PGS 37-1: safe energy storage with batteries

Are you looking for information about PGS 37-1? Then you probably want to know whether this guideline applies to your situation and what you need to do. On this page, we explain PGS 37-1 step by step, in clear language and with a focus on practice.

What is PGS 37-1?

PGS 37-1 is a Dutch guideline for the safe storage of energy in systems with lithium-based batteries. These systems are also called energy storage systems (ESS).

The guideline is intended to reduce risks, such as fire or the release of hazardous substances. This is important because lithium batteries can react strongly in case of damage or malfunction.

PGS 37-1 does not only apply to the batteries themselves, but to the entire system, including:

• battery modules
• the Battery Management System (BMS)
• technical safety measures such as ventilation and protection systems

When does PGS 37-1 apply?

PGS 37-1 applies to energy storage systems with lithium-based batteries with a total installed capacity of more than 20 kWh.

It does not matter whether the system is:

• installed indoors or outdoors
• placed in a building, container or cabinet
• installed permanently or temporarily

In short:

• More than 20 kWh? PGS 37-1 generally applies
• 20 kWh or less? The system falls outside the formal scope of PGS 37-1

When does PGS 37-1 not apply?

PGS 37-1 does not apply in the following situations:

• storage of loose batteries (this is covered by PGS 37-2)
• systems used by private individuals, such as home batteries
• batteries in vehicles or machines used as vehicles

Please note:
For large private systems (more than 20 kWh), it is often recommended to follow the safety principles of PGS 37-1.

How large is your system?

For large energy storage systems, additional requirements apply.

• PGS 37-1 is developed for energy storage parks up to 400 MWh
• Systems larger than 400 MWh require custom risk assessment
• This must always be done in consultation with the competent authority and the safety region

Is PGS 37-1 mandatory?

PGS 37-1 is a Dutch guideline, not a law. However, in The Netherlands, in practice it is often decisive.

At this moment:

• PGS 37-1 can be made mandatory through permits or tailor-made requirements
• Authorities and safety regions use PGS 37-1 as a reference
• Insurers often expect compliance with PGS 37-1

The government is working on including PGS 37-1 in national regulations. This is expected to take effect in 2026.

Practical advice

Treat PGS 37-1 as the standard for safe energy storage. This helps avoid problems later.

What does PGS 37-1 cover?

PGS 37-1 focuses on controlling risks related to energy storage systems. The guideline is built around three main themes.

1. Preventing incidents

• safe system design
• proper operation of the BMS
• monitoring, maintenance and inspection

2. Limiting consequences if something goes wrong

• fire and smoke control measures
• preventing escalation to the surroundings
• safe distances to other objects
• accessibility for emergency services

3. Organisation and preparedness

• clear procedures for incidents
• information for emergency responders
• agreements on maintenance and decommissioning

The exact measures depend on the type of installation and application.

Common misconceptions about PGS 37-1

“PGS 37-1 only applies to large battery parks”

No. The guideline applies from more than 20 kWh, also to smaller systems.

“If the system is outdoors, PGS 37-1 does not apply”

Incorrect. Outdoor installations are also covered by PGS 37-1.

“Existing systems do not need to take action”

Existing systems can also fall under PGS 37-1.
For existing situations, transition periods may apply.

“PGS 37-1 and PGS 37-2 are the same”

No.

• PGS 37-1: energy storage systems (ESS)
• PGS 37-2: storage of loose lithium batteries

How to approach PGS 37-1 in practice

Step 1 – Define your situation

• what type of system do you have or need?
• what is the total capacity?
• where and how is it installed?

Step 2 – Determine which guideline applies

• energy storage system → PGS 37-1
• storage of batteries → PGS 37-2

Step 3 – Align early with authorities

Contact at an early stage:

• the competent authority
• if needed, the safety region

This helps avoid changes later on.

Step 4 – Work in a demonstrably safe way

Document:

• design choices
• maintenance and inspections
• emergency procedures

Step 5 – Consider the full lifecycle

PGS 37-1 applies from commissioning to decommissioning.
End-of-life and removal are also part of this.

Need any help with this?

Legal notice

We have prepared this page to make PGS 37-1 understandable in practice. Because every situation is different, exact requirements may vary. The official PGS 37-1 and agreements with the competent authority are always leading.

Sources & further reading

This page is based on official Dutch guidelines and government explanations:

• Publicatiereeks Gevaarlijke Stoffen – PGS 37-1:2023, version 1.0
• IPLO – Explanation of PGS 37-1 and PGS 37-2
• RVO – Guideline for permitting energy storage systems