Importer and Distributor Obligations

The requirements don’t stop at the manufacturer, the new delegated regulation puts some onus and responsibility on the Importer too:

• Ensure manufacturer has completed their obligations (e.g. labeling, CE Marking etc.)

• Provide trading name, address, website etc on product, packaging or accompanying documentation

• Ensure while under their responsibility it is stored and transported such that it doesn’t jeopardise compliance

• Where appropriate (with regards to the risks of the product) carry out sample testing

• Keep copies of Declaration of Conformity for 10 years

• Take corrective actions when known to not be compliant and respond to audits

Distributor obligations are largely the same (except the need for adding trading name and details), however, if a product is placed on the market under the trading name of a distributor then they take on the responsibility of fulfilling the manufacturer obligations.

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.

Manufacturer Obligations

Current regulations for selling in europe are quite exhaustive in terms of product safety but don’t specifically cover drones. The classes I have previously covered fills that gap and will form part of the requirements to CE mark drones to be sold in the EU. The following are the responsibilities of the Manufacturer in respect to drones they sell:

• Ensure software, design or characteristic changes are only be issued if they don’t affect compliance with the DR

• Ensure compliance with the DR, provide technical information and conformity assessment

• Produce Declaration of Conformity and CE Marking and they should keep this for 10 years

• Put procedures in place to ensure series production remain compliant

• Ensure drone / remote ID add on has the type/class (drone only) and unique serial number

• Provide trading name, address, website etc on product, packaging or accompanying documentation

• Ensure product has User Manual and EASA Information notice in language that can be understood

• Take corrective actions when known to not be compliant and respond to audits

• They may delegate certain aspects of this to an Authorised Representative (i.e. data retention, audits, and/or non-conformity actions).

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.

Remote ID Add On Requirements

There’s really little difference between the requirements of a remote ID system already built into a drone vs the requirements of a separate add on remote ID device. Here’s a reminder:

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) of 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.

The following is the key difference, a remote Add on should have a user manual with transmission protocol details and instructions to:

• Install on the drone

• change operator registration number

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.