A question people ask · answered against the Corpus of 2026-08-29
Does my drone need an export licence?
It depends on the ECCN and the destination country, not on the drone alone.
A licence requirement is the product of 2 things: the classification of the item, and where it is going. Neither answers the question by itself.
First fix the entry. If the drone is on 9A012, it carries reasons for control that reach a wide set of destinations. If it falls to EAR99, most commercial shipments to most countries move without a licence — but never to an embargoed destination, a denied party, or a prohibited end use.
Then take the ECCN to the Commerce Country Chart at Supplement No. 1 to Part 738 and read across the reasons for control. That crossing is what tells you whether a licence is required for that country.
Then check whether a licence exception applies. Exceptions are narrow and conditional, and each has its own eligibility test. An exception you cannot evidence later is worth nothing when someone asks.
What decides it
- 01What is the ECCN of the drone as configured for shipment?
- 02Which country is the consignee in, and who is the end user?
- 03What is the stated end use, and is anything about it military?
- 04Does any licence exception apply, and can you evidence its conditions?
Free, no account. Dossier $249 if you want the record.
The entries this turns on, opening text as it reads today
a. “UAVs” or unmanned “airships”, designed to have controlled flight out of the direct 'natural vision' of the 'operator' and having any of the following: a.1. Having all of the following: a.1.a. A maximum 'endurance' greater than or equal to 30 minutes but less than 1 hour; and a.1.b. Designed to take-off and have stable controlled flight in wind gusts equal to or exceeding 46.3 km/h (25 knots); or a.2. A maximum 'endurance' of 1 hour or greater; Technical Notes: 1. For the purposes of 9A012.a, 'operator' is a person who initiates or commands the “UAV” or unmanned “airship” flight. 2. For the purposes of 9A012.a, 'endurance' is to be calculated for ISA conditions (ISO 2533:1975) at sea level in zero wind.3. For the purposes of 9A012.a, 'natural vision' means unaided human sight, with or without corrective lenses. b. Related equipment and “components”, as follows: b.1 [Reserved] b.2 […]
(c) "Items subject to the EAR" consist of the items listed on the Commerce Control List (CCL) in part 774 of the EAR and all other items which meet the definition of that term. For ease of reference and classification purposes, items subject to the EAR which are not listed on the CCL are designated as "EAR99." Items subject to temporary CCL controls are classified under the ECCN 0Y521 series (i.e., 0A521, 0B521, 0C521, 0D521, and 0E521) pursuant to § 742.6(a)(8) of the EAR, while a determination is made as to whether classification under a revised or new ECCN, or an EAR99 designation, is appropriate.
Skenai never shows unquoted regulation. This page is research and documentation, not legal advice, and it is not a determination on your product.
People who ask this also ask
- Is an FPV drone ITAR?Rarely. Most civilian FPV and industrial drones are EAR, and 9A012 is the entry to check first.
- What does EAR99 mean?It means the item is subject to the EAR but is not listed on the Commerce Control List. It is a residual, not a clearance.
- What is the difference between ITAR and EAR?Two regimes, two regulators. ITAR is State and covers defence articles; EAR is Commerce and covers dual-use items.
A general answer is not your answer.
The Interview asks 5 to 9 questions about your product, only the ones the entries turn on, and names the Determination free. The Dossier is the dated, cited record of how it was reached — the thing an investor or a prime asked for.
Free, no account. Dossier $249 if you want the record.