EU compliance documents for battery storage
An EU-ready file for a commercial battery system has four layers, and no single certificate covers all of them: CE marking for product conformity, IEC test reports for safety evidence, a grid-connection package for the network operator, and site approval for fire and building control. Suppliers deliver the first two. The installer assembles the third. The owner carries the fourth.
This page sets out what belongs in each layer for a 50–200 kWh cabinet in the EU — the same cabinet range covered in our commercial battery storage overview — which document proves which claim, and where the CE declaration stops short. It is general information, not legal or fire engineering advice, and it cannot replace the national code of the member state where the unit is installed — those codes differ even where the underlying standard is harmonised.
Layer 1 — CE marking: what the declaration has to say
CE marking is a manufacturer’s declaration that the product meets the EU legislation that applies to it. It is not a certificate issued by the EU, and it is not a test report. For a battery cabinet with an integrated PCS, four instruments are normally in scope, and the declaration of conformity should cite each one by number.
| Instrument | What it covers | What to look for in the file |
|---|---|---|
| Low Voltage Directive 2014/35/EU | Electrical safety of equipment within its voltage scope | The rated voltage of the unit falls inside the directive’s scope, and the cited standard is a harmonised one |
| EMC Directive 2014/30/EU | Emissions and immunity | Both emission and immunity standards cited, not emissions alone |
| RoHS 2011/65/EU | Restricted substances | Declaration covers the whole unit, including the PCS and wiring |
| Batteries Regulation (EU) 2023/1542 | Battery-specific obligations across the life cycle, replacing Directive 2006/66/EC | CE marking under the Regulation has applied since 18 August 2024; further obligations are phased in to 2027 and beyond |
The Batteries Regulation is the part most suppliers still answer vaguely, because its obligations arrive in stages rather than at once. Three dates matter for a commercial project in 2026 and 2027:
- Carbon footprint declaration for rechargeable industrial batteries above 2 kWh — from 18 February 2026, or 18 months after the delegated act, whichever is later. Most C&I cabinets are above the 2 kWh threshold and therefore in scope.
- Battery passport and QR code — from 18 February 2027. This date has no conditional clause attached, so it is the one to plan against.
- Supply-chain due diligence — from 18 August 2027, moved from 2025 by Regulation (EU) 2025/1561, with a higher turnover threshold proposed but not adopted at the time of writing.
A practical consequence: a unit delivered in late 2026 may be fully compliant on the day of delivery while the model it belongs to becomes non-compliant for new placement on the market in 2027. Ask the supplier which passport and carbon-footprint status the shipped model will have, not only what it holds today.
Layer 2 — The four test reports you will actually be asked for
Test reports are what turn a declaration into evidence. Four are requested consistently in European C&I projects, and each answers a different question.
| Report | Question it answers | Check before accepting |
|---|---|---|
| IEC 62619 | Is the lithium cell and battery safe in industrial use, including thermal propagation behaviour at cell level? | Edition cited, tested model, cell maker and cell model named, and whether the propagation test was in scope |
| IEC 62477-1 | Is the power conversion system safe? | That the PCS model shipped is the one tested; frequently missing when PCS and battery come from different suppliers |
| IEC 62933-5-2 | Is the integrated grid-connected system safe as an assembly? | Whether the report covers the assembled cabinet or only a subsystem |
| UN38.3 + safety data sheet | Can the unit be transported legally? | The cell type in the test summary matches the cells in the shipped unit |
Installation safety is a separate matter and is often confused with product safety. The IEC 62485 series covers safety requirements for secondary batteries and battery installations — ventilation, clearances, fault protection — and it applies to the site, not the product. A supplier can be fully compliant on IEC 62619 and still be unable to answer whether the unit may sit in a room with the clearance the building actually has.
Layer 3 — Grid connection: the document that sets the schedule
Grid connection is where European projects lose weeks, and the reason is structural. The legal requirement comes from the network code — the RfG regulation at EU level and the national implementing code below it. The technical proof comes from the EN 50549 series. Both are needed: a compliant product and a compliant installation.
- EN 50549-1 — requirements for generating plants, including storage, connected to the low-voltage network, up to and including type B.
- EN 50549-2 — the same for the medium-voltage network.
- EN 50549-10 — the test procedures used to demonstrate conformity with parts 1 and 2. A unit certificate without a stated test basis is worth checking closely.
The sequence below is the pattern used across most member states. Names and forms differ; the logic does not.
| Step | What happens | Typical owner |
|---|---|---|
| Connection request and grid study | The operator assesses available capacity at the connection point and issues connection conditions | Installer or EPC |
| Connection agreement | Connection point, capacity and technical requirements are fixed, driven by the plant’s type classification | Installer or EPC with the owner |
| Unit certificates | Type-test evidence for the PCS and the storage unit against EN 50549 and the national code | Manufacturer |
| Plant certificate | For the larger type classes, an accredited body certifies the as-built installation — protection, controls, EMS settings | Installer or EPC |
| Compliance statement and energisation notice | The operator accepts the file and issues permission to energise for commissioning | Operator, on the installer’s submission |
| Commissioning and final notice | Witness tests confirm the installed settings match the certified design; commercial operation is released | Installer, operator |
Two of those steps are long poles and both are usually underestimated: the operator’s connection queue, and the plant certificate. Neither can be back-filled after the equipment is on site. A PCS without the right unit certificate cannot be certified later by adding paperwork.
National codes sit on top of the harmonised standard
| Country | Low-voltage code | Medium-voltage code | Additional requirement to expect |
|---|---|---|---|
| Germany | VDE-AR-N 4105 | VDE-AR-N 4110 | NELEV sets when a unit certificate and an installation certificate are required; component registry entries are requested for some equipment |
| Italy | CEI 0-21 | CEI 0-16 | Strict interface-protection rules and a separate storage annex |
| Spain | National technical supervision rules implementing the RfG | Conformity assessed through an accredited certification scheme | |
| France | National connection framework administered by the DSO | Documentation-heavy; a French-language file is expected | |
| Netherlands / Belgium | Netcode elektriciteit | — | Regional DSO requirements and, in Belgium, the Synergrid technical prescriptions |
A certificate issued in one member state does not transfer to another. The technical requirements overlap heavily; the forms, registries and protection settings do not. Budget a separate compliance package per country rather than assuming a single EU file.
Layer 4 — Fire, siting and insurance
There is no EU-wide fire code for battery storage. Fire and siting requirements come from national building regulations, regional fire authority guidance and, increasingly, insurer conditions. That is why a supplier cannot certify that a unit may be installed in a particular room: the supplier does not know the room.
Three questions decide most of it, and they belong in the design stage rather than the commissioning stage:
- Separation and access — distance to occupied space, escape routes and other combustibles, and whether the fire service can reach the unit.
- Ventilation and detection — what the enclosure provides, and what the building must add around it.
- Suppression and evidence — whether a suppression system is included or optional, and whether the insurer expects propagation testing beyond IEC 62619, such as UL 9540A data.
For projects where the unit sits inside an occupied building, the fire strategy is usually the item that moves the completion date, not the battery delivery.
The pack to request, in one table
| # | Document | Issued by | What to verify |
|---|---|---|---|
| 1 | EU declaration of conformity | Manufacturer | Directives cited, model named, signatory and date |
| 2 | IEC 62619 report | Test laboratory | Edition, tested model, cell maker, scope of tests |
| 3 | IEC 62477-1 report | Test laboratory | PCS model matches the shipped unit |
| 4 | IEC 62933-5-2 report | Test laboratory | Covers the assembly, not a subsystem |
| 5 | EN 50549-1 or -2 unit certificate | Accredited certification body | Test basis stated, firmware version covered, country settings available |
| 6 | UN38.3 test summary | Manufacturer, from the laboratory report | Cell type matches the shipped cells |
| 7 | Safety data sheet | Manufacturer | Language accepted by the forwarder and the receiving country |
| 8 | Carbon footprint declaration status | Manufacturer | Whether the model is in scope of the February 2026 obligation |
| 9 | Battery passport readiness | Manufacturer | Planned data set and QR approach for the February 2027 date |
| 10 | Installation manual with clearances | Manufacturer | Ventilation, service clearance and ambient derating figures |
Ten documents is a long list for a first email. Request items 1 to 7 with the quotation, and ask for the status of 8 and 9 in writing so the obligation is on record. Once the bids are in, the priced fields — price, capacity, DoD, scope and warranty — go into the quote comparison worksheet, and the gate answers decide which bids are eligible to be ranked.
Five red flags in an EU submission
- A declaration that cites standards but not the model. Family declarations are common and only valid where the family scope genuinely covers the shipped configuration.
- An EN 50549 certificate with no stated test basis. Ask which part of EN 50549-10 was used and for which firmware version.
- No PCS report because the PCS is "included". Included does not mean tested; the conversion equipment needs its own IEC 62477-1 evidence.
- A 2026 delivery with no passport plan. The February 2027 date has no conditional clause, and a model can be compliant on delivery while becoming non-compliant for new placement.
- Fire approval left to the supplier. No supplier can approve siting in a building it has not surveyed. If the fire strategy is missing from the project plan, it will appear at commissioning.
Frequently asked questions
Does a CE mark mean the battery can be installed anywhere in the EU?
No. CE marking means the product may be placed on the market; it says nothing about a specific installation. Grid connection, fire siting and building approval are site-level decisions made by the network operator and the local authority. A unit can be fully CE compliant and still be refused at a particular site because of clearance, ventilation or the fire strategy.
Which EN 50549 part applies to a 100 kWh commercial cabinet?
It depends on the voltage at the connection point, not on the battery capacity. A unit connected to the low-voltage network is assessed against EN 50549-1; a connection at medium voltage falls under EN 50549-2. Most C&I cabinets below a few hundred kilowatts connect at low voltage, but the decision belongs to the network operator’s connection conditions.
Is the Batteries Regulation already binding in 2026?
Yes, and progressively. It has applied since 18 February 2024, CE marking under it since 18 August 2024, and the carbon footprint declaration for rechargeable industrial batteries above 2 kWh is due from 18 February 2026 or 18 months after the delegated act, whichever is later. The passport and QR code obligations follow on 18 February 2027, and due diligence on 18 August 2027.
Can the supplier obtain the grid connection approval for us?
The supplier can supply the unit certificate, protection settings and firmware profiles, and can support the application with data. The application itself is made by the party connecting to the network, which is normally the installer or the owner, and the plant certificate is issued against the as-built installation rather than the product. Treat supplier-run applications with caution unless they are contracted to hold the connection.
What if the destination is outside the EU but the equipment is EU-certified?
It helps and it is often accepted as technical evidence, but it is not a substitute for the national scheme. Markets with their own conformity infrastructure — the UK, Saudi Arabia, the UAE, Brazil — will ask for their own mark or certificate, and the customs entry is cleared against that document rather than against CE. The market comparison in the compliance document index lists the starting point for each. The UK is covered separately on the UK compliance documents page.
General information only. Requirements differ by member state and change between editions. Confirm the applicable code, its current edition and the local approval route with the network operator and the authority having jurisdiction before ordering equipment.
Preparing an EU submission?
Send the destination member state, the connection voltage and the application. We reply with the document set that market will ask for, and which items only the installer can provide.
