ED Decision 2022/002/R
MODIFICATION OF A UAS WITH A CLASS IDENTIFICATION LABEL
When placing UASs with a class identification label on the market, manufacturers should ensure the compliance of those UASs with the applicable regulatory requirements. It is the responsibility of UAS operators to ensure that those UASs remain compliant throughout their lifetime. UAS operators should, therefore, not make any modifications to a UAS in class C0, C1, C2, C3 or C4 that breach compliance with the product requirements, unless the modification is foreseen by the manufacturer and documented in the manufacturerâs instructions.
The replacement of a part by a similar one for maintenance purposes is not considered a modification, provided the operator uses an original part or a part that complies with the characteristics defined by the manufacturer in the list of replaceable parts provided in the manufacturerâs instructions.
The affixation of payload is not considered a modification provided that affixing a payload is not forbidden by the manufacturer and the payload complies with the characteristics provided in the manufacturerâs instructions. Affixing a payload when it is forbidden by the manufacturer or affixing a payload that does not comply with the characteristics provided in the manufacturerâs instructions is strictly forbidden.
If the payload does not comply with the characteristics of the allowed payloads or if maintenance is not performed according to the manufacturerâs instructions, it is then considered a modification that invalidates the class conformity. The class identification label must be removed from the UAS identification label and the modified UAS may only be operated in the âspecificâ category in accordance with Subpart B of Annex to the UAS Regulation.
Changes to UASs with a class identification label C4 are allowed, and such UASs can be considered âprivately builtâ UASs and continue to be operated in subcategory A3 of the âopenâ category.
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