PGS 37-1 is the Dutch safety guideline for energy storage systems (EOS): installed, operational battery installations built around lithium batteries that store and release electrical power. Typical examples are neighbourhood and community batteries, wind- and solar-coupled storage, and grid-stabilisation systems. It's the sibling of Pgs 37 2, and the two are easy to mix up.
PGS 37-1 vs PGS 37-2: the difference
- PGS 37-1 = the system in operation. An energy storage system that is installed and running (charging/discharging electricity). The duty sits with the operator of the installation.
- PGS 37-2 = batteries as goods. The storage (warehousing) of lithium batteries and packs as inventory. The duty sits with whoever warehouses them.
The underlying hazard is the same — thermal runaway of lithium cells, with toxic gases and corrosive extinguishing water — but it's a different activity, so a different guideline.
What PGS 37-1 covers
Fire-safety and placement requirements for the installation: detection, suppression, separation distances, and measures to contain a runaway so it doesn't spread to surroundings. The batteries inside are the same Class 9 lithium cells you'll see under UN 3480 / 3481 / 3090 / 3091 when they're transported.
Status (mid-2026): same trajectory as 37-2
Like Pgs 37 2, PGS 37-1 is not yet hard-anchored in the Bal. The Ministry intends to anchor both via the Bal (Omgevingswet) in the course of 2027 (subject to shift). Until then the general duty of care applies and environmental services can already expect reasonable compliance. From 2027 the Bal is set to define when an energy storage system is an environmentally burdensome activity (and when an environmental permit is needed).
How Nexport Logistics fits in
Operating an EOS is the operator's responsibility under PGS 37-1; that's not a forwarder's job. Our role is getting the hardware to you compliantly: importing the batteries and system components, the Dangerous Goods transport (the UN-3480/3481 paperwork), Customs clearance, and compliant storage of the batteries before installation, via partners with the right permit.
Nexport Logistics works as a freight forwarder under the FENEX conditions, with the whole flow visible in the Nexportal portal. Importing an energy storage system or the batteries for one? Email info@nexportlogistics.nl.
Official sources: PGS 37-1 (publication series) · IPLO — PGS 37-1 en 37-2. Related: Pgs 37 2 · Dangerous Goods · Customs