if i read point number 3 right, declasssification for mini 4 pro doesnt make sense anymore, because after 1st of january u can have the 500 m limit via software - but u can only fly the declassified drone in the specific category. and flying in the specific category is a NIGHTMARE! it makes it so hard to fly it legally at all then - given all the restrictions u have there (at least within EU). i wonder if a lot of people who already declassified it will have a depression soon... i stopped my declassification process because of this.
and its not enoguh that some "experts" in youtube handle point 3 by saying "this might be wrong", or "its probably meant differently". as long as it stands there as in the screenshot, it means that u can fl only in specific category. things like "this might be..." wont help then - if all misunderstood this point or ignored it.

The EU forcing this restriction on DJI makes no sense to me because it is preventing something that I believe will remain legal, i.e. it is legal to fly the drone above 120m wrt the take off point providing the drone remains within 120m of the closest ground and it still doesn't prevent drones breaking 120m AGL etc.
It amounts to forcing car manufacturers to introduce a maximum speed limit of 50kph irrespective of the legal limit on the actual road.

I will shut up now as I don't want to side track what might turn into a very useful thread.

I interpret section 3 to mean if you leave the C0 label on the drone until the end of 2023 (the drone is not decertified during 2023) and remove the label on or after 01. January 2024, the drone will lose all certification and can no longer be regarded as a legacy drone. Without certification of any kind it can only be flown in the special category. This would also be the case if you bought the drone in 2024 and removed the label.
If correct, this is more of a hypothetical case because Dji will not offer the decertification process in 2024 and the only way to remove the C0 certification would be to simply peel off the C0 label.
As I said at the beginning, this is just my interpretation.

By the way, my interpretation of the second sentence of section 1:
"Starting from 2024, a compliant pathway for applying for the C1 label will be made available."
based also on recent comments from the forum admins, means that as an alternative to removing the label in 2023 as described, a compliant path to C1 certification will be provided in 2024. The statement is a little ambiguous, but arguably not incorrect. If the do actually provide this C1 certification path, which has not yet been defined.

StepCH Posted at 12-14 11:53
I interpret section 3 to mean if you leave the C0 label on the drone until the end of 2023 (the drone is not decertified during 2023) and remove the label on or after 01. January 2024, the drone will lose all certification and can no longer be regarded as a legacy drone. Without certification of any kind it can only be flown in the special category. This would also be the case if you bought the drone in 2024 and removed the label.
If correct, this is more of a hypothetical case because Dji will not offer the decertification process in 2024 and the only way to remove the C0 certification would be to simply peel off the C0 label.
As I said at the beginning, this is just my interpretation.

The statement seems pretty clear for me despite what I read from the DJI reps : if you remove the C0 label in 2023, you can request a C1 label by 2024.

If they wanted to say that if you remove the C0 label by 2023 you wouldn't be able to ask for a C1 label by 2024, they wouldn't had said the same section #1 with two phrases and they would say 'or' or something else.

If we look at the official regulation (not at DJI statements), we can read that:

UAS types within the meaning of Decision No 768/2008/EC of the European Parliament and of the Council1, which do not comply with Delegated Regulation (EU) 2019/945 and which are not privately-built are allowed to continue to be operated under the following conditions, when they have been placed on the market before 1 January 2024:

(a) in subcategory A1 as defined in Part A of the Annex, provided that the unmanned aircraft has a
maximum take-off mass of less than 250 g, including its payload;

(b) in subcategory A3 as defined in Part A of the Annex, provided that the unmanned aircraft has a
maximum take-off mass of less than 25 kg, including its fuel and payload.


This means that a declassified Mini 4 Pro starting from 1st Jan 2024 can always fly in A1 scenarios, also without the C1 classification. In fact the Mini 4 Pro has an official MTOM statement and this puts the aircraft in the group (a) of the official statement.

Obtaining a C1 certification includes the activation of the ID broadcast ... are you sure you want that ? What are the advantages of a C1 certification vs a declassified M4P ?

Greetings everyone,
this is the response obtained yesterday from support@dji.com to an email of mine requesting questions on the topic...

“We appreciate your time for sending us an email. We would love to help you with your inquiry. Please allow us to answer your questions below:

Starting from January 1, 2024, DJI Mini 4 Pro will be qualified for C1 certificate, and new firmware and App version will be released in mid-December, supporting DJI Mini 4 Pro to apply for C1 certification label. For those ones who does not remove the C0 label in 2023, there will be chances to keep the C0 label with the 120m altitude restriction, and chances to apply for C1 label after 2024 (while the prcedure TBC).

For those ones who purchase in 2024, there will be non-removable mandatory category identification label. Thank you for your support and understanding.

For DJI Mini 4 pro, which has already applied for the removal of the 120m height limit in 2023, there will no longer be a mandatory label requirement after 2024, and you can still fly the drone up to 500m. Aircraft that have applied for the C0 label removal in 2023 can be used normally in the A1 environment, so there is no need to apply for a C1(C0) label and the C1(C0) application is not supported. Thank you for your understanding and support.

Once the C0 label is removed, it cannot be obtained again. and here will no longer be a mandatory label requirement after 2024, and you can still fly the drone up to 500m, so there is no need to apply for a C1(C0) label and the C1(C0) application is not supported.

We hope this information and email helps. Thank you for choosing DJI and have a nice day! ”

"Without Cx label..." so it means none of the current drones can fly after 01.01... How many consumer drones on the market have the Cx classification?
DJI is changing statements every week depending on sales volumes... Anyway I'll take the risk and declassify mine, as soon as it arrives. On the drone is written 249gr I have a valid A1/A3 certificate

travelmate Posted at 12-15 03:46
"Without Cx label..." so it means none of the current drones can fly after 01.01... How many consumer drones on the market have the Cx classification?
DJI is changing statements every week depending on sales volumes... Anyway I'll take the risk and declassify mine, as soon as it arrives. On the drone is written 249gr I have a valid A1/A3 certificate

In retrospect, I think the statements from Dji have been fairly consistent, especially considering the fact that the process hasn‘t been finalised yet. Bear in mind they don‘t actually have to do any of this for us. They could have simply left the M4P as a C0 only drone.
On the other hand, the wide range of interpretations has indeed led to a great deal of confusion on this forum.
Please read post #7 of this thread.

DJI is interpreting the EU regulation in some ways that probably are not correct.
As an example, DJI is interpreting the statement "placed on the market" as the date when a given item has been sold. Based on detailed explanations provided by EASA, that statement is related to the date when a given model has been made available in on the market. The DJI Mini 4 Pro has been placed on the market on 2023 and this is true also for the items purchased in 2024 (if the model number remains the same).
For that reason, there should not be any difference between the M4P purchased on 2023 or on 2024. But maybe they want to push sales for achieving year's end targets ...
From my point of view, on 2024 I would fly only with a MP4 with a valid C0 or C1 label, in order to avoid any misinterpretation. If in doubt, I would wait until a clear path for the C1 certification will be published.

  

Sean-bumble-bee Posted at 12-14 10:15
The EU forcing this restriction on DJI makes no sense to me because it is preventing something that I believe will remain legal, i.e. it is legal to fly the drone above 120m wrt the take off point providing the drone remains within 120m of the closest ground and it still doesn't prevent drones breaking 120m AGL etc.
It amounts to forcing car manufacturers to introduce a maximum speed limit of 50kph irrespective of the legal limit on the actual road.

Well, in a way that speed limit lark has started, but it only hurts those that hit the Autobahn, Volvo for sure has limited their cars now to I think 116 or 117mph. I think another manufacturer has done this too, not sure about that or who for that matter, but it is of their own volition, i.e. it's not mandatory. If you remember, it was Volvo that was leaps ahead in safety years ago and the rest followed suit (3 point seat belt and side impact prevent system) so for sure other manufacturers will start with the lower restrictions, i talking about lower than the 155mph that most do anyway. Actually, thinking about it, didn't the EU pass sone law back in 2022, saying all new cars from  2022 have to be restricted, sorry I know its gone off-topic, I just thought it was worth a mention.

"Well, in a way that speed limit lark has started, b....." wouldn't surprise me.

There is a lot of chatter about declassifying or not the Min4Pro

I will be in Europe before the end of this month, one of my jobs will be to declassify my Mini4Pro, what will change, I will be able to set maximum height to > 120m < 500m, enabling me to fly up the side or up the crevice of tall mountains legally as long as its always within 120m of the earth in Europe, just as I can in UK.

So my Mini4pro will be just like my Mini3pro, both none classified (no labels) both below 250g. Both bought before 01/01/24 and able legally fly in A1.

Happy days, just fortunate that I am going to Europe before 01/01/24.

I'm not sure how DJI can foresee upcoming changes in drone regulation so I would be reluctant to take their word on transitional matters in the UK at least where new regulations are due soon because our withdrawal from the EU has left some temporary gaps. To see the direction of travel, I would urge UK pilots to read the CAA's consultation response last month at
https://consultations.caa.co.uk/ ... inal_2ndedition.pdf

Some key excerpts:
—————————————
Currently, all flights in the A1 sub-category cannot take place over groups of uninvolved people, but UAS <250g and C0 UAS can fly over uninvolved individuals. C1 UAS (<900g) must reduce, as much as possible, flights over uninvolved persons. Our view is that this complexity could make it harder for UAS remote pilots to understand and comply with this requirement. We are proposing to allow C1 UAS to overfly uninvolved people, whilst maintaining the requirement not to overfly groups of uninvolved people. This would, in effect, harmonise requirements for flying over uninvolved persons in the A1 sub-category for different types of UAS.
—————————————
At present, the regulation only explicitly allows C0 and C1 UAS to fly in the A1 sub-category. We are proposing to explicitly allow C0 and C1 UAS to fly in the A3 sub-category. Whilst this will not impact the actual operational privileges for these UAS, it will clarify that C0 and C1 can be used in these sub-categories, and help CAA communicate how class-marks relate to operational requirements.
—————————————
We are proposing to change the names of UAS sub-categories from A1, A2, and A3, to ‘Over’, ‘Near’ and ‘Far’. These revised names aim to reflect the key operational differences between each sub-category – i.e. the distance to uninvolved persons.
—————————————
We are proposing to extend the requirement for a remote pilot to take the Flyer ID test for UAS operations in the ‘Open’ category, to include when flying a UAS less than 250g with and without a camera.
—————————————
We are proposing to require C0, C1, C2 and C3 UAS to display important regulatory information, via a digital information notice, on the user interface or controller app during the product set-up. However, we also agree with Call for Input respondents, who argued that more frequent displays of this information would inconvenience experienced fliers. As such, we do not propose to require manufacturers to display the digital information notice more frequently.
—————————————
We are proposing to implement class-marking and product standards from 1st January 2026 for UAS intended to be used in the Open category. In effect, manufacturers and other economic operators placing UAS on the market for use in the Open category would need to meet class-marking requirements from this point.
We recognise the benefits of international alignment. However, we also consider there to be areas where divergence is in the UK’s interests. We are proposing to align to EU regulations for class-marking and product standards, unless there is a safety, security or user benefit that requires divergence. Chapters 3 and 5 describe specific proposals that diverge from EU regulations, relating to Remote ID, geo-fencing, and user guidance.
—————————————
However, as is described in the above section, we do not expect to fully align to EU product requirements in all cases, and the UK and EU may diverge further over time. Consequently, EU class identification labels cannot be an enduring solution to physically identify compliant products under the UK jurisdiction. Using the same label as the EU would introduce practical challenges for stakeholders to understand whether the product is compliant under the UK or EU jurisdictions, or both.
We are proposing to replace the EU class identification label with a UK-specific identification label. We expect that replacing the letter ‘C’ with ‘UK’ provides the simplest solution (i.e. replacing C1 with UK1). We believe this proposal is necessary to ensure class identification labels can be used to demonstrate compliance with the regulations under the UK and/or EU jurisdictions.
—————————————
Remote ID is proposed to be mandated for all UAS with a maximum take-off mass of 250g or more, or under 250g with a camera, in both the Open and Specific category.
We propose to implement technical mitigations that ensure Remote ID is active before a UAS takes flight.
—————————————
The current operational requirements allow legacy (i.e. non-class marked) UAS to be operated in the A1 and A3 sub-category indefinitely. Our view is that these regulations for legacy UAS would undermine the benefits of Remote ID, by allowing malicious operators to operate lawfully without Remote ID indefinitely, and by reducing the ability for police to differentiate between lawful, negligent and criminal operations. We are therefore proposing to require legacy UAS to be operated with active Remote ID from 1st January 2028 onwards (excluding UAS <250g without cameras). This requirement could be met through either remotely upgrading a UAS with inactive Remote ID capabilities, or through users attaching a compliant Remote ID add-on module to their device.
—————————————
We are also proposing to place a requirement on UAS operators and remote pilots in the Open category to have an active geo-fencing function during UAS operations of C1-C3 UAS and C0 UAS with cameras, in addition to existing regulatory requirements for geo-awareness to be used. This will provide an additional layer of assurance that UAS operators do not attempt to disable or override this capability during operations.
We do not propose to apply this requirement to legacy UAS operations, given the challenges in applying this retrospectively.
—————————————
In addition, Article 20 sets out that UAS weighing less than 250g can be used in the A1 sub-category indefinitely, and UAS weighing less than 25kg can be used in A3 sub-category indefinitely. These requirements reflect regulatory changes made by the government, following our consultation and recommendation provided in 2022.28
6.3. In the Call for Input, we asked whether the CAA should change the transitional arrangements for legacy UAS (Question 8). Of those who provided a view, 74.8% of responses were positive, citing the impacts of the current transitional arrangements, such as the costs to UAS operators of needing to replace legacy UAS with new models.
6.4. Our view is also that the current transition period set out in Article 22, due to end on 1st January 2026, could create some challenging impacts for the UAS sector. For example, these arrangements could result in some UAS operators needing to replace their aircraft in a short timeframe. It could also have undesirable environmental impacts from many UAS being disposed of earlier than necessary and/or incorrectly, undermining the sustainability of the UAS sector.
6.5. However, we also consider that an indefinite transition period for all legacy UAS may delay the safety and security benefits of class-marked UAS. We expect this to become more important over time, as the UAS sector grows.
6.6. We are proposing to extend the transitional arrangements set out in Article 22 of UK Regulation (EU) 2019/947 to 2 years after the introduction of class-marking requirements on UAS manufacturers – 1st January 2028. This aims to mitigate some of the impacts on the UAS sector of the current arrangements, whilst also ensuring we transition to using safe and secure UAS in a timely manner. It aims to reduce the regulatory burden for UAS users, where possible.
6.7. As is described in Chapter 5, we are also proposing to continue to allow the use of legacy UAS under the arrangements of Article 20 (as described in paragraph 6.2), provided that the UAS is flown with active Remote ID from 1st January 2028 onwards (excluding UAS <250g without cameras). These proposals are summarised in the below table.

StepCH Posted at 12-15 04:08
In retrospect, I think the statements from Dji have been fairly consistent, especially considering the fact that the process hasn‘t been finalised yet. Bear in mind they don‘t actually have to do any of this for us. They could have simply left the M4P as a C0 only drone.
On the other hand, the wide range of interpretations has indeed led to a great deal of confusion on this forum.
Please read post #7 of this thread.

"they don‘t actually have to do any of this for us" actually they have, we are the customers, if it wasn't possible to declassify mini 4 pro, I wouldn't have bougth it. This drone costs money, when I pay the money, I want my thingy to do what I want, respecting or disrespecting the law is my responsibility, I'm not an apple customer "give us the money and we will tell you what you can do and what you can't"

https://www.dronelicense.eu/blog ... rone-pilots-in-2024

Drones without Cx label        Until the end of 2023        From 1 January 2024
< 250 grams                                      Subcategory A1        Subcategory A1

Doesn't your aircraft have a Cx label in the open category?
You can continue to fly without Remote ID.

Ok, now I know what this point 3 is all about, got clarification: if you remove the C0 label after 1st of January, not even applying for C1, then its undefined and thus only in the specific category. Mea culpa. Thread closed for me ^^

I don't get it, why is everyone relying on forums instead of reading the actual regulation... It took me no more than 30 min to find the coresponding articles and process them to my mind: (both post are mine)
https://forum.dji.com/forum.php? ... =300851&pid=3205781
https://forum.dji.com/forum.php? ... =300851&pid=3205862

after me, another guy has  found the regulation regarding "placed on the market" acc to EASA the day the model was initially introduced.So the real trap is, that DJI pays more to the marketing team, isntead of bunch of good lawyers to find the back door and this is EU regulation, there is always a back door left.
I've already declassified mine and have pages 29 and 246 from Regulation (EU) 2019/947  printed with me and I'm happy with my new drone