Andreja
lvl.4
Flight distance : 864961 ft
Germany
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JodyB Posted at 10-13 03:58
Apparently this is so their drones can meet the requirements for C1 certification. I don't know what the actual requirements for C1 certification are as listed by EASA but it might be worth a research?
Hi!
The issue I see here, is that the actual EU Drone Regulations, that is to say "COMMISSION DELEGATED REGULATION (EU) 2019/945" and "COMMISSION IMPLEMENTING REGULATION (EU) 2019/947", do not actually say anything about users not being able to control lights, and they are publicly accessible in the Official Journal of the European Union, which is in charge of publishing laws.
However, there's another part of the story for Europe. For a product to put a CE sign, it must comply with all European laws about products of that category, and manufacturer must issue a Declaration of Conformity document, stating the norms, laws, and so on.
For some types of devices (I myself work with medical devices, but the process is similar for other types), an internal compliance process done by the manufacturer is not enough to put a CE sign, and external body (a little bit like the Underwriters Laboratories in the US) must also be involved, to determine that the product fulfills all the regulations.
That type of body is called "notified body" in EU-bureaucracy-speech. So a notified body works with a manufacturer to determine which norms the product must fulfill, and check if the product is compliant with those norms, and if it is, then the manufacturer is allowed to put the CE sign on the product.
So we come to the the EN 4709 series of European Norms, currently prEN 4709-001 through prEN 4709-004. They are the norms which concern themselves with drones, and they're still drafts. Those drafts are not free, and cost around $250 a pop, and they'll have in them the actual requirements of what needs to be done.
But wait, that's not all!
The notified body checks if we're in compliance with our norms.
So, we can say, that the notified bodies interpret the norms, and in practice, the law is what the notified body says that it is, and different notified bodies might have different interpretations of norms, or they might pay special attention to some parts of the norms, and let rules from other parts "slip through".
This is also a case of perverse incentives, since in EU, there's a free market for notified bodies, and manufacturer (or distributor) is free to choose which notified body will do the certification of the product. At the same time, there isn't really a punishment system for notified bodies, if they end up not looking at some aspects of the product they way they should*. So some companies might want to choose a "cooperative" notified body, which won't make things more complicated than they need to be.
So to sum the above wall of text up: Even though the actual laws do not say anything about disallowing users from operating the auxiliary light switch, the norms might have something in them about that topic, or notified body might interpret them as if they have something about this topic in them.
Different notified bodies might interpret norms in different ways, so in the end, we can have two different products implementing the same norm differently, and manufacturers could correctly claim that they're both implementing the norm correctly, because their notified bodies told them that they are.
Also, in the concrete case of the DJI Air 3, the notified body was ALTER TECHNOLOGY-TÜV NORD, S.A.U., notified body number 2031, from Spain.
I belive that the whole story I wrote above might be a bit too complicated to go through different levels of DJI worker hierarchy, so by the time it reaches the support representatives here in the forum, story gets shortened to the "EU laws" responses, which we get.
Then, for the conspiracy theory part... Auxiliary light switched are often used on drones modified to drop objects from drones to the ground, and I suspect that the EU might want to make such use a bit more difficult. |
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