ICPE : Battery and electric vehicle charging workshops

Heading 2925 of the nomenclature of classified installations concerns workshops for charging electric accumulators.

This heading covers installations where electric batteries are charged. Equipment that could potentially be classified under this heading may be :

• Battery energy storage systems (BESS)
• Electrical inverters
• Loaders for handling equipment (forklift trucks, aerial work platforms, etc.)
• Charging stations for electric vehicles

In view of recent requirements for the installation of charging stations for electric vehicles, we suggest that you take a look at the procedures for classification under this heading.

Title of heading n° 2925

Heading no. 2925 was last amended by Decree no. 2019-1096 of October 28, 2019. It is now divided into two headings.

Heading no. 2925-1 concerns workshops for charging electric accumulators when the charge produces hydrogen.

This applies in particular to lead-acid batteries.

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Heading no. 2925-2 concerns workshops for charging electric accumulators when the charge does not produce hydrogen.

These include lithium-ion batteries. Electric vehicle charging stations therefore fall within the scope of this sub-heading n° 2925-2.

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Note: as indicated in the heading of item no. 2925-2, recharging infrastructures open to the public are exempt from classification.

This is a recharging infrastructure or recharging station or recharging point located on public or private land, to which users have non-discriminatory access. Non-discriminatory access does not preclude the imposition of certain conditions in terms of authentication, use and payment.

Details of classification procedures for heading no. 2925

A note from the Ministry dated December 20, 2024, published on the INERIS AÏDA website, clarifies the classification procedures under this heading with regard to :

• The concept of load shops ;
• The classification of installations spread over a site;
• Classification of charging points for light electric vehicles in outdoor parking areas not open to the public.

• Notion of load shops

This note reviews the concept of "load workshops". The notion of "workshop" is to be understood in the broadest sense of the term: it refers to the place where the activity is carried out, whether the place is a covered space or not.

The charging of batteries therefore comes under heading 2925 in the various configurations: in buildings and on open-air parking areas.

Electric vehicle charging stations for light vehicles, installed in parking areas not open to the public, both inside and outside buildings, are likely to be classified under heading 2925-2.

• Calculation of load power at a single site

This note explains how power is calculated at site level: all equipment, whatever its type or use (ESS, IRVE terminals, charging rooms, carts, vehicles, etc.) falling under heading 2925 operated by the same operator on a site must be added together to check whether power exceeds the classification threshold.

For a single operator, this means combining the following for a single site:

• On the one hand, the power of all installations that may emit hydrogen during charging, and to compare with the threshold of heading no. 2925-1.
• On the one hand, the power of all the installations that cannot emit hydrogen during charging, and to compare with the threshold of heading no. 2925-2/ on the other hand, the power of all the installations that cannot emit hydrogen during charging, and to compare with the threshold of heading no. 2925-2/ on the other hand.

The same site can therefore be classified under both subheadings.

• Classification of charging points for light electric vehicles in outdoor parking areas not open to the public

This note sets out the definition of a recharging station open to the public, as referred to in the wording of this ICPE heading.

Charging stations for both light and heavy-duty vehicles, located on company premises, are not considered to be charging points open to the public. They are therefore not excluded, and are likely to be concerned by this classification if the maximum current power usable for this operation exceeds the 600 kW threshold.

Technical requirements for the operation of this activity

Several ministerial decrees on general requirements may apply to a site classified under heading no. 2925:

• Arrêté du 29 mai 2000 relatif aux prescriptions générales applicables aux installations classées pour la protection de l'environnement soumises à déclaration sous la rubrique n° 2925 accumulateurs (ateliers de charge d') :
  This decree currently applies to all workshops classified under heading no. 2925 (whether for heading no. 2925-1 or 2925-2), with the exception of workshops specifically covered by the second text cited below.
• Arrêté du 3 août 2018 relatif aux prescriptions générales applicables aux ateliers de charge contenant au moins 10 véhicules de transport en commun de catégorie M2 ou M3 fonctionnant grâce à l'énergie électrique et soumis à déclaration sous la rubrique n° 2925 de la nomenclature des installations classées pour la protection de l'environnement :

Today, these workshops are generally covered by heading no. 2925-2 (vehicle batteries are generally batteries that do not emit hydrogen during charging).

In addition, the publication of a new regulations order applying specifically to workshops classified under heading no. 2925-2 located outdoors and using lithium technologies is currently in the planning stage. This new order will apply in particular to charging infrastructures and stations for electric vehicles not open to the public, with a combined power rating of over 600 kW.