由 caicai8478 I. Direct restrictions under the framework of international sanctions
Export controls by the United States and its allies
In July 2023, the U.S. Department of Commerce included 13 Chinese drone companies in the Entity List (including DJI, Autel, etc.)
Prohibit the export of any drones and related parts containing more than 25% of U.S. technology to Russia and Belarus
Canada, the United Kingdom, Australia and other allies simultaneously implemented similar restrictions
Amendment to EU Regulation No. 833/2014
Prohibit the export of all dual-use drones to Russia (regardless of origin)
Special restrictions on the export of drones with the following characteristics:
Maximum flight time ≥30 minutes
Operation distance ≥5 kilometers
Can carry ≥5 kg of payload
II. Transit trade restrictions in third countries
Strengthen compliance review in transit countries
Traditional transit hubs such as Turkey, Kazakhstan and the United Arab Emirates strengthen customs inspections
Require the provision of an End-User Declaration (End-User Declaration) Certificate)
Some Central Asian countries have suspended drone transit permits
Payment channel restrictions
SWIFT system sanctions on Russian banks lead to payment difficulties
Third-party payment platforms (such as PayPal) freeze drone trading accounts involving Russia
III. Technology blockade and supply chain constraints
Embargo on key components
The United States bans the sale of high-precision IMUs (inertial measurement units) and military-grade photoelectric sensors to China
The Netherlands restricts the export of ASML lithography machines, affecting independent chip research and development
Termination of software services
International mainstream flight control software (such as ArduPilot) stops providing services to Russian IPs
Cloud data processing platforms (such as DJI Fly) restrict geo-fence updates in conflict areas
IV. New barriers to market access
New regulations for the European market
EU effective in December 2023 Regulation 2023/2405:
Requires all incoming drones to be equipped with a remote ID system
Mandatory installation of geofencing
UAVs of level C2 and above require EU type certification
US “Blue Drone” program
List of “trusted suppliers” approved by the Department of Defense (excluding Chinese companies)
Government agency procurement must pass NDAA compliance review
V. Logistics and insurance barriers
International transportation restrictions
IATA strengthens lithium battery air transportation supervision (UN38.3 test report requirements)
Major carriers such as Maersk and DHL suspend Russian drone cargo
Insurance coverage Cover excluded
London insurance market lists drones as “high-risk goods”
War insurance premiums increased by 300%-500%
VI. Chinese companies’ response strategies
Compliance system construction
Establish a complete ECCN (Export Control Classification Number) identification process
Develop independent and controllable supply chain alternatives (such as Huawei HiSilicon chip alternatives)
Market diversification layout
Expand emerging markets such as the Middle East (Saudi Arabia, UAE), Latin America (Brazil, Mexico)
Develop non-sensitive application areas such as agricultural drones and inspection drones
Technical adaptability adjustment
Develop an offline version of the flight control system
Introduce EDR-compliant 155 standard regional customized models
VII. Forecast of future regulatory trends
The upcoming global drone trade agreement (expected in 2024Q3)
It is possible to establish an international drone export registration system
Implement a mandatory end-use monitoring system
China’s local policy response
The Ministry of Commerce’s revision of the “UAV Export Control Measures” (under solicitation of opinions)
It is possible to establish a “white list” enterprise system in exchange for partial market access
Special note: According to the Announcement No. 12 of the Ministry of Commerce of China in 2023, the export of drones with a maximum take-off weight of ≥1.5kg to conflict areas requires an application for a dual-use export license (processing period 15-20 working days). It is recommended that export companies regularly check the “Catalogue of Dual-Use Items and Technology Import and Export License Management” for updates.