.europa.eu/eli/reg_del/2024/1108/oj
- Implementing Regulation (EU) 2019/947 on rules and procedures for the operation of unmanned aircraft (consolidated text), EUR-Lex eur-lex.europa.eu/eli/reg_impl/2019/947/oj
- Implementing Decision (EU) 2024/2103 citing EN 4709-002:2023 with restriction, EUR-Lex eur-lex.europa.eu/eli/dec_impl/2024/2103/oj
- Harmonised standards for unmanned aircraft systems, European Commission single-market-economy.ec.europa.eu/single-market/goods/european-standards/harmonised-standards/unmanned-aircraft-systems_en
- EASA Civil Drones (UAS) domain portal, EASA www.easa.europa.eu/en/domains/civil-drones
- EASA Easy Access Rules for UAS (Regulations (EU) 2019/947 and 2019/945), EASA www.easa.europa.eu/en/document-library/easy-access-rules/easy-access-rules-unmanned-aircraft-systems
- JARUS publications (SORA), JARUS jarus-rpas.org/publications/
- Directive 2009/48/EC on the safety of toys, EUR-Lex eur-lex.europa.eu/eli/dir/2009/48/oj
- 14 CFR Part 107, small unmanned aircraft systems, eCFR www.ecfr.gov/current/title-14/chapter-I/subchapter-F/part-107
- 14 CFR Part 89, remote identification of unmanned aircraft, eCFR www.ecfr.gov/current/title-14/chapter-I/subchapter-F/part-89
Frequently asked questions
- What is a UAS class identification label C0 to C6?
- It is the label defined in Parts 1 to 5, 16 and 17 of the Annex to Delegated Regulation (EU) 2019/945 that tells which of the seven classes a drone belongs to. Article 16(2) requires it to be affixed visibly, legibly and indelibly to the unmanned aircraft (or to each accessory of a C5 kit) and to its packaging, at least 5 mm high. It comes on top of the CE marking, and Implementing Regulation (EU) 2019/947 uses it to decide in which Open subcategory or standard scenario the drone may fly.
- What is the difference between the product class (2019/945) and the operating category (2019/947)?
- The class (C0 to C6) is a product property, declared by the manufacturer after a conformity assessment under Regulation 2019/945. The category (Open A1/A2/A3, Specific, Certified) belongs to each operation and is set by Regulation 2019/947. A C2 drone can fly in A2 or A3, or in the Specific category under an operational authorisation, but it never becomes another class.
- Does the C0 class require a notified body?
- No. Article 13(2)(a) of Regulation 2019/945 makes internal production control (Module A, Part 7 of the Annex) available for Parts 1, 5, 6, 16 and 17, that is C0, C4, the direct remote identification add-on, C5 and C6, on condition that the manufacturer has applied the harmonised standards cited in the Official Journal for all the requirements they cover. A C0 that is a toy under Directive 2009/48/EC cannot use Module H (Article 13(2)(c)), and points 4, 5 and 6 of Part 1 do not apply to it.
- Is Remote ID mandatory for every class?
- No. Direct remote identification is required for C1 (Part 2, point 12), C2 (Part 3, point 14) and C3 (Part 4, point 9, unless tethered), and for C5 and C6 because they must meet Part 4. Geo-awareness is mandatory for C1, C2 and C3 only; C5 and C6 must comply with it only if they are fitted with it. Parts 1 and 5 (C0 and C4) contain neither requirement.
- What exactly do C5 and C6 cover?
- They were added by Delegated Regulation (EU) 2020/1058 for the two EU standard scenarios. C5 (Part 16) is required for STS-01, VLOS over a controlled ground area in a populated environment. C6 (Part 17) is required for STS-02, BVLOS over a controlled ground area in a sparsely populated environment, with or without airspace observers. Declarations under these scenarios apply from 1 January 2024 (Article 23(2) of Regulation 2019/947).
- Is the EU class label enough to fly the drone in the United States?
- No. The FAA does not use C0 to C6. Operations fall under 14 CFR Part 107 (small UAS under 55 lb) and remote identification under 14 CFR Part 89, which has its own producer requirements. One element is shared: both Regulation 2019/945 and Part 89 call for a serial number compliant with ANSI/CTA-2063-A. See the EU + US dual certification guide.
- Does a Remote ID firmware update trigger a new marking?
- Article 4(3) of Regulation 2019/945 allows software updates on products already on the market only if they do not affect compliance, and Article 6(4) requires changes in software to be taken into account in series conformity. If an update changes a declared characteristic, the technical documentation and the EU declaration of conformity must be updated and, under Module B and C or Module H, the notified body involved accordingly. Regulation 2019/945 has only Modules A, B and C, and H.