ICPE and battery storage: which heading, which obligations

When a company looks into electricity storage, the ICPE battery storage question comes up quickly: does the system fall under the French regime for installations classified for environmental protection (ICPE), and what needs to be filed? The answer comes down to one heading, one threshold and one ministerial order. This article goes through them from the texts, with example calculations for common configurations.

Which ICPE heading applies to battery storage?

The ICPE nomenclature does not, to date, have a heading of its own for stationary electricity storage. Batteries fall under heading 2925, "Workshops for charging electric accumulators", in the version resulting from Decree No. 2019-1096 of 28 October 2019 (Ineris AIDA database). It has two sub-headings, depending on the chemistry:

An LFP battery, the chemistry of most current stationary systems (see LFP or NMC), therefore falls under sub-heading 2925-2. The sub-heading excludes electric vehicle charging infrastructure open to the public.

Both sub-headings only provide for declaration: heading 2925 provides for neither registration nor authorisation. It is the simplest regime in the nomenclature.

How is the relevant power calculated?

The threshold applies to power, not to stored energy. The note to the heading specifies that this is the deliverable charging power cumulated across all the equipment in the workshop. Three practical consequences:

• Everything is added up: all the batteries on the site, even if installed in several phases or in different parts of the establishment.
• Megawatt-hours do not count. A long-duration, low-power battery can stay below the threshold; a short, powerful one can exceed it.
• The converter sets the charging power. For a storage system, the power used is in practice the power at which it can charge. The exact reading is confirmed with the classified installations inspectorate for each project.

Three example calculations

The power ratings below come from RelyEZ datasheets; the classification is a reading of the heading, to be confirmed project by project.

The first case is that of many commercial and industrial sites that shave their consumption peaks (see Exceeding subscribed power). The other two show that a project crosses the threshold as soon as it goes beyond a few cabinets or moves to a container.

What does the declaration change for the site?

A declaration before commissioning

The declaration is filed with the prefecture, before work starts and before commissioning. It describes the installation, its location and the planned measures. The operator receives proof of filing and undertakes to comply with the applicable general requirements.

The requirements of the order of 29 May 2000

These requirements are set by the order of 29 May 2000 on heading 2925, whose Annex I was last amended by the order of 3 August 2018 (Légifrance). The main ones:

The text was written for charging workshops inside buildings: some requirements (hydrogen ventilation and detection, for example) mainly concern batteries that give off hydrogen. For a container placed outdoors, how they apply is discussed with the inspectorate and the departmental fire and rescue service, which may specify requirements suited to the project.

What the equipment brings to the file

A declaration file comes together all the faster when the equipment is well documented: dated datasheet, certifications, fire test reports, layout plan with distances. GridUltra containers arrive assembled and tested, with their detection and extinguishing built in; what they contain is detailed in Battery storage container. The certifications of the RelyEZ range are listed on the RelyEZ page.

Can other headings or procedures apply?

Yes, and this is often where the timetable is decided. The law firm CMS Francis Lefebvre lists them in a note of 30 September 2026:

• Other ICPE headings when the site has other activities: a warehouse storing batteries (heading 1510) or end-of-life batteries passing through (heading 2718). The site's regime may then move to registration or authorisation.
• Environmental assessment, systematic or after case-by-case review depending on the project and its connection works (Article R. 122-2 of the Environmental Code).
• Planning: building permit or prior declaration depending on the floor area and the location, in line with the local urban plan.
• Related environmental procedures depending on the land: water law, land clearing, protected species.

For a battery installed behind the meter of an existing site, most of these points are handled within the site's file. For a standalone project on undeveloped land, they are planned from the outset.

What could change?

Two developments are worth following:

1. A draft decree amending heading 2925 was put out for public consultation until 7 September 2026, then presented to the Higher Council for the Prevention of Technological Risks on 15 September (Actu-Environnement, 18 August 2026). It mainly concerns sub-heading 1, for batteries whose charging produces hydrogen.
2. A heading dedicated to battery storage has been announced for 2027, according to the CMS Francis Lefebvre note; the decree had not been published at the date of that note.

Until a new text is published, classification is based on heading 2925 in its 2019 version. A project filed after a reform will be classified under the version in force on the filing date: this is a point to check when the file is launched.

How should the ICPE side of a project be prepared?

1. Set the charging power at the sizing stage, taking into account all the batteries planned on the site, including extensions.
2. Read the classification: below or above 600 kW, and the other headings present on the establishment.
3. Draw the layout with distances, emergency access and the water point.
4. Gather the equipment documentation: datasheets, certifications, tests.
5. Talk early with the classified installations inspectorate and the fire service.

The sizing method is described in Battery storage for businesses: how to size it. JR Batteries, official RelyEZ distributor, supports installers and sites on equipment selection and the technical documentation for the file; the group's engineering team is presented on the JR Énergie page.