Navigating New Skies: Understanding China's Export Controls and FPV Drones

Navigating New Skies: Understanding China's Export Controls and FPV Drones

Posted on: [2025-04-15]
Author: FPV Prokit Team

The world of FPV drones is constantly evolving, not just in technology but also in the regulatory landscape. Recently, China implemented a new, consolidated Dual-Use Item Export Control List (中华人民共和国两用物项出口管制清单), which came into effect alongside updated regulations in 2024. As a leading source manufacturer, FPV Prokit believes it's crucial for us and our global community to understand these regulations and how they might apply to the FPV gear we love.

This post aims to shed light on the key aspects of these controls, specifically concerning FPV drones, based on the official list.

What are Dual-Use Items?

Dual-use items are goods, software, and technologies that can be used for both civilian and military purposes. Governments regulate their export to prevent potential misuse, particularly concerning national security and non-proliferation of sensitive technologies.

China's Consolidated Export Control List

The new list integrates regulations previously scattered across different categories (like nuclear, missile, chemical, biological) into a unified framework. It uses a coding system (e.g., 9A012) to categorize items based on industry sector, item type (system, test equipment, material, software, technology), and control reason.

How Does This Affect FPV Drones?

The most relevant section for FPV drones falls under Category 9: Aerospace and Propulsion (第 9 类 航空航天与推进). Within this, Section 9A012 specifically addresses "Unmanned aerial vehicles" ("无人驾驶航空器"), "Unmanned airships" ("无人驾驶飞艇"), and related equipment and components.

Let's break down the key criteria in Section 9A012 that could apply to certain UAVs:

• Control Beyond Visual Range & Endurance: Section 9A012.a controls UAVs that can be flown controllably outside the operator's "natural visual range" ("自然视距") and meet specific performance thresholds. These include:

  • 9A012.a.1: Maximum "endurance time" ("续航时间") of 30 minutes or more but less than 1 hour, and capable of stable, controlled flight in wind gusts of 46.3 km/h (25 knots) or more.

  • 9A012.a.2: Maximum "endurance time" of 1 hour or more.

• Specific Payloads & Components: Section 9A012.c controls specific high-performance payloads like certain thermal imagers, Synthetic Aperture Radar (SAR), target designation lasers, and high-spec inertial measurement units. Section 9A012.e controls specific communication equipment enabling control ranges beyond 50km or one-station-to-multiple-aircraft control (>10 aircraft).

• Range Threshold: Another section, 9A501, controls UAVs not captured by 9A012 but having a "range" ("射/航程") of 300 km or more.

• Flight Controllers: While not explicitly detailed under 9A012 payloads (due to potential overlap with Category 7 controls), Section 7A103.b under Category 7: Navigation and Avionics (第 7 类 导航和航空电子) controls autopilots for "Unmanned aerial vehicles".

Important Exclusion: The regulations (9A012.a and related notes) explicitly state that they do not control model aircraft or model airships ("说明：9A012.a、9A012.b.1、9A012.d 项不管制模型飞机或模型飞艇。").

FPV Prokit's Perspective: What This Means for FPV Enthusiasts

As a source manufacturer deeply involved in the FPV community, here's our take:

1. Most Standard FPV Drones Likely Unaffected: Typical FPV drones used for racing, freestyle, and general hobbyist cinematography generally have flight times under 30 minutes. They usually don't carry the high-spec payloads listed in 9A012.c and certainly don't meet the 300 km range requirement of 9A501. Furthermore, they often operate closer to the concept of "model aircraft," which are noted as exclusions in the list.

2. Focus on Capability: The regulations target UAVs with specific, high-level capabilities (long endurance, long-range control, specific sensors, high-altitude engines). Standard FPV components like basic flight controllers, motors, ESCs, and standard video transmission systems generally fall well below these thresholds.

3. Advanced Systems Require Scrutiny: High-endurance, long-range FPV setups, or drones equipped with sophisticated sensors (beyond standard FPV cameras) or very long-range control links (>50km), might potentially approach the criteria defined in 9A012 or involve components controlled under other sections (like 7A103.b for advanced autopilots). Manufacturers and exporters of such advanced systems need to carefully evaluate their products against the list's specific parameters.

4. Compliance is Key: FPV Prokit is committed to understanding and complying with all relevant export regulations. We continuously monitor the regulatory landscape to ensure our operations align with current requirements.

5. Buyer Responsibility: While we strive to comply with export rules from China, international customers must also be aware of and responsible for complying with the import regulations of their own countries. Dual-use regulations can exist globally, and importing controlled items may require specific licenses or permissions in your jurisdiction.

Conclusion

China's new Dual-Use Item Export Control List provides a consolidated framework for regulating potentially sensitive technologies. While the list includes specific categories for UAVs, the detailed technical thresholds mean that most conventional FPV drones and components used by hobbyists are unlikely to be subject to these specific export controls. The focus appears to be on systems with significant endurance, range, payload, or communication capabilities that could potentially have military applications.

FPV Prokit remains dedicated to providing high-quality FPV gear while operating responsibly and transparently within the global regulatory environment. We encourage all participants in the FPV community, especially those involved in international trade, to stay informed about both export and import regulations.

Disclaimer: This blog post is intended for informational purposes only and does not constitute legal advice. Regulations can be complex and subject to interpretation and change. Please consult the official documentation or legal counsel for specific guidance regarding export or import compliance.