Issuer: Incutec BV, Stapelhuisstraat 15, 3000 Leuven, Belgium (KBO 1038.934.039) Effective: 8 June 2026 Last reviewed: 18 April 2026 Review cycle: annually, or on any material change to our product scope, the regulatory environment, or our distribution channels.
Incutec BV designs and supplies civilian electronics. This policy sets out how we classify those products under EU export control law, which end-uses we refuse, and where we will and will not ship. It applies to every product we sell, including the OpenDrone line.
We publish it because we think anyone buying drone components deserves to know where the company behind them stands, and because our webshop terms commit us to it.
Our position
We build for civilian use. We do not sell into military supply chains, and we do not want our parts in weapons.
That is a founder policy, not a legal minimum. Nothing below is a claim that the law forces us to refuse this business. We refuse it anyway.
Export control classification
We have self-classified our products against Annex I of Regulation (EU) 2021/821, the EU Dual-Use Regulation. The assessment was carried out on 18 April 2026 and covers the following:
| Product family | Function | Radio |
|---|---|---|
| OpenFC | Flight controller: microcontroller, inertial measurement unit, on-screen display | 2.4 GHz ISM on the full variant only |
| OpenESC | Brushless motor driver (electronic speed controller) | None |
| OpenRX | ExpressLRS radio receiver | 868 MHz (EU) and 2.4 GHz ISM, within EN 300 220 and EN 300 328 power limits |
The findings:
- Category 7, navigation and avionics. Our boards use commercial MEMS inertial sensors with open-source firmware. They fall orders of magnitude short of the performance thresholds in Category 7A, which describe military-grade inertial navigation. Not controlled.
- Category 9A012, unmanned aerial vehicles. This entry controls complete UAV systems meeting specific endurance, range and payload thresholds. We sell individual components, not systems, and hobby multirotor hardware does not approach those thresholds. Not controlled.
- Category 5, telecommunications and information security. Our radio links run on publicly available, unlicensed ISM bands using standard published protocols. There is no military-grade spread spectrum, anti-jamming, or controlled cryptography. Not controlled.
Conclusion: none of our products are listed in Annex I of Regulation (EU) 2021/821. No export licence is required for commercial sales to non-sanctioned destinations.
Being unlisted is not the end of the analysis. Article 4 of the same regulation allows the competent authority to require a licence for unlisted items where a military or weapons-of-mass-destruction end-use is known or suspected. We treat that as a live obligation, not a formality.
Permitted end-use
We supply goods for:
- consumer hobby and recreational use;
- educational, research and maker contexts;
- non-defence commercial use, including industrial control, robotics and prototyping.
Excluded end-use
We do not knowingly sell, supply or distribute goods for use in:
- armed conflict zones where civilian unmanned aerial vehicle components are demonstrably used in kinetic, loitering, or intelligence, surveillance and reconnaissance roles;
- weaponised unmanned aerial systems, including those carrying lethal or sub-lethal payloads;
- military procurement programmes, defence ministries, defence prime contractors, or their direct subcontractors, where the contract end-use is military;
- paramilitary, mercenary, or private military company end-users;
- any end-use contravening Regulation (EU) 2021/821 (dual-use), Regulation (EU) 833/2014 (Russia), Regulation (EC) 765/2006 (Belarus), or any successor instrument.
Where we ship
Destinations we block. Our checkout does not ship to the Russian Federation, Belarus, Iran, Syria, North Korea, or Cuba, nor to Crimea or the other occupied territories of Ukraine. Several of our products contain components on the EU Common High Priority Items list, which makes supply to Russia and Belarus prohibited at component level. This is not a judgement we make case by case.
Conflict zones. Beyond the sanctions lists, we maintain an internal block list of active-conflict territories, reviewed quarterly against the Armed Conflict Location and Event Data Project and the Uppsala Conflict Data Program. It applies uniformly to a territory in active conflict. We do not classify parties to a conflict and we do not take sides through this list.
Everywhere else. We ship normally, subject to the screening below.
How we screen
- Consumer orders are screened against the EU consolidated sanctions list.
- Business orders additionally undergo end-use review. Where the buyer is established outside the EU and outside the partner countries listed in Annex VIII of Regulation (EU) 833/2014, our contract includes the no-re-export-to-Russia clause required by Article 12g of that regulation.
- Larger business orders to those destinations require a signed end-user statement before we ship.
- Placing an order constitutes acceptance of the acceptable end-use clause in our General Terms and Conditions.
We may decline any order, without giving reasons, where the end-use is unclear or the circumstances of the order do not add up. We would rather lose a sale than guess.
What this policy does not do
To be honest about its limits, this policy:
- does not classify any party to any conflict;
- does not restrict purchases by people employed at defence-related organisations who are buying privately, for their own non-military use;
- does not guarantee that goods we supply will never reach a restricted end-use through channels outside our control;
- does not restrict what our employees, contractors or shareholders support in a personal capacity.
Our design files are published under an open licence. Anyone may build from them. We control what we sell and to whom, and we are straightforward that this is where our control ends.
Contact
Questions about this policy, or about a specific order, go to info@incutec.eu.
Our competent authority for export control is the Flemish Department of Chancellery and Foreign Affairs, Strategic Goods Control Unit (Dienst Controle Strategische Goederen).