Drone motors: prior authorization for Armenia, Kazakhstan, and Kyrgyzstan

The Ministry of Foreign Affairs and International Cooperation has subjected the export of internal combustion engines intended for the aviation sector and related components to Armenia, Kazakhstan, and Kyrgyzstan to prior authorization. The decree of September 1, 2026, signed by Minister Antonio Tajani, is published in the Official Gazette of the Italian Republic, General Series no. 236 of October 10, 2026, with the official reference 26A05300. The measure was created to counter the risk that Italian components be re-exported to the Russian Federation and the Republic of Belarus and end up in unmanned aerial vehicles used in the aggression against Ukraine.

The provision implements Article 9 of the Legislative Decree of December 15, 2017, no. 221, which regulates the export control of dual-use products and operations relating to proliferating materials. This is not an absolute novelty: the Decree of the Minister of Foreign Affairs and International Cooperation of July 10, 2023, had already introduced prior authorization for the same engines and components with final destinations in Armenia, Iran, Kazakhstan, or Kyrgyzstan. The new text restricts the geographical scope and extends the obligation, after the National Authority UAMA, with note no. 0147648 of August 7, 2026, carried out the communication provided for by Article 9, paragraph 2, of the aforementioned legislative decree and no observations were received from the consulted administrations within the following ten working days.

What is subject to authorization

Article 1, paragraph 1, of the decree identifies two categories of products for which export, the provision of brokerage services, and technical assistance require prior authorization when the final destination is Armenia, Kazakhstan, or Kyrgyzstan:

• reciprocating or rotary piston engines with spark ignition, i.e., internal combustion engines, usable in the aviation sector;
• parts recognizable as intended, exclusively or primarily, for the engines mentioned above.

By “aviation sector,” the decree intends a broad perimeter: airplanes, unmanned aerial vehicles (UAVs), helicopters, autogyros, hybrid aircraft, and radio-controlled models. The text justifies the choice by noting that these engines and their parts do not appear in the list of dual-use products in Annex I of Regulation (EU) 2021/821, although they may be used for the construction of drones designed for military use.

The procedure for exporters and customs controls

Before carrying out the operations, the exporter must submit an application for authorization to the National UAMA Authority, pursuant to Article 4 of Legislative Decree no. 221 of 2017 and Article 9 of the same decree. The provisions take effect from the day following their adoption and remain in force for three years. Regarding controls, Article 2, paragraph 2, establishes that for products arriving at customs after July 10, 2026, and lacking authorization, the Customs and Monopolies Agency shall not proceed with clearance and shall invite the exporter to submit an application. The decree is communicated to the administrations that make up the Consultative Committee referred to in Article 5, paragraph 3, of Legislative Decree no. 221 of 2017 and to the European Commission.

Why three countries and no longer Iran

The narrowing of the list compared to 2023 is explained by two considerations contained in the premises. On one hand, Armenia, Kazakhstan, and Kyrgyzstan are part of the Eurasian Customs Union, which also includes the Russian Federation and Belarus: components exported to these countries therefore present risks of re-export and incorporation into military products in violation of the arms embargo. On the other hand, the export of the same engines and components to Iran is now prohibited by Regulation (EU) no. 2023/1529 and cannot be carried out even with government authorization, except for the derogations provided for in Article 2, paragraph 3, of the same regulation. The reference sanctions framework also includes Regulations (EU) no. 833/2014 and no. 765/2006, as well as Directive 2009/43/EC and the list of armament materials referred to in the decree of the Minister of Defense of May 30, 2025, published in the Official Gazette, General Series no. 131 of June 9, 2025.

The impact for companies

The measure directly concerns aeronautical and component companies that maintain commercial relations with the three countries of Central Asia and the Caucasus: for them, export becomes subject to government authorization, with a three-year horizon. The decree is also published on the institutional website of the Ministry of Foreign Affairs and International Cooperation, and was signed in Rome on September 1, 2026.

Source: Official Gazette of the Italian Republic, General Series no. 236 of October 10, 2026 — decree of the Minister of Foreign Affairs and International Cooperation September 1, 2026, “New export control measures towards certain third countries, for certain internal combustion engines and related parts intended for the aviation sector” (26A05300).