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What is the efficient path for lithium battery energy storage to go global and obtain certification in Europe and America?
Author.
LCS
Source:
Post time:
2026-07-21
European and American authentication logic
An energy storage cabinet, from selecting battery cells to finally landing at a project site in the United States or Europe, has a certification process that can take as little as six months to as much as one year. Many companies are not due to inadequate technology, but rather due to incorrect certification sequence - before the battery report is released, the entire machine is sent for testing; The battery cell model was changed midway, and all data was invalidated; UN38.3 was delayed until before shipment, and the shipping schedule was forced to be postponed.
The root of the problem is not that the standards are too difficult, but that no one has helped you arrange all the certification processes into an executable parallel timetable. Before starting, take three minutes to clarify the overall logic:
① UL 1973 manages the safety of battery subsystems, UL 9540 manages the safety of complete energy storage integrated systems, and UL 9540A evaluates the risk of thermal runaway fire spread - a three-layer standard that progresses step by step and supports each other.
② Standard configuration for the North American market: UL three-layer standard complete report+FCC electromagnetic compatibility. Core of the EU market: CE (IEC/EN 62619+EMC+LVD)+compliance with EU battery regulations.
③ The 8 transportation safety tests for UN38.3 lithium batteries are prerequisites for sea, land, and air transportation. Without test reports and transportation identification documents, the freight company directly refused to load them.
Quick search of core terms
UL 1973- Safety Standard for Fixed Energy Storage Lithium ion Batteries
Evaluating the safety performance of battery cells, modules, and battery packs themselves is the foundation of energy storage battery certification.
UL 9540- Overall Safety Standard for Energy Storage Integrated Systems
Covering the integrated safety of the entire energy storage cabinet, it provides protection for batteries BMS、PCS、 Conduct an overall evaluation of the temperature control and fire linkage system.
UL 9540A - Safety Standard for Thermal runaway spread assessment of lithium-ion battery systems
By manually triggering thermal runaway, verify whether a single battery cell will ignite surrounding modules after catching fire. The US Fire and Safety Regulatory Agency (AHJ) approves the necessary report for energy storage projects, without which on-site filing and equipment insurance cannot be completed.
CE - EU Safety Conformity Mark
Mandatory entry mark for entering the EU market. The energy storage system must synchronously meet the three major directives of IEC/EN 62619, EMC, and LVD; Those with communication modules must also comply with the RED radio directive.
IEC/EN 62619- Safety Standard for Industrial Lithium ion Batteries in the European Union
The EU benchmarks the battery safety standard UL 1973. There are differences between the testing items and North American standards, and both parties cannot directly recognize each other's reports. IEC is an International Electrotechnical Commission standard, while EN is an EU coordinated standard with consistent technical content.
BMS - Battery Management System
Responsible for charge and discharge control, temperature monitoring, fault protection, and high-voltage linkage cut-off.
PCS - Energy Storage Converter
Completing the bidirectional conversion between battery DC power and grid AC power is the core evaluation component of electromagnetic compatibility testing.
UN38.3- UN TDG regulation: 8 safety tests for lithium battery transportation
Global transportation compliance requirements for lithium batteries. After testing, a DGM dangerous goods transportation identification certificate is required before normal shipment can be made.
North American three-tier progressive certification system
Access to North American energy storage systems cannot be cleared with just one UL certificate. Three sets of standards for hierarchical control of different security dimensions:
01
UL 1973 Battery Subsystem Safety
Control objects: battery cells, battery modules, and complete battery clusters.
Core testing items: overcharge, overdischarge, external short circuit, compression, needle puncture, high temperature thermal abuse, vibration, mechanical impact, etc.
Overcharge test: Continuously charge beyond the rated charging limit to verify that the battery does not ignite or explode
Acupuncture Test: Steel Needle Punctures Cell to Simulate Internal Short Circuit and Evaluate the Probability of Thermal Loss Triggering
Squeezing test: Simulate external impact squeezing to verify the safe state after deformation
Thermal abuse test: Continuous baking at 130 ℃ to test the stability of high-temperature environment
Cycle reference: Pure testing for 2-4 months; Including sample rectification, witness testing, certificate issuance, overall 3-6 months.
02
UL 9540 · Integrated Safety of Energy Storage System
Control object: The entire energy storage equipment, including battery systems PCS、BMS、 All integrated units including temperature control, fire protection, high-voltage distribution, communication modules, etc.
Audit focus: Do not evaluate components separately, focus on verifying component interaction - whether BMS can link PCS shutdown when charging is abnormal; Can the fire protection and power outage protection be triggered synchronously during overheating; Can the system automatically switch to safe standby mode when communication fails.
Cycle reference: scheme pre review+whole machine testing+factory system audit, totaling 6-12 months.
03
UL 9540A · Special Test for Thermal runaway spread
This is an independent safety standard that does not issue UL certificates, only official test reports are issued. The experiment actively triggers the thermal runaway of the battery cell, and collects data on temperature, flame height, toxic gases, and spread range throughout the process.
User: AHJ (fire, building safety, electricity approval agency) and commercial insurance companies in the United States. Without this report, it is impossible to obtain the installation permit and equipment insurance for the energy storage power station.
Important update: UL 9540A Ed.6 (effective March 2025) has changed large-scale fire testing from optional to mandatory. The new version will be fully implemented for North American projects in 2026.
UL 1973 (Basic Safety for Battery Cells) → UL 9540 (Integrated Safety for Whole Machines, Must be Equipped with UL 1973 Certified Batteries) → UL 9540A (Supplementary Fire Risk Data for On site Installation Approval)
Practical parallel suggestion: UL 1973 battery testing and UL 9540A thermal runaway testing can be started synchronously; The UL 9540 complete machine project can conduct scheme review and structural pre testing in advance, and then conduct complete machine reliability testing after the UL 1973 battery report is basically implemented.
EU CE certification path: synchronous compliance with three major directives
The CE mark is a mandatory requirement for energy storage products entering the European Union, and the entire machine must comply with three directives simultaneously.
Directive 1: IEC/EN 62619 Safety Standard for Industrial Lithium Batteries
EU exclusive safety standard for energy storage batteries, benchmarked against North American UL 1973. The test covers overcharge, short circuit, drop, thermal shock, internal short circuit and other working conditions, and is mandatory for all energy storage industrial batteries.
Directive 2: EMC Electromagnetic Compatibility Directive
Control the electromagnetic noise during the operation of energy storage equipment, avoid interfering with the power grid and surrounding electronic devices, and verify the equipment's ability to resist external electromagnetic interference. The PCS high-frequency inverter unit is the core object of EMC testing.
Instruction Three: LVD Low Voltage Instruction
Suitable for electrical equipment with DC 75V-1500V and AC 50V-1000V. The energy storage high-voltage DC bus and PCS AC/DC output are both within the control range, and the evaluation is based on EN IEC 62477-1.
The EU's new battery regulation (EU) 2023/1542 imposes mandatory new regulations
(EU) 2023/1542 will come into effect on August 17, 2023, and fully replace the old Battery Directive (Directive 2006/66/EC) on August 18, 2025. This is currently the strictest battery lifecycle management framework in the world, covering the entire chain from raw material extraction, production and manufacturing, use to scrap and recycling. Energy storage batteries (>2kWh industrial batteries) are a key controlled object.
Energy storage products exported to the European Union must meet four new compliance requirements in addition to CE certification:
1
Carbon Footprint Classification Label
2kWh rechargeable industrial batteries (including energy storage systems) must calculate their full lifecycle carbon emissions in accordance with the EU Product Environmental Footprint (PEF) rules, indicating their carbon footprint performance levels (A-E) and specific emission values. Carbon footprint data requires ISO 14067 certification.
If rated as D or E, European energy storage integrators may abandon procurement in order to maintain their product's environmental rating.
Time node:>2kWh industrial battery carbon footprint declaration, mandatory from February 18, 2026; Carbon footprint performance level labeling will be mandatory from August 18, 2026.
2
Digital Battery Passport
Energy storage batteries with a rated capacity of ≥ 2kWh must be equipped with a digital battery passport that can be accessed through QR code. Scanning the QR code can provide full lifecycle traceability information, including manufacturer, material composition, recyclable content, carbon footprint data, performance and durability parameters, etc.
Time node: Mandatory from February 18, 2027.
3
Due diligence on mineral supply chain
Enterprises need to establish a due diligence system for their supply chain, publicly disclose compliance certificates for key mineral sources such as lithium, cobalt, nickel, and lead, covering the entire chain of human rights, environmental, and social risk assessments, and require third-party verification by EU notified bodies.
Time node: Fully effective by August 2025; Third party verification will be mandatory from August 18, 2027.
4
Recycled material content and extended producer responsibility (EPR)
Proportion of recycled materials: Starting from 2031, the minimum recycling requirements for cobalt, lead, lithium, and nickel in industrial batteries will take effect and increase year by year.
Cobalt: 6% from 2027 → 12% from 2031 → 20% from 2036
Lead: 6% from 2027 to 16% by 2031
Lithium: 6% from 2027 → 12% from 2031 → 20% from 2036
Nickel: 6% from 2027 to 12% by 2031
EPR obligation: Starting from August 18, 2025, manufacturers must complete EPR registration in each member country and bear the costs of collecting, processing, and recycling waste batteries. Failure to register will face the risk of account closure and suspension.
Key compliance timeline
On August 18, 2025, the old battery directive will be abolished, and EPR registration and recycling labeling will be fully mandatory; Due diligence on mineral supply chain fully effective
February 18, 2026:>2kWh industrial batteries must submit a carbon footprint statement
August 18, 2026: Mandatory carbon footprint performance level labeling (A-E level labeling)
February 18, 2027: Mandatory implementation of digital battery passports and QR codes
August 18, 2027: Compulsory third-party verification for supply chain due diligence
August 18, 2028: Mandatory requirement for the proportion of recycled raw materials for power batteries and industrial batteries
2031-2036: The target for the regeneration content of cobalt, lithium, nickel, lead, and other materials will gradually increase
Efficient parallel authentication scheme: synchronous promotion of three testing lines
The biggest pain point of energy storage certification is serial waiting - one step is rectified, and the entire process is delayed. After reasonable splitting, the three testing main lines can be started synchronously, greatly reducing the total cycle.
A-line Battery Safety Test (UL 1973/IEC/EN 62619)
Cycle: 3-6 months, can be parallel with Line B.
Key action: Lock in the battery cell model and formula in the early stage, prepare sufficient test samples (≥ 30 battery cells, ≥ 5 sets of modules); Simultaneously initiate testing for UL 1973 in North America and IEC/EN 62619 in the European Union. The two standard testing items overlap, and some raw data can be shared but separate reports need to be issued; Synchronize the UN38.3 transportation test without waiting for the battery safety test results.
B-line UL 9540A thermal runaway fire test
Cycle: 2-4 months, synchronized with the launch of Line A.
Key action: Use the same type of battery cell as A line to make test modules and units, and send them to the laboratory for graded fire testing; The testing logic is at the cell level → module level → battery cluster level → whole machine installation level, with the preceding data used as the basis for subsequent input. It should be noted that from March 2025, the new version of UL 9540A will be subject to mandatory large-scale fire testing, which will significantly increase the testing cost compared to the old version, and a budget needs to be reserved in advance.
C-line · Complete System Certification (UL 9540/CE Complete Set)
Cycle: 6-12 months, initiated after completion of UL 1973.
Key action: Based on UL 1973 certified batteries, assemble a complete energy storage system with BMS, PCS, temperature control, and fire protection components; Conduct a complete set of integrated testing for UL 9540 to verify the charge discharge linkage, communication protocol, and fault protection conditions; Simultaneously initiate CE EMC and LVD testing; The North American market is synchronously equipped with FCC Part 15 Subpart B electromagnetic compatibility testing.
Three line parallel time reference
January February: A-line battery safety, B-line UL 9540A thermal runaway, UN38.3 transportation testing, CE EMC/FCC pre-test all start synchronously
From March to May: The in-depth testing of A-line batteries continues to advance, while B-line enters the module/battery cluster fire testing phase
5th to 6th months: A-line UL 1973 testing completed, C-line UL 9540 complete machine integration testing started
June to October: C-line whole machine testing, factory system audit, B-line whole machine level fire test completion
10th to December: All standard tests and certificate issuance are completed, and the products can be exported in bulk to Europe and America
Five high-frequency pitfalls in major industries
① Mistakenly thinking that UL 1973 is sufficient to complete the UL certification for the entire machine
UL 1973 only regulates the safety of individual battery modules. Both North American project clients and fire approval agencies require a complete UL 9540 system certificate and UL 9540A fire report. Providing only the battery report will cause the project to be suspended midway, and additional testing of the entire machine will take an extra 2-6 months.
② Change battery cell model during certification
UL 1973 certification binds fixed cell formula and model. During the testing process, the battery cells were replaced, rendering all previous test data invalid. A new sample needs to be made and retested, doubling the cycle and cost. It is recommended to lock in battery cell suppliers in the early stage and sign a stable supply agreement for at least 2 years.
③ Omitting FCC electromagnetic compatibility compliance in the United States
PCS energy storage inverters belong to high-frequency switching equipment, with a high risk of electromagnetic radiation exceeding the standard. Most companies only focus on UL safety standards and ignore FCC Part 15 Subpart B electromagnetic compatibility requirements. After the goods arrive at the port, they are detained by customs, resulting in high demurrage fees.
④ UL 9540A is still using the old version report
The new UL 9540A 6th edition will come into effect in March 2025, and large-scale fire testing will be mandatory. By 2026, all energy storage projects in North America will require a new version of the report. The old version is not recognized by fire and insurance companies and needs to be retested.
⑤ UN38.3 transportation testing to be conducted before shipment
UN38.3+DGM transportation appraisal is a mandatory threshold for sea and air transportation, and freight companies directly refuse to load without documentation. This test only takes 7-15 working days, and if it is delayed until before shipment, it can easily delay the shipping schedule and order delivery. It is recommended to conduct battery safety testing simultaneously.
Self inspection checklist for export of energy storage products
The battery cell model has been locked and a stable supply agreement of no less than 2 years has been signed with the supplier
UL 1973 cell and module level testing has been initiated or certified, and complete testing reports are available
UL 9540A thermal runaway fire test strictly follows the sixth edition standard, including mandatory large-scale fire test
UL 9540 complete system certification has been initiated, covering BMS, PCS, temperature control, and fire protection fully integrated linkage testing
FCC Part 15 Subpart B Electromagnetic Compatibility Complete Test Report for the North American Market
Complete set of CE compliance documents for the EU market: IEC/EN 62619 Battery Safety+EMC Electromagnetic Compatibility+LVD Low Voltage, with additional RED report for wireless devices
UN38.3 eight item transportation test report+DGM dangerous goods transportation identification+MSDS material safety data sheet complete
Compliance assessment for EU Battery Regulation (EU) 2023/1542 has been completed, including carbon footprint accounting, implementation of passport preparation plan for batteries with a capacity of ≥ 2kWh, and EPR registration
All test reports issued by institutions with dual accreditation qualifications of CNAS and A2LA
Energy storage going global, certification first. LCS helps you turn serial waiting into parallel breakout.
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