ICPE 2925: Accumulator and electric vehicle charging workshops

ICPE heading 2925 covers electric battery charging workshops. Learn how facilities and equipment used for charging electric batteries are regulated. Read the full article to better understand these new regulations!

Fabien Gélisse
Consultant HSE
Mise à jour : 
22.06.2026
Publication : 
17.02.2025
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🔎 Key takeaways

  • Strict battery regulations: ICPE heading 2925 strictly regulates the charging power of professional electrical installations (forklifts, UPS systems, charging stations), distinguishing between workshops that emit hydrogen (lead-acid, 50 kW threshold) and those that do not (lithium-ion, 600 kW threshold).
  • The crucial public domain exception: Given the rise of electric vehicles, regulations completely exempt publicly accessible charging infrastructure from classification, but private charging stations installed at workplaces are subject to the law if they are intended for employees or internal fleets.
  • A globalized power calculation: A recent ministerial note clarifies the rules by specifying that the term "workshops" applies to both indoor and outdoor areas, and requires the power of all equipment on a single site to be aggregated to determine if declaration thresholds have been met.
  • Regulatory changes on the horizon: While these activities are currently governed by general requirements orders dating back to 2000 and 2018, a new draft ministerial order is being prepared to specifically address the risks associated with outdoor lithium-based technologies.

    • Please note: This article concerns French legislation. The requirements described may not apply in other countries.

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    ICPE heading 2925 covers electric battery charging workshops.

    This heading regulates facilities where electric batteries are charged. Consequently, equipment that may trigger classification under this heading includes:

    • Battery Energy Storage Systems (BESS)
    • Uninterruptible Power Supplies (UPS)
    • Chargers for material handling equipment (forklifts, aerial work platforms, etc.)
    • Charging stations for electric vehicles

    In the context of recent requirements for installing charging stations for electric vehicles, we provide a detailed breakdown of the classification procedures under this heading.

    Heading for section no. 2925

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

    Section no. 2925-1 covers electric battery charging workshops where the charging process produces hydrogen.

    This specifically applies to lead-acid batteries.

    Description Classification regime
    2925-1:
    Where charging produces hydrogen, and the maximum direct current power usable for this operation is greater than 50 kW     		Declaration

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    Section no. 2925-2 covers electric battery charging workshops where the charging process does not produce hydrogen.

    This specifically applies to lithium-ion type batteries. Electric vehicle charging stations therefore fall within the scope of this sub-section no. 2925-2.

    Description Classification regime
    2925-2:
    Where charging does not produce hydrogen, and the maximum current usable for this operation is greater than 600 kW, except for electric vehicle charging infrastructure open to the public as defined by Decree No. 2017-26 of 12 January 2017 on electric vehicle charging infrastructure, transposing various measures of Directive 2014/94/EU of the European Parliament and of the Council of 22 October 2014 on the deployment of alternative fuels infrastructure.     		Declaration

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    Note: as indicated in the heading for section no. 2925-2, charging infrastructure open to the public is exempt from any classification.

    This refers to charging infrastructure, a charging station, or a charging point located on public or private property to which users have non-discriminatory access. Non-discriminatory access does not preclude the imposition of certain conditions regarding authentication, usage, and payment.

    Clarifications on classification procedures under section no. 2925

    A ministerial note dated December 20, 2024, published on the INERIS AÏDA website, provides clarification on the classification procedures for this section regarding:

    • The definition of charging workshops;
    • The classification of facilities distributed across a site;
    • The classification of light electric vehicle charging stations in outdoor parking areas not open to the public.

    • Concept of charging workshops

    This note reviews the concept of "charging workshops." The term "workshop" should be understood in a broad sense; it refers to the location where the activity is carried out, whether that location is a covered space or not.

    Thus, battery charging falls under heading no. 2925 in various configurations: inside buildings and in outdoor parking areas.

    Charging stations for light electric vehicles installed in parking areas not open to the public, both indoors and outdoors, may be classified under heading 2925-2.

    • Calculating charging power for a single site

    This note explains how to calculate power at the site level: all equipment, regardless of type or use (ESS, EV charging stations, charging rooms, forklifts, vehicles, etc.) falling under heading 2925 and operated by the same operator on a site must be aggregated to determine if the power exceeds the classification threshold.

    Therefore, for a single operator on a single site, the following must be aggregated:

    • On one hand, the power of all installations capable of emitting hydrogen during charging, to be compared against the threshold for heading no. 2925-1
    • On the other hand, the power of all installations not capable of emitting hydrogen during charging, to be compared against the threshold for heading no. 2925-2/

    A single site may therefore be classified under both sub-headings.

    • Classification of light electric vehicle charging stations in outdoor parking areas not open to the public

    This note clarifies the definition of a charging station open to the public, as referred to in the wording of this ICPE heading.

    Charging stations for light vehicles or heavy goods vehicles located within company premises are not considered charging points open to the public. They are therefore not excluded and may be subject to this classification if the maximum power usable for this operation exceeds the 600 kW threshold.

    Technical requirements for operating this activity

    Several ministerial orders setting out general requirements may apply to a site classified under heading no. 2925:

    • Order of May 29, 2000, regarding general requirements applicable to installations classified for environmental protection subject to declaration under heading no. 2925 (battery charging workshops):
      This order currently applies to all workshops classified under heading no. 2925 (both for heading no. 2925-1 and 2925-2), with the exception of workshops specifically covered by the second text cited below.
    • Order of August 3, 2018, regarding the general requirements applicable to charging workshops containing at least 10 public transport vehicles of category M2 or M3 powered by electrical energy and subject to declaration under heading no. 2925 of the nomenclature of installations classified for the protection of the environment:

    These workshops are generally governed today by heading no. 2925-2 (as vehicle batteries generally do not emit hydrogen during charging).

    Furthermore, a new order of requirements specifically applicable to workshops classified under heading no. 2925-2 located outdoors and using lithium technologies is currently being drafted. This new order will therefore apply in particular to charging infrastructure and stations for electric vehicles not open to the public with a cumulative power output exceeding 600 kW.

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