UK compliance documents for battery storage
A battery cabinet for the UK needs four sets of documents, and the first one is often described with a rule that changed two years ago. CE marking has been recognised indefinitely in Great Britain since October 2024, so a UK project does not require UKCA marking — but it does require a UK declaration of conformity, and the grid connection and fire evidence are entirely separate from the product file.
This page sets out what belongs in each layer for a 50–200 kWh cabinet installed in Great Britain, which document proves which claim, and where a UK submission genuinely differs from an EU one. It is general information, not legal, electrical or fire engineering advice. Grid connection and building approval are site-specific decisions made by the distribution network operator and the local authority, and the applicable editions must be confirmed before ordering.
It follows the same four-layer structure as our EU compliance page, so the two can be read side by side when a supplier ships to both markets. The market-level overview sits in the compliance document index.
Layer 1 — Product conformity in Great Britain
Great Britain — England, Scotland and Wales — has its own product regulations, and they are near-copies of the EU directives they replaced. A battery cabinet with an integrated converter normally falls inside four instruments, and the declaration of conformity should cite each one by name.
| Instrument | What it covers | What to look for |
|---|---|---|
| Electrical Equipment (Safety) Regulations 2016 | Electrical safety of equipment within the voltage scope | Rated voltage inside scope, harmonised standard cited, UK declaration signed and dated |
| Electromagnetic Compatibility Regulations 2016 | Emissions and immunity | Both emission and immunity standards cited, not emissions alone |
| Restriction of the Use of Certain Hazardous Substances Regulations 2012 | Restricted substances | Covers the whole assembly including converter and wiring; exemptions identified where relied on |
| Batteries and Accumulators (Placing on the Market) Regulations 2008 | Battery marking, capacity labelling and take-back obligations | Producer registration and take-back route stated for the importer |
The marking question is where most outdated procurement documents still cause delays. The Product Safety and Metrology etc. (Amendment) Regulations 2024 extended recognition of CE marking in Great Britain indefinitely, and have been in force since 1 October 2024. In practice:
- CE or UKCA, either is accepted in Great Britain for these regulations, provided the product meets the essential requirements.
- Northern Ireland still requires CE, under the Windsor Framework. A unit shipped to Belfast is an EU-market placement for product conformity purposes.
- UKCA labelling flexibility runs to 31 December 2027. Where UKCA is used, the mark may be applied to a label or accompanying document until then; from 1 January 2028 it must be affixed to the product itself or its data plate.
- Dual marking is permitted where the product meets both sets of essential requirements, which is the usual arrangement for a supplier serving the EU and the UK from one production line.
One document is specific to the UK and is frequently missing: the UK declaration of conformity. It is not the EU declaration with a different header. It must name the UK regulations, be signed by an authorised representative and be held by the person placing the unit on the GB market. An importer that brings the cabinet in under its own name takes on the manufacturer’s obligations, must show its name and a contactable address, and must retain the technical file for ten years after the last unit is placed on the market.
A second point that catches suppliers out: the EU Batteries Regulation (EU) 2023/1542 does not apply in Great Britain. The carbon footprint declaration, the battery passport and the due diligence obligations described on our EU page are EU-market requirements. A UK-only project is not bound by them — but a supplier building one product line for both markets will follow the EU regime anyway, and a distributor moving stock between the two needs to know which file belongs to which placement.
Layer 2 — The four test reports you will be asked for
UK projects cite the British adoptions of the IEC standards, which are technically identical in content. The report a supplier already holds for an EU project is normally acceptable; what changes is the standard reference on the certificate and the edition it was tested to.
| Report | Question it answers | Check before accepting |
|---|---|---|
| BS EN IEC 62619 | Is the lithium cell and battery safe in industrial use, including cell-level thermal propagation behaviour? | Edition cited, tested model, cell maker and cell model named, whether propagation testing was in scope |
| BS EN IEC 63056 | Is the battery safe as a secondary cell or battery used in electrical energy storage systems? | Specific to storage duty rather than general industrial use; model coverage stated |
| BS EN IEC 62477-1 | Is the power conversion system safe? | The converter model shipped is the one tested — the usual gap when battery and converter come from different suppliers |
| UN38.3 test summary and safety data sheet | Can the unit be transported legally, by air, sea or road? | Cell type in the summary matches the cells in the shipped unit |
Installation safety is separate again, and it is the item most often confused with product safety. BS EN IEC 62485-5 covers safety requirements for secondary batteries and battery installations, including ventilation, clearances and fault protection. It applies to the site, not to the product. A supplier can be fully compliant with BS EN IEC 62619 and still be unable to say whether the unit may sit in the plant room the building actually has.
Layer 3 — Grid connection: G98, G99 and G100
The UK connection process is decided by the aggregate generating capacity at the connection point, not by the size of the battery alone. Three documents govern it, and the threshold between the first two is a hard line at 16 A per phase.
| Route | Applies when | What the process requires |
|---|---|---|
| G98 | Aggregate generation of 16 A per phase or less at the premises — approximately 3.68 kW single-phase or 11.04 kW three-phase | Connect and notify: commissioning first, then notify the distribution network operator within 28 days on the standard form |
| G99 | Above 16 A per phase | Apply and receive approval before energising. The DNO may require protection settings, a single-line diagram, and evidence of type-tested equipment |
| G100 | Where export is to be limited, or where the DNO requires it as a connection condition | An export limitation scheme with demonstrated response, plus settings that are locked and evidenced at commissioning |
Almost every 50–200 kWh commercial cabinet sits in the G99 band, and this is the single largest scheduling risk in a UK project. The sequence below is the pattern; the forms and timelines are the DNO’s.
| Step | What happens | Typical owner |
|---|---|---|
| Connection application | Capacity at the point of connection is assessed against the aggregate at the premises, including existing generation | Installer or EPC |
| Connection offer and acceptance | Capacity, protection requirements and any reinforcement are fixed; reinforcement can carry a date and a cost | Installer or EPC with the owner |
| Type-tested equipment evidence | The converter’s type test results are checked against the ENA Type Test Register and the relevant engineering recommendation | Manufacturer, via the installer |
| Installation and commissioning | Protection settings applied and witnessed; export limitation proved where G100 applies | Installer |
| Notification or commissioning notice | G98 form within 28 days of commissioning, or the G99 commissioning notice as the offer requires | Installer |
Two documents are worth requesting at quotation stage rather than at commissioning: the converter’s type test certificate with the ENA registration reference, and the firmware version the settings apply to. A converter without a valid type test can be refused at the application stage, and no amount of paperwork added later changes the hardware.
Layer 4 — Installation, fire and building control
There is no single UK fire code for battery storage either. Requirements come from the wiring regulations, from building regulations, from fire safety legislation that applies to the premises, and increasingly from insurer conditions.
- BS 7671:2018+A4:2026 — the wiring regulations. Amendment 4 was published in 2026 and added provisions for stationary secondary battery installations, including isolation, labelling and protection requirements. Confirm the edition the installer is certifying against, because certificates are issued against an edition.
- PAS 63100:2024 — fire safety guidance for domestic battery installations. It is written for dwellings, and it is often applied by analogy to small commercial rooms; where it is, the reasoning should be recorded rather than assumed.
- Building Regulations, Approved Document B in England — fire safety provisions for non-domestic buildings, including compartmentation and means of escape. Scotland and Wales have their own building standards and guidance.
- Regulatory Reform (Fire Safety) Order 2005 in England and Wales — the responsible person’s fire risk assessment must account for the installation: ignition risk, detection, suppression and fire service access.
- Insurer conditions — increasingly the binding constraint. Some insurers ask for propagation test evidence beyond BS EN IEC 62619, such as UL 9540A data, before they will accept a unit inside an occupied building.
The practical consequence is the same as in the EU: no supplier can certify that a cabinet may be installed in a particular room, because the supplier has not surveyed the room. If the fire strategy is not in the project plan at design stage, it will surface at commissioning.
The pack to request, in one table
| # | Document | Issued by | What to verify |
|---|---|---|---|
| 1 | UK declaration of conformity | Manufacturer or GB importer | UK regulations named, model listed, signatory and date |
| 2 | EU declaration of conformity | Manufacturer | Needed where CE marking is relied on, and for any Northern Ireland placement |
| 3 | BS EN IEC 62619 report | Test laboratory | Edition, tested model, cell maker, scope of tests |
| 4 | BS EN IEC 63056 report | Test laboratory | Covers storage duty, model coverage stated |
| 5 | BS EN IEC 62477-1 report | Test laboratory | Converter model matches the shipped unit |
| 6 | Converter type test certificate with ENA register reference | Manufacturer, accredited body | Valid for the firmware version shipped, G99 settings available |
| 7 | UN38.3 test summary | Manufacturer, from the laboratory report | Cell type matches the shipped cells |
| 8 | Safety data sheet | Manufacturer | Language accepted by the forwarder and the receiving site |
| 9 | Installation manual with clearances and ventilation | Manufacturer | Service clearance, ambient derating and ventilation figures stated |
| 10 | Battery producer registration evidence | Manufacturer or importer | Registration and take-back route for the GB market |
Request items 1 to 6 with the quotation and add 7 to 10 before the order is confirmed. Once the bids are in, the priced fields go into the quote comparison worksheet, and the document answers decide which bids are eligible to be ranked at all — which is the same gate structure described in the 12-field RFQ checklist.
Five differences from an EU submission
- The marking rule is more permissive than most tender documents assume. CE is recognised indefinitely in Great Britain; a specification that rejects CE-marked equipment as non-compliant is out of date and will narrow the field for no benefit.
- The declaration is a different document. A UK declaration of conformity naming the UK regulations is required alongside, not instead of, the EU declaration where both markets are served.
- The Batteries Regulation stops at the border. Carbon footprint declarations and battery passports are EU-market obligations; Great Britain runs on the 2008 placing-on-the-market regulations and separate waste battery producer obligations.
- Connection routes are numeric, not type-based. The UK decides by current per phase and aggregate capacity at the premises, where most EU markets decide by a type classification in the national code. A unit certified for a German type class tells you nothing about the G99 outcome.
- Fire evidence is driven by the insurer as much as the regulator. In practice the propagation test data an insurer asks for decides whether a unit goes inside the building, and that question is rarely answered by a product certificate.
Frequently asked questions
Do I need UKCA marking for a battery cabinet in 2026?
No. Since 1 October 2024, CE marking has been recognised indefinitely in Great Britain for the product regulations in scope, so either CE or UKCA is accepted. What is required is a UK declaration of conformity naming the UK regulations, plus the importer’s details on the product or its documentation. Northern Ireland is different: CE marking is required there under the Windsor Framework.
Is G98 or G99 the right route for a 100 kWh cabinet?
G99, in almost every case. G98 is limited to an aggregate of 16 A per phase at the premises, roughly 3.68 kW single-phase or 11.04 kW three-phase, and the aggregate includes existing generation such as rooftop solar. A 100 kWh cabinet with a converter of any commercial size is far above that threshold, so the application-and-approval route applies before energising.
Can an EU test report be used for a UK project?
Usually yes. The British standards are adoptions of the same IEC documents, so a report against IEC 62619 is technically the evidence behind BS EN IEC 62619. What matters is the edition cited, whether the tested model and cell match the unit being shipped, and whether the certificate names the standard the DNO or the insurer will look for. Ask for the scope page, not the cover page.
Does the EU Battery Regulation apply to a UK installation?
Not in Great Britain. The carbon footprint declaration, battery passport and due diligence obligations under Regulation (EU) 2023/1542 are EU-market requirements. Great Britain applies its own placing-on-the-market and waste battery producer obligations. A supplier serving both markets will typically build to the EU regime because it is stricter, but the file submitted for a GB placement is the UK one.
Who is responsible for the fire strategy?
The owner, acting through the responsible person for the premises, with the installer designing and submitting the evidence. The supplier can provide test data on the enclosure and on propagation behaviour, and that data is often what the insurer requires, but siting approval belongs to the building and the fire authority. Budget it at design stage: it is the item most likely to move a completion date.
General information only. Requirements differ across England, Scotland, Wales and Northern Ireland, and change between editions. Confirm the applicable regulations, their current edition, the DNO connection route and the local approval path with the network operator and the authority having jurisdiction before ordering equipment.
Shipping to the UK?
Send the site location, the connection capacity and the application. We reply with the document set a GB project will ask for, the standards the converter is type-tested to, and where the DNO approval sits in the schedule.
