Introduction
The 鈥榣ow-altitude economy鈥� has in recent years been booming in China, with the technical development and commercial operations of unmanned aircraft systems (UAS) as its centerpiece. Arguably, aided by the industry effort and favorable government policies, China is rapidly developing its domestic 鈥榣ow altitude鈥� market based on UAS operations. For example, in Shenzhen, 309 air routes have been established for regular UAS delivery services, with 776,000 delivery flights operated in 2024 and more than 548,000 delivery flights taking place during the first eight months of 2025. Similarly, in Shanghai, the world鈥檚 first regular urban sightseeing service operated by electric vertical take-off and landing aircraft (eVTOL aircraft) is about to commence. Behind the rapid progression of UAS operations in China, the so-called Unmanned Civil Aviation Experimental Zones (UCAEZs, hereinafter Experimental Zones) play a pivotal role. This commentary will examine: the organizational structure of Experimental Zones; how they promote standardization and technical rulemaking and their legal basis; and the potential challenges created by these novel activities. The objective of this commentary is to introduce the Chinese practice of UAS industry rulemaking to a wider audience and contribute to the global discussion on UAS industry regulations development.
What are Experimental Zones?
Experimental Zones are regulated and facilitated spaces that are separated from other air traffic and used exclusively for UAS test operations. In 2020, the Civil Aviation Administration of China (CAAC) established Experimental Zones to promote the development of the UAS industry. By 2022, a total of 17 Experimental Zones have been established throughout China. The purposes of establishing Experimental Zones are:
a. to provide platforms for UAS manufacturers in the industry to test their designs;
b. to provide a platform for UAS operators to gain experience and data through test operations;
c. to develop a coordinated UAS regulatory framework among civil, military aviation authorities, and local governments, and
d. to develop airworthiness, navigation, and air traffic management standards for specific operating scenarios.
Experimental Zones have a unique organizational structure to fulfill these purposes. A management corporation owned by the local government is responsible for the day-to-day operations of an Experimental Zone. Industry players who wish to establish in the Experimental Zone can contact the management corporation to rent hangars, warehouses, test fields, and other infrastructure. The management corporation is also responsible for flight information services and coordinating the test airspace. All private companies involved in the UAS industry supply chain can establish themselves in the Experimental Zone, subject to joint supervision by the CAAC and the local government.
How Experiential Zones generate technical standards, and their legal basis
Experimental Zones function as test grounds for a range of diverse operational scenarios, depending on their geographic or social features. For example, the Experimental Zone located in Shanghai focuses on inter-island logistics operations over the East China Sea, while the Hangzhou Experimental Zone focuses on urban delivery operations. Likewise, each operation scenario has specific requirements for technical standards. For example, Shanghai requires a reinforced datalink for beyond-visual-range communication, and multiple backup landing points for potential diversions over-water. In contrast, Hangzhou requires noise-abatement procedures and special route planning to ensure that UAS operations do not pose hazards or inconvenience to urban communities.
This opens the question of who is responsible for developing these standards. In China, UAS operations are regulated by the Interim Regulation on the Administration of the Flight of Unmanned Aircraft (Interim Regulation), and aided by multiple normative and policy documents developed by the CAAC. These documents are critical elements of national safety oversight system that contain 鈥榯echnical guidance, tools, and provision of safety-critical information鈥� (CE-5) as clarified by the International Civil Aviation Organization (ICAO). Technical standards provide the specifications and procedures that UAS design and operations must follow, as Interim Regulations and normative documents refer to technical standards as means for showing compliance. Instead of the traditional approach of the civil aviation authority developing detailed rules for all operational scenarios and asking all stakeholders to comply, industry players operating in the Experimental Zones take the lead in generating technical standards.
This is pursuant to the Standardization Law of the People鈥檚 Republic of China;
Article 5: 鈥淸鈥 Competent administrative authorities under the State Council shall, in line with their respective functions, be in charge of standardization in their respective departments and industries [鈥鈥�
Article 6: 鈥淣ational standards shall be formulated for the technical requirements that need to be unified nationwide. [鈥 In the absence of national standards, technical requirements for a certain industry need to be unified, industry standards may be formulated. Industry standards shall be formulated by competent administrative authorities under the State Council and reported to the department of standardization administration under the State Council for the record, and shall be annulled on publication of the national standards [鈥鈥�
The 鈥渃ompetent administrative authorities under the State Council鈥� are therefore empowered to oversee standardization of their respective departments and enforce national standards when applicable. When no national standards are applicable, administrative authorities have the discretion to adopt industry standards. As a 鈥渃ompetent administrative authority under the State Council,鈥� the CAAC oversees standardization in civil aviation, including that for UAS.
However, pursuant to Article 16, 18, and 19 of the Regulation on Civil Aviation Standardization (CCAR-375SE-R2), when there are no industry standards applicable, aviation enterprises shall develop their own internal standards, and they are entitled to request the CAAC for new industry standards. In the case of the UAS industry, the CAAC established a general framework for standardization in 2022, which includes three main blocks: UAS initial airworthiness certification, UAS operations, and UAS services. Many of the individual standards established under these guidelines are based on requests and internal standards submitted by industry players operating in the Experimental Zones. It is also common for companies and associations to jointly submit standards they concur with as 鈥榞roup standards.鈥� Other industry players are free to support such standards or file their comments during the public consultation session. The whole procedure is arguably transparent and evidence-based.
Take, for example, the inter-island UAS operation standards produced by the Shanghai Experimental Zone. The company operating the inter-island logistics services is Phoenix Wings Logistic Drones (Shenzhen) Co., Ltd., and the management corporation of the Experimental Zone is Shanghai New Jinshan Century Aviation Development Co., Ltd. The two companies collaborated in establishing the landing points and air routes to the Zhoushan islands, located 100 kilometers away from Shanghai. By 2024, the Shanghai Experimental Zone had established regular seafood logistics services between Shanghai and the Zhoushan Islands, operating at a frequency of over 50 flights per week on eight air routes.
Based on their successful operations, Phoenix Wings Logistic Drones (Shenzhen) Co., Ltd. and Shanghai New Jinshan Century Aviation Development Co., Ltd. jointly submitted group standards to the CAAC regarding the setup of landing points and air routes for inter-island UAS operations. Another UAS company, based in the Experimental Zone, Shanghai Autoflight Co., Ltd., joined as a co-author of the group standards. Although its focus is on large unmanned eVTOL aircraft used for passenger transport, Autoflight Co. Ltd. considers some of the standards useful for their operations over water and in line with its own test experience. The standardization department of the CAAC then examined and approved the group standards, which became draft industry standards for public consultation. In 2023, the CAAC adopted the draft standards as a new civil aviation industry standard titled 鈥楪eneral Requirements for Civil Unmanned Aircraft Systems Logistics Operation Part 1: Island Scenario鈥� (MH/T 2014-2023). The same standardization process is likely to repeat for other major UAS operation scenarios identified by the CAAC.
Contributions by Experimental Zone operations
Experimental Zone operations offer four advantages in promoting industry standardization and rulemaking. First, through a trial-and-error testing phase in various Experimental Zones, private operators would rapidly gain experience and data in adapting their technology to the actual operational environment. Such experimental data is invaluable for the rulemaking process, but usually not easily accessible to aviation authorities.
Second, as the standardization is generated by industry players instead of being imposed by State authorities, it is easier to induce compliance. Furthermore, the standards are arguably based on real, practical operations and, therefore, easier to understand for operators. In contrast, State-imposed standards can be alien to industry practice, and industry players may need additional guidance from the authorities about what kind of practice or approach is considered compliant. For example, currently, the UAS industry in Europe appears to face difficulties, as EASA has slowed down in producing guidance materials for its rigorous UAS regulations. Industry players may need to wait until EASA examines and certifies their operations on a case-by-case basis, which can take a considerable amount of time.
Thirdly, Experimental Zone operations provide valuable regulatory experience for coordination among authorities. UAS operations involve multiple aspects regulated by different authorities. Civil and military aviation authorities regulate airspace access and traffic management, while local governments manage social impacts. The local police department oversees the security aspect, etc. These authorities rarely work together due to their different scopes of responsibility, but they must coordinate closely to ensure effective oversight of UAS operations.
Finally, operations in the Experimental Zones can offer financial sustainability to industry players. For any UAS design and services that need certification, it can be a very time-consuming process. For example, an urban UAS delivery service can take between three to six years to obtain its Air Operator Certificate (AOC). It means that during this time, there is no certified commercial operation, and therefore no profit. Many industry players struggle to maintain their financial status due to high development costs and slow certification processes. Experimental Zones, however, support limited operations for remuneration. Experiences in China demonstrate that if local communities give consent to limited UAS operations and the local government can provide oversight on social impacts, industry players can offer test UAS services for remuneration. For example, Meituan, one of China鈥檚 market leaders in food delivery and quick commerce, operated urban food delivery services in various Experimental Zones before it gained an AOC in April 2025. While it was insufficient to cover the entire research or operation cost, it was arguably better than no profit at all.
Overall, Experimental Zones offer unique advantages in gaining operational and regulatory experience and provide financial revenue for industry players during certification processes.
Regulatory Challenges of Experimental Zones
There are, however, two potential challenges for relying on Experimental Zones to foster the UAS industry. First, access to Experimental Zones is limited; thus, not all industry players can establish themselves in these zones. Those who gain access enjoy initial advantages, including policy support, test operation opportunities, and a significantly stronger voice in drafting industry standards. This may lead to market distortion. A potential solution would be to establish as many Experimental Zones as possible for all types of UAS operations. However, as the State owns the airspace and land resources, it would require considerable local government investment to allocate proper land and airspace resources to these new Experimental Zones. Not to mention that many places in China lack suitable land or airspace resources for UAS operations.
Second, gaps may emerge during the transition from limited test operations in the Experimental Zones to actual commercial operations. Experiences have shown that actual operations involve more complicated challenges. For example, setting up an urban UAS delivery service would include negotiations with various social entities regarding air route design, establishing landing points, and installing navigation infrastructure. It may also affect other social aspects, such as data management and privacy issues. A potential solution would be to create a test environment with actual communities to be served by the UAS, but this depends on whether the local community would give consent and whether the local government and aviation authority can provide sufficient oversight. This may not be a serious obstacle for Chinese practice, but it may not be the case for other States that would like to replicate the Experimental Zone scheme.
Conclusion
The Experimental Zone model adopted by the Chinese UAS industry offers valuable insights into promoting industry standardization and technical rulemaking. The Experimental Zone model relies on a unique organizational structure to provide a segregated, regulated, and facilitated space for UAS test operations. The experience and data gained through trial and error in the Experimental Zones have driven the development of industry standards, thanks to a transparent and evidence-based rulemaking procedure under Chinese law. Experiences have shown that the Experimental Zone model offers significant advantages for both industry players and regulators; however, some challenges require further attention to ensure future market access and a smooth transition to commercial operations. Undoubtedly, integration of UAS into our daily lives is no longer a distant vision. The Chinese practice in facilitating its UAS industry and its standardization may serve as a good reference for a global initiative fostering safe and efficient UAS regulation and integration.
Hao Zhou, DCL student at the Institute of Air and Space Law at 51吃瓜网.
In keeping with 51吃瓜网鈥檚 commitment to academic freedom, the Institute of Air and Space Law supports the free expression of ideas in its publications. The views expressed in this commentary are solely those of the author and do not reflect the official positions or views of the Institute of Air and Space Law, the Faculty of Law, or 51吃瓜网. Furthermore, authors represent only themselves; they do not represent their countries of nationality nor any organizations with which they may be affiliated.
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