G/TBT/W/646  
 
4 July 2019  
(19-4485) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
EUROPEAN UNION - EXPLANATORY MEMORANDUM OF UNMANNED AIRCRAFT  SYSTEMS 
AND THIRD -COUNTRY OP ERATORS OF U NMANNED AIRCRAFT  
STATEMENT BY CHINA T O THE COMMITTEE ON T ECHNICAL BARRIERS TO  TRADE  
20 AND 21 JUNE 2019  
The following communication, dated 4 July 2019, is being circulated at the request of the delegation 
of China . 
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1.  Our concern is related to  EU commission delegated regulation on unmanned aircraft systems and 
third-country operators of unmanned aircraft, Notification No. is G/TBT/N/EU/628 . 
2.  On 10 December 2018, the EU notify its draft regulation on unmanned aircraft which is just cover 
the "open" category, after comment period, EU extended the scope of regulation to all types of UAS, 
and published Commission Delegated Regulation (EU) "on unmanned aircraft systems and on third -
country operators of unmanned aircraft systems." And several new requirements were added. 
So our first concern point is the suggestion for EU  to provide a comment opportunity for such new 
products and requirements added in its new version.  
3.  Secondly,  the regulation require s a physical serial number affixed to equipment . We suggest that 
the EU harmoni ze its require ments  with international standar ds developed by relevant international 
standardization bodies. ISO, IEC and ITU  are jointly developing an  international standard for UAS 
OID codin . According to that standard, the distribution and management of coding is subject to the 
supervision by ISO/IEC and ITU, which can reduce the security risks , and more compatible  to the 
OID application of the International Civil Aviation Organization.  
4.  Thirdly, the requirement for the mechanical strength of the tethered UAS cable is stricter than 
necessary. T he regulation requires 10 times by take -off weight, according to assessment by 
enterprises, 4 times is enough for safety. It is calculated that the safety factor of mechanical strength 
of different material cables 10 times by the take -off weight is 2.8 - 8.4, which is much higher than 
the safety factor of all parts of manned civil aviation and general aviation (1.25 - 1.8). Superabundant 
requirement also leads to a significant reduction of the overall performance. In addition, the backup 
batteries, automatic  return and other technologies are more conducive to ensure the safe operation 
of the tethered UAS in terrible weather, air flow and other special conditions.  
5.  Fourthly, we think the limit of the length of category C3 UAS is too short. With the development 
of technology, the category C3 of tethered UAS has good stability and wind resistance. The extension 
length of 50 meters, which required by EU regulation, could not meet the needs of customer's 
applications. Since the regulation limits the flying height of  "Open Drones" to 120 meters, and 
category C3 of the tethered UAS do not have more risk than Open Drones. So we suggest EU consider 
to use the same criteria for both of them.  G/TBT/W/646  
 
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  6.  Lastly, we think the test criteria for noise is hard to practice. The Chapter 13 of the Act require 
"UAS should hover 0.5 meters above the reflection plane", but some industry -class drones, generally 
category C3, C4 UAS, have a big scaffold, even higher than 0.5 meters, it's impossible to act as the 
description in EU's regulation. So w e suggest to change the requirement to "UAS should hover at 
the lowest point to 0.5 meters above the reflector".  
 
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