Reconnaissance drone

2. Summary

SAFE Article 16(10)

Main reasons

• Origin unknown for 7 components (3.4 % of component cost).

Rulebook: Council Regulation (EU) 2025/1106 (SAFE), Article 16(10), as of 12 October 2026. Not yet expert reviewed.

EDIP Article 10(3)

Main reasons

• Origin unknown for 7 components (3.4 % of component cost).
• The association status of Norway, Iceland and Liechtenstein under EDIP is to verify.
• The result changes if Norway, Iceland and Liechtenstein do not count as associated countries.

Rulebook: Regulation (EU) 2025/2643 (EDIP), Article 10(3), as of 12 October 2026. Not yet expert reviewed.

EU-Canada agreement Article 5(8)

Components originating in Canada make up 4.7 % of the estimated cost of the components of the end product. The agreement allows this share to exceed 35 %.

Main reasons

• Origin unknown for 7 components (3.4 % of component cost).

Rulebook: Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(8), as of 12 October 2026. Not yet expert reviewed.

Ukraine Support Loan Article 13(4)(g)

Main reasons

• Origin unknown for 7 components (3.4 % of component cost).

The Commission has granted derogations from this rule under Article 13(5).

Rulebook: Regulation (EU) 2026/467 (Ukraine Support Loan), Article 13(4)(g), as of 12 October 2026. Not yet expert reviewed.

This is not a decision on eligibility. Only the contracting authority or funding body decides that. You sign your own declaration. Lodemark shows the calculation and the evidence behind it.

3. Calculation table

186 lines of version 3. Cost in euros at the rate entered. Components only count in the share; other lines are listed and left out.

Totals per rulebook

• SAFE Article 16(10): component cost 50,911.00 EUR, of which outside the set 14,003.00 to 15,715.00 EUR
• EDIP Article 10(3): component cost 50,911.00 EUR, of which outside the set 15,703.00 to 17,415.00 EUR
• EU-Canada agreement Article 5(8): component cost 50,911.00 EUR, of which outside the set 0 EUR
• Ukraine Support Loan Article 13(4)(g): component cost 50,911.00 EUR, of which outside the set 14,003.00 to 15,715.00 EUR

3a. Evidence grade summary

Result grade: D, Unknown, the weakest grade that carries cost.

Every line of grade C or D, with its cost:

Counting only grades A and B as known, the SAFE share outside would be up to 39.8 %.

4. Method

• SAFE Article 16(10): Cost base: the estimated cost of the components of the end product.
• EDIP Article 10(3): Cost base: the estimated cost of the components of the end product.
• Ukraine Support Loan Article 13(4)(g): Cost base: the estimated cost of the components of the defence product.
• EDIP: the type of action of Article Article 10(3), as chosen for this product.
• Origin: the customs origin of each component bought directly, at tier 1, with its basis and the grade of its evidence.
• Left out of the share: raw materials, services and final assembly.
• Unknown origin: counted outside the set for Meets, inside for Above; between the two the state is Needs review.
• Rounding: one decimal, half up; comparisons on exact amounts.
• Documents are read by AI. A value read counts once a person has checked it, or once the rules engine has shown that the result stays the same even if it were wrong; the rules engine calculates, and the same lines give the same result every time.

5. What drives the result

SAFE Article 16(10)

The largest lines that do not count under SAFE Article 16(10). Lodemark shows them; the customer decides what, if anything, to change.

EDIP Article 10(3)

The largest lines that do not count under EDIP Article 10(3). Lodemark shows them; the customer decides what, if anything, to change.

EU-Canada agreement Article 5(8)

The largest lines that do not count under EU-Canada agreement Article 5(8). Lodemark shows them; the customer decides what, if anything, to change.

Ukraine Support Loan Article 13(4)(g)

The largest lines that do not count under Ukraine Support Loan Article 13(4)(g). Lodemark shows them; the customer decides what, if anything, to change.

6. Control and establishment

The customer's answers for this product, as given. They are the customer's statements, signed on the declaration page.

7. Subcontractor derogation

The rulebook's derogation for subcontractors established outside the accepted places, as the customer answered it under the question on establishment.

The customer's answers for this product, as given. They are the customer's statements, signed on the declaration page.

8. Design authority

The maker's statement on design rights and on replacing restricted components, as answered.

The customer's answers for this product, as given. They are the customer's statements, signed on the declaration page.

9. Infrastructure location

Production and test sites with their country, as answered.

The customer's answers for this product, as given. They are the customer's statements, signed on the declaration page.

10. Security-interest sentence

No component comes from a country on the configured list.

The customer makes this assessment.

11. Equivalence

None claimed.

12. Open issues

Every point that keeps a result open, with its owner and due date.

13. Country annex

No Member State annex was added for this pack. Where a buyer's Member State asks for evidence that is not public, it is listed here as reported by the customer.

14. Evidence index

Every document this pack rests on, by reference: name, issuer, date and fingerprint. Copies are not part of the pack unless the customer chose to include them.

15. Audit trail

This is the first pack of this product: the changes since its first version.

No change was recorded.

16. Rule citations

The articles this pack applies, in their own words.

Council Regulation (EU) 2025/1106 (SAFE), Article 16(10)

10. The cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the end product. For the purpose of procurements supported by the SAFE instrument, no component shall be sourced from a third country that contravenes the security and defence interests of the Union and its Member States.

Text as of 12 October 2026. Not yet expert reviewed.

Regulation (EU) 2025/2643 (EDIP), Article 10(3)

3. For procurement carried out pursuant to Articles 11, 13 and 35 which is supported by Union funding, the cost of components originating outside the Union and associated countries shall not be higher than 35 % of the estimated cost of the components of the end product. No component shall be sourced from third countries that contravene the security and defence interests of the Union and its Member States.

Text as of 12 October 2026. Not yet expert reviewed.

Agreement between the European Union and Canada on participation in the SAFE instrument (OJ L, 2026/445), Article 5(8)

8. The cost of components originating in Canada may exceed 35 % of the estimated cost of the components of the end product. The cost of components originating either in the Union, an EEA EFTA State or Ukraine must not be lower than 20 % of the estimated cost of the components of the end product. The cost of the components from third countries must not exceed the cost of components originating in the Union, an EEA EFTA State, or Ukraine, and in any case may not exceed 35 % of the cost of the components of the end product.

Text as of 12 October 2026. Not yet expert reviewed.

Regulation (EU) 2026/467 (Ukraine Support Loan), Article 13(4)(g)

(g) the cost of components originating outside the Union, EEA EFTA States and Ukraine shall not be higher than 35 % of the estimated cost of the components of the defence product. No component shall be sourced from a third country that contravenes the security and defence interests of the Union and its Member States;

Text as of 12 October 2026. Not yet expert reviewed.

Council Regulation (EU) 2025/1106 (SAFE), Article 16(4)

4. By way of derogation from paragraph 3, in order to take into account industrial cooperation with non-EU partners, common procurements that involve a subcontractor which is allocated between 15 % and 35 % of the value of the contract, and that is not established or doesn’t have its executive management structures in the Union, EEA EFTA State or Ukraine, shall be eligible for support under the SAFE instrument providing that at least one of the following conditions are met: (a) a direct contractual relationship related to the defence product has been established between the contractor and that subcontractor prior to the date of entry into force of this Regulation; (b) the contractor commits to studying, within two years, the feasibility of replacing the input provided by that subcontractor with an alternative, restriction-free input originating in the Union, EEA EFTA States or Ukraine, and meeting technical and time requirements.

Text as of 12 October 2026. Not yet expert reviewed.

Council Regulation (EU) 2025/1106 (SAFE), Article 16(11)

11. For defence products related to category two as referred to in Article 1, second subparagraph, point (b), contractors shall have the ability to decide, without restrictions imposed by third countries or by third-country entities, on the definition, adaptation and evolution of the design of the defence product procured, including the legal authority to substitute or remove components that are subject to restrictions imposed by third countries or by third-country entities.

Text as of 12 October 2026. Not yet expert reviewed.

Regulation (EU) 2025/2643 (EDIP), Article 10(5)

5. Recipients of Union funding or, where relevant, contractors, shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence products concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities.

Text as of 12 October 2026. Not yet expert reviewed.

Regulation (EU) 2025/2643 (EDIP), Article 12(4)

4. For the production of ammunition and missiles, recipients of Union funding or relevant governmental authorities of the Member States concerned shall have the ability to decide, without restrictions imposed by non-associated third countries or by non-associated third-country entities, on the definition, adaptation and evolution of the design of the defence product concerned, including the legal authority to substitute or remove components that are subject to restrictions imposed by non-associated third countries or by non-associated third-country entities, or alternatively, by way of derogation from Article 10(5), shall have obtained a legally binding commitment from the non-associated third country or the non-associated third-country entity concerned that they will obtain such ability to decide within a reasonable timeframe commensurate with the complexity of the action concerned, and in any event no later than 31 December 2033.

Text as of 12 October 2026. Not yet expert reviewed.

17. Declaration page

A template for the maker's own declaration. Lodemark does not sign.

• The share outside the set under SAFE Article 16(10): 27.5 to 30.9 %.
• The share outside the set under EDIP Article 10(3): 30.8 to 34.2 %.
• The share outside the set under Ukraine Support Loan Article 13(4)(g): 27.5 to 30.9 %.

The declarant states, as answered Yes in this pack:

• SAFE Article 16(10): Answered Yes, for you to sign in the evidence pack: Common procurement, Establishment and management: the EU, Control: the EU, Sites: the EU, Product category: category two, Design authority: the EU, Security and defence interests.
• EDIP Article 10(3): Answered Yes, for you to sign in the evidence pack: Actions not funded, Establishment and management: the EU, Control: the EU, Sites: the EU, Design authority: the EU, Whole action, Security and defence interests.
• EU-Canada agreement Article 5(8): Answered Yes, for you to sign in the evidence pack: Contract under the agreement, Establishment and management: the EU, Control: the EU, Sites: the EU, Product category: category two, Design authority: the EU, Security and defence interests.
• Ukraine Support Loan Article 13(4)(g): Answered Yes, for you to sign in the evidence pack: Product schedule, Establishment and management: the EU, Control: the EU, Sites: the EU, Product category: category two, Design authority: the EU, Security and defence interests.

No tender condition was set.

Name, role, company, date

18. Limitations

• Not a decision on eligibility and not legal advice.
• Based on data the customer supplied and warrants.
• Documents checked only as marked in the index.
• No classified or export-controlled data processed.

This is not a decision on eligibility. Only the contracting authority or funding body decides that. You sign your own declaration. Lodemark shows the calculation and the evidence behind it.

The same data as CSV and JSON files, in the data model's words, come with this pack.