PGS 37-2 is the Dutch safety guideline for storing lithium-containing energy carriers: lithium-ion and lithium-metal batteries and battery packs, home/buffer batteries, e-bike and EV batteries, and energy storage systems. It came about after a string of fires where lithium batteries (think e-bikes) went into thermal runaway, and the regulator had to act. This is part of the Dangerous Goods picture, on the storage side rather than transport.
Why lithium storage is treated so seriously
A damaged, overcharged or overheated lithium cell can go into thermal runaway: a self-sustaining fire that's hard to extinguish, releases toxic pyrolysis gases, and produces corrosive, toxic extinguishing water that endangers firefighters and the surroundings. One bad cell in a full warehouse is a major incident. That's the reason PGS 37-2 sets heavy fire-safety expectations: detection, fire suppression such as sprinklers, separation distances and quantity limits.
The UN numbers involved (all Class 9)
Lithium batteries are dangerous goods in Class 9, under these UN numbers:
- UN 3480: lithium-ion batteries (stand-alone)
- UN 3481: lithium-ion batteries packed with, or contained in, equipment
- UN 3090: lithium-metal batteries (stand-alone)
- UN 3091: lithium-metal batteries packed with, or contained in, equipment
- UN 3536: lithium batteries installed in a cargo transport unit
Damaged or defective cells carry extra special provisions. These are the codes you'll see on the transport documents that arrive with the goods you then need to store.
The catch: very few facilities actually comply
The requirements (especially fire suppression / sprinklers and separation) are strict, and many existing warehouses don't meet them. They have no sprinkler system. So if PGS 37-2 were hard-enforced overnight, a large part of the market would simply have nowhere compliant to store lithium batteries. That impact is the reason the rollout has been so controversial.
Status (mid-2026): not yet a hard obligation
PGS 37-2 exists as a guideline (current version PGS 37-2:2023, v1.1, April 2026), but its legal anchoring in the Bal (under the Omgevingswet) has been postponed several times. The internet consultation on the amendment ran March–April 2026; entry into force is now expected in the course of 2027, and the ministry warns this may still shift. Until then PGS 37-2 is not a hard obligation on its own. Don't read that as "no rules", though: under the general duty of care (zorgplicht) the environmental services (omgevingsdiensten) can already expect reasonable compliance. From 2027 the Bal is set to define when lithium storage counts as an environmentally burdensome activity (then an environmental permit is needed; otherwise you follow PGS 37-2). Operating an installed battery system is a separate guideline — see Pgs 37 1. Because this is moving, always check the current status at the official source.
"Not anchored" — so free storage? No
A common misconception. IMDG/IMO Class 9 (and ADR) govern transport, not storage: they classify the batteries (UN 3480 etc.) while they move, but give you no storage regime. Even without PGS 37-2 anchored, you remain bound by the general duty of care, your site's environmental permit, fire-safety/building rules (Bbl) and occupational-safety (Arbo) law. And your insurer typically demands measures regardless. Environmental services already use PGS 37-2 as the benchmark. So lithium batteries can't simply be stored "freely"; what's missing is one hard, uniform PGS 37-2 obligation, not the rules themselves.
How Nexport Logistics handles lithium storage
We keep our own warehouse for non-hazardous goods. For lithium batteries and other hazardous energy carriers we work with trusted partners that hold the right permit and the right facility for the substance and quantity, so your batteries are stored safely and lawfully even while the rules are in flux. We also handle the Dangerous Goods transport (the UN-3480/3481 paperwork) and the Customs side in one flow.
Nexport Logistics works as a freight forwarder under the FENEX conditions, with everything visible in the Nexportal portal. Importing or storing lithium batteries? Email info@nexportlogistics.nl and we'll route your shipment to a facility that's actually compliant.
Official sources: PGS 37-2 — Lithiumhoudende energiedragers: Opslag · IPLO — PGS 37-1 en 37-2. Further reading: internetconsultatie — wijzigingsbesluit opslag elektrische energie. Related: Pgs 37 1 · Dangerous Goods · Customs