CE and Class Marking for Drones
The CE mark is required to classify products sold in the European Economic Area (EEA). The mark is used to verify a product meets the necessary health, safety and environmental standards in order to be marketed across the EU. Only products that have been issued a CE mark can be sold in the EU.
EASA’s Delegated Regulation (EU) 2019/945 will be mandatory for all drones in Europe from January 1, 2024. The document formulates the regulatory framework required for all uncrewed aircraft systems (UAS) in the open category that are intended to operate within European airspace and outlines the rules and conditions under which UAS can be operated according to its type and the necessary remote identification specifications. This defines which C-Class level the drone will require.
Categories and Classification for Drones in Europe
Implementing Regulation (EU) 2019/947, published on May 24, 2019, defines UAS by three main categories: Open, Specific and Certified. These categories identify the operational level of risk within an airspace.
Delegated Regulation (EU) 2019/945 divides drones into 7 classes (C0 - C6). These classes determine the certification requirements for CE marking and notify the operator whether Remote ID is necessary.
How to Comply with the Regulation
The biggest challenge drone manufacturers will face when certifying a drone is the full responsibility for identifying and complying with all valid legislation and the procedures involved. These include several Union harmonisation legislation listed in Chapter II of Regulation (EU) 2019/945, which can only be done by an official notified body, of which there are only 5 within Europe.
Once a drone has been conformed to all relevant legislation, an EU Declaration must be formulated in compliance with the Regulation (EU) 2019/945, and the CE marking must be added to the drone.
During the application process, the notified body is not allowed to consult the applicant. This means that the applicant will only receive a pass or fail from the notified body and will not receive any feedback or ways to improve their product in order to pass certification for CE marking. Murzilli Consulting’s C-Class and CE support services were established to ease this process.
How to Receive CE Marking and C-Class Rating
The certification process involves 9 key steps. It begins with the manufacturer correctly identifying the targeted C-Class category (1-6). This is followed by the preparation of the technical documentation aligning with Regulation (EU) 2019/945 and the Machinery Directive 2006/42/EC. In parallel, the technical design and functionalities are developed to comply with the pre-standards of EN 4709-001, -002, 003, 004. It is important to note that these first 3 steps are crucial for a successful interaction with the notified body. Any missing documentation can lead to multiple redesigns and test loops. With the help of a consultancy firm like Murzilli Consulting, these steps can be prepared by consultancy experts to ensure the initial processes run smoothly.
Once the above-mentioned preparations are in place, the manufacturer should identify and contract a notified body and agree on a test campaign. The manufacturer needs to provide at least two test UAS for the notified body to execute the tests.
After the tests have been performed, the notified body issues a test report, which may lead to a potential re-design or documentation update by the manufacturer. If this is the case, the notified body must perform a re-testing. The final step is the issue of the CE marking certification and assigned C-Class rating, signifying the UAV’s compliance and readiness for market.
How a Drone Consultancy Firm Supports the Certification Process
Murzilli Consulting’s UAS C-Class and CE services have been tailored to accelerate the certification process and reduce time and effort while coordinating with the notified bodies. The process is typically formatted into 4 standard phases, although additional services can be added to fit varying customer needs.
The familiarisation phase is used to identify the manufacturer’s C-Class target market (1-6) while outlining the regulatory roadmap required to secure the C-Class and CE marking certification and authorisation. This is also when a stocktake of the existing documents takes place and a walk-through of the drone design to ensure it complies with the specified standards and requirements.
The design and documentation review is when the consultancy team extensively reviews the design and technical documentation to create a structured walk-through of the testing phase and to outline with whom each responsibility lies. This includes a preliminary gap analysis on the functionalities and technical documentation. This is also the time that the consultants begin to align with the notified bodies.
The testing phase is in place to assess the functional requirements of a design. These include gap testing for the various hardware and software functionalities with a focus on the C-Class rating. CE testing will be performed by the notified body at the assessment, although during this phase, the consultants offer guidance on the standards to be considered to show compliance and to make sure the final testing runs smoothly.
The final gap analysis and gap closing procedures phase allows for the test results to be evaluated in order to prepare for a comprehensive gap analysis, which leads to effectively addressing and closing these gaps.
The benefits of using an experienced consulting firm such as Murzilli Consulting to perform these phases are that they have long-formed connections with the relevant notified bodies and know specifically what each authority is looking for and how to highlight those features in a proposal. They are also up-to-date with the latest response times and know the best communication methods with a notified body, which can help give a more accurate time estimation to complete the C-Class and CE marking certification.
What About Drone Operators?
Although surveillance authorities are working to ensure that a UAS on the market complies with Regulation (EU) 2019/945, there are several measures you, as an individual, can reference. These include:
🔸Purchasing a drone from a verified shop and avoid buying online, in particular outside of the EU, as these may not be compliant with EU laws
🔸Clarifying the drone has an authentic class identification logo. It will be one of the following:
🔸Confirming that there is a CE mark on the drone
🔸Verifying that the EU declaration of conformity (referring to R945 and containing the serial number on the drone) was included in the package
🔸Checking that the requirements of the drone comply with the categories and classes using the infographic above
How to Define the Open Category
Drones in the open category are classed by the identification labels 0, 1, 2, 3, 4. The open category applies to all drones with a total weight of less than 25 kg. Drone operators must maintain the UAS in visual line of sight (VLOS) and keep a safe distance from people. During flight, the UAS must remain 120 m from the Earth’s surface and may not fly over crowds of people. Drones in this category are prohibited from carrying dangerous goods or dropping any material. All drones in the open category must have a CE marking.
What About the Subcategories?
The subcategories A1, A2 and A3 apply to the Open category and allow drones to be operated according to each of their specific conditions. These subcategories help characterise drones into the open category to meet the requirements for the CE marking process.
What is the Specific Category?
The specific category was created with a broad spectrum of UAS operations in mind. It allows for low- and high-risk operations, meaning each case must be assessed and analysed individually. The method SORA (Specific Operations Risk Assessment) was created for this purpose and has several training courses available. Using SORA, your operation can obtain a SAIL (Specific Assistant and Integrity Levels), which will result in either:
- Low Risk (SAIL I and II)
- Medium Risk (SAIL III and IV)
- High Risk (SAIL V and VI)
This complex risk assessment will identify if your operation is categorised in a standard scenario and whether it will need additional certification, such as a Design Verification Report (DVR) or Type Certificate (TC).
The CE marking process for this category will depend on which standard scenario is targeted. If the risk assessment is completed under the SORA/ConOps procedure, CE marking will not be required.
The Certified Category
The certified category was designed for high-risk operations. This includes flights with human passengers on board. The aircraft used for these operations will always need to be certified and will be regulated by the relevant (crewed) aviation authority.
This category does not require CE marking as it falls into the aircraft certification process.
Murzilli Consulting’s specialised UAS C-Class and CE marking services can provide end-to-end support to prepare manufacturers for C-Class and CE marking certification.
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