The legal anchoring of PGS 37-2 — the Dutch guideline for the safe storage of lithium-containing energy carriers (li-ion and lithium-metal batteries, packs and battery-powered products) — has been postponed once more. Entry into force via the Bal (Besluit activiteiten leefomgeving, under the Omgevingswet) is now expected in the course of 2027.
Where the process stands
- The internet consultation on the amendment decree ran from 27 March to 28 April 2026; the ministry is now processing the responses.
- The ministry itself warns that the planning can still shift if there are setbacks — it would not be the first time: the anchoring has now been postponed several times.
- The same amendment also anchors PGS 37-1 (installed, operational energy-storage systems such as neighbourhood batteries).
No anchoring ≠ no rules
Until the Bal amendment takes effect, PGS 37-2 is not a hard legal obligation on its own. But don't read the delay as breathing room: under the general duty of care (zorgplicht) environmental services already treat PGS 37-2 as the benchmark for safe lithium storage, and permits for new sites are in practice written against it. The requirements — think fire suppression, compartmentalisation and separation distances — are substantial, and many existing warehouses do not meet them yet.
What this means if you store or import batteries
If you import or store lithium batteries, e-bikes, power tools or energy-storage products, the sensible course is unchanged: don't wait for the formal date. Sites that prepare now avoid scrambling when the obligation lands — and avoid discussions with their environmental service and insurer today. For the full picture of what PGS 37-2 covers, the UN numbers involved and how it differs from PGS 37-1, see our guide: PGS 37-2 (lithium battery storage).
Source: IPLO — PGS 37-1 en 37-2 · Internetconsultatie — wijzigingsbesluit opslag elektrische energie.