The mass that counts: MTOM, payload, thresholds
Almost every door in the ‘open’ category opens or closes on a mass. You still have to know which one: the catalogue figure is never the regulation's, and three words make all the difference.
Key points
- Article 2(22) defines the maximum take-off mass as the mass defined by the manufacturer or the builder, including payload and fuel. It is the mass at take-off, not the empty mass.
- The ‘open’ category stops at 25 kg at take-off (Art. 4(1)(b)). That is a category ceiling, not a class.
- The classes: C0 under 250 g including payload; C1 under 900 g OR energy transmitted to a human head below 80 J; C2 under 4 kg; C3 under 25 kg AND a maximum characteristic dimension of less than 3 m. The C3 dimension criterion is the one most often forgotten.
- The words ‘including payload’ are constitutive of the limit: 245 g on the scales plus a 12 g lens filter make 257 g, and class C0 is lost along with everything that depends on it.
- Point UAS.OPEN.060(1)(e) requires, where an additional payload is fitted, verifying that its mass exceeds NEITHER the MTOM defined by the manufacturer NOR the MTOM limit of its class. Those are two distinct ceilings, which do not necessarily coincide.
- Exceeding the class ceiling makes the aircraft lose the benefit of its label, and with it the subcategory of operation that follows from it.
- The 250 g of Article 14(5)(a) is a threshold for REGISTRATION of the operator, not a class, and it falls anyway as soon as a sensor can capture personal data.
- The 20 kg threshold is something else again: it belongs to Regulation (EC) No 785/2004, specific to aviation insurance law. Three thresholds, three regimes, never to be stacked.
The trap. The mass announced by a manufacturer is that of the aircraft in bare configuration. A bigger battery, a gimbal, propeller guards, and the threshold is crossed without any light coming on. The only measurement that counts is that of the aircraft as it takes off.
A diagram goes with this card: see it in the We Drone app.
Source
Delegated Regulation (EU) 2019/945 (CELEX 02019R0945, consolidated on 24/06/2025), Annex, Part 1, point 1, Part 2, point 1, Part 3, point 1, and Part 4, point 1; Implementing Regulation (EU) 2019/947 (CELEX 02019R0947, consolidated on 01/05/2025), art. 2, point 22), art. 4, paragraph 1, point b), art. 14, paragraph 5, point a), and Annex Part A, point UAS.OPEN.060(1)(e); Regulation (EC) No 785/2004 (CELEX 02004R0785, consolidated on 30/07/2020), art. 2, paragraph 2, point b)