How does a drone get a Cx CE marking?

When will drones with Cx class identification labels be available? Unfortunately, as secretary of the NEN committee for drones, I cannot (yet) answer this question. What I can do is provide insight into the process of developing standards and when they are expected. Note, for convenience, this is a simplified representation of the process.

Harmonized standards

Standards and regulations are often confused. Standards are usually voluntary agreements on specifications or criteria for products, working methods and services. In addition, standards are drawn up by industry stakeholders and not by the government. For drones it is actually a bit of both: the drone standards in Europe are harmonized standards. These are standards that are created on the basis of a request from the European Commission to the European standardization bodies to create standards to which regulations can refer.

Essential requirements and standards

For a Cx CE marking, the drone must meet the ‘essential requirements’ from the European regulation (2019/945 and 2020/1058). The ‘essential requirements’ are described in the annex of the regulation: which requirements are set for drone classes C0 to C6. The regulation also states that products that are in conformity with harmonized European standards shall be presumed to be in conformity with the ‘essential requirements’.

European level playing field

Based on these requirements, drone industry stakeholders create standards. These standards are then assessed by the European Commission. It checks whether they have been drawn up correctly and whether they meet all the conditions. Then a reference to the standards is published in the EU’s Official Journal (OJEU). From that moment on, there is a harmonized standard. Do you meet the requirements from a harmonized standard? Then you can assume that you meet the essential requirements in the (legal) regulation. This principle is also known as “the presumption of conformity”. Because both standards and regulations are valid throughout Europe, a clear level playing field is created for market parties.

Conformity

The harmonized standards referred to under the Regulation can then be used in the conformity assessment procedures. These are the procedures in which it is checked whether the product meets the essential requirements and after which the CE marking (and the Cx label) may be applied. But standards are voluntary: you don’t necessarily have to follow the standards. You can always show in another way that the product meets the requirements of the regulation. Applying a harmonized standard does make it easier to show that you meet the requirements. Plus, you don’t have to reinvent the wheel.

Timeline Cx CE markings

So when can a drone be sold with a Cx CE marking? When a manufacturer, importer, or distributor can demonstrate that the drone meets the essential requirements for the drone class from the regulation. When the person doing the conformity assessment has the standard in hand, it is probably a lot easier to demonstrate than without.

The deadline for creating the harmonized standards classes C0 to 4 is June 30, 2022. For classes C5 and C6, that is June 30, 2023. After completion, the standards are assessed and the reference must be published in the OJEU. This can sometimes take several months. They can then be used – based on the deadline towards the second half of 2022 (or second half 2023 for C5 and C6).

The further timeline for a Cx CE marking then depends on the conformity assessment based on the standards. Are those procedures fully ready on the day of publication in the OJEU? Then assessments based on the standard can be performed immediately and Cx CE markings can be applied. If these procedures are only initiated after publication in the OJEU, it will take longer.

Making standards: The process

The harmonized European standards for drones are made within ASD-STAN, an institute associated with CEN (European Committee for Standardization). This standard development process is accessible to all stakeholders through the national standardization bodies, such as NEN in the Netherlands. The standards are being developed in the ASD-STAN working group on drones. Within this working group, national representatives jointly determine the main features of the content based on the essential requirements of the regulation. Then the actual writing takes place in smaller subgroups. As soon as a concept is ready, they submit it to the working group.

As soon as the working group gives the green light, the draft will be submitted to the national standardization bodies for public consultation. All stakeholders can then use the standardization institute in their own country to comment. Only when the comments have been processed by the working group and subgroups can the draft finally be put to the vote. Voting also takes place via the national standardization bodies. This voting is done on the basis of a weighted vote – larger member states have a heavier vote.

National standardization committees

NEN coordinates the Dutch position within the drone standards committee. Experts and stakeholders meet in the NEN standards committee and jointly determine the position of the Netherlands. Through the NEN committee, members can also participate in the subgroups that write the standards or comment on concepts. NEN is a member of ASD-STAN and votes based on the opinion of the standards committee members.

Importance of participation

By participating in a committee, members can influence the content of the standard. Apart from that, they have early knowledge of the content. This enables committee members to anticipate upcoming developments and requirements before the standard is published. In principle, any party can register as a member of the national commission. The only requirements are expertise and demonstrable interest in influencing standards for the drone sector.

Good standards are in the interest of every professional in the industry: topics such as “safely controllable”, “minimize injury to people”, “flight instructions”, “geo-awareness” and “verification methods” are just a few examples of elements in the current set of standards relevant to all stakeholders. Not only the producer of the drone, but also the (demanding) user. Representation of all stakeholders in the creation of a standard ensures better standards. Good standards, just like regulations, contribute to the safety and quality of drones and thus the possibilities for the sector.

Subjects of standards

The European standards under development for drones (or UAS – Unmanned Aircraft Systems) cover the following topics:

  • General product characteristics classes C0 to C4 UAS
  • Direct Remote Identification requirements for UAS
  • Geo-awareness requirements for UAS
  • Lighting requirements for UAS
  • Network remote identification requirements for UAS
  • Geo-caging requirements for UAS
  • Flight Termination System Requirements for UAS
  • General product features for classes C5 and C6 UAS and accessories

Global standards for drones

In addition to the European EN standards there are also ISO standards. These too areagreements about products, services and methods made by market parties, but at a global level. The first published ISO standard for drones dealt with “operational procedures”. It seems so logical that these are the same all over the world – but that sort of thing is often based on a standard. There is a reason whythe ISO aviation and shipping committees, with products and services that travel the world, are two of the most important and largest committees out there! In addition, ISO standards are also important because they sometimes form the basis for harmonized European standards.

ISO also covers a wide range of topics for which it is important that all countries implement them in the same way: From “vocabularies” to “staff training” and “test methods” to “UAS components” and “Requirements for UTM service providers” to “requirements for tethered UAS”. Participation in ISO committees works roughly the same way as with the NEN standards: It all starts with the national NEN committee. In the world of international standards, this expresses the voice of the Dutch drone industry. For companies and stakeholders in other European states I’d have to refer you to the national standards institute.

Contact us!

With this blog I hope to have provided a little more insight into the world of standards and why they are important for the drone sector in the Netherlands. For more information and a complete overview of the ISO standards, I would like to refer you to the website of the NEN drones committee. If you have any questions about standards for drones or membership as a result of this blog, I cordially invite you to contact us via iv@nen.nl or tel no. +31152690180.

(cover photo: DJI, edited in Photoshop)

Nina van der Meer

Nina van der Meer is Consultant Industry and Safety at NEN.

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