CROSS-STANDARD public interest · Battery energy storage (BESS)

China-to-Armenia BESS Compliance Gap Matrix

AI-compiled from official public sources — cross-checked by multiple AI models, not human-verified. Informational only; see disclaimer. Public-interest, source-linked comparison of common China battery energy storage system documentation against Armenia SARM/EAEU Technical Regulation product conformity requirements, IEC 62619 and IEC 62933 international standards, PSRC grid-connection requirements, ENA (Electric Networks of Armenia) utility interconnection expectations, local fire and building authority approval requirements, UN 38.3 transport requirements for landlocked routing, and 50 Hz grid context — versus China GB/T 36558-2023, GB/T 34120-2023, and NB/T 42090-2016 baselines.

Dataset 2026-06-11 Last verified 2026-06-14 4 rows

GAP MATRIX

Compliance Gap Matrix

Gap matrix
Compliance item Common China baseline Armenia (SARM / PSRC / ENA) Gap / action Source + verification date
BESS Fire Safety Installation — Armenia Local Fire and Building Authority Approval Requirements China manages BESS fire safety under a combination of mandatory standards and project-level fire-safety review. GB 44240-2024 includes fire-safety provisions for BESS cells and modules (mandatory from August 1, 2025). GB/T 36558-2023 and GB/T 36276-2023 cover system-level safety including fire-related requirements. Project-level fire-safety review in China is governed by local fire authority approval procedures. Chinese fire-safety standards and domestic approval procedures are not recognised by Armenian fire authorities as equivalent to Armenian or EAEU-based fire-safety requirements. BESS fire-safety evidence prepared under Chinese standards must be supplemented with IEC-aligned documentation where required by the Armenian local authority having jurisdiction.GB 44240-2024 — 电化学储能系统用二次锂电池安全要求 (includes fire-safety provisions for BESS cells/modules; mandatory, effective August 1, 2025)
GB/T 36558-2023 — 电力系统电化学储能系统通用技术条件 (General Technical Requirements for Electrochemical Energy Storage Systems in Power Systems)		 Fire safety and building permitting for BESS installations in Armenia falls under the authority of local fire safety inspectorates and building permit authorities operating under Armenian law. Armenia does not have a confirmed standalone national technical regulation specifically for stationary BESS fire safety equivalent to NFPA 855 or a dedicated EU storage installation directive as of the dataset date. SARM (National Body of Standards and Metrology of Armenia) adopts international and GOST-based standards; some IEC fire safety standards relevant to BESS — including IEC 62619, IEC 62933-5-1, and IEC 62133 — may be adopted by SARM or referenced in EAEU Technical Regulations applicable to Armenia. Local fire authority approval is required for commercial and industrial BESS installations before commissioning. Project owners and installers must verify the specific local fire code requirements — including acceptable suppression system types, ventilation requirements, separation distances, thermal-runaway mitigation measures, and emergency shutdown procedures — with the local fire authority having jurisdiction over the installation site. Armenian fire standards may draw from both GOST and IEC frameworks given Armenia's dual EAEU membership and independent IEC engagement through SARM.Local fire safety inspectorate (Armenia) — mandatory approval required for commercial and industrial BESS installations before commissioning; specific applicable code must be verified with the authority having jurisdiction
SARM (National Body of Standards and Metrology of Armenia) — national standards body adopting IEC/GOST standards; verify whether IEC 62619, IEC 62933-5-1, or IEC 62133 have been adopted as Armenian national standards (sarm.am)
IEC 62933-5-1:2024 — Electrical Energy Storage Systems — Safety considerations — Hazard identification, risk assessment and risk mitigation (system-level safety standard; may be adopted by SARM or referenced in EAEU Technical Regulations)
IEC 62619:2022 — Safety Requirements for Secondary Lithium Cells and Batteries for Use in Industrial Applications (cell/module safety standard; may be referenced in project specifications)
EAEU Technical Regulations TR CU 004/2011 and TR CU 020/2011 — applicable to in-scope BESS equipment; EAC certification required from an EAEU-accredited certification body		 Gap: Local fire authority approval is a mandatory project gate for commercial and industrial BESS installations in Armenia. Chinese BESS fire-safety documentation based on GB standards does not automatically satisfy Armenian local fire authority requirements. The exact applicable fire code framework (IEC, GOST, or EAEU TR-based) varies by project type and must be confirmed with the local authority having jurisdiction. Exporters and project teams should: (a) confirm with the local Armenian fire authority the applicable fire safety code for the specific installation type, location, and capacity — and whether IEC 62619, IEC 62933-5-1, or IEC 62133 have been adopted as the applicable national standards via SARM; (b) prepare BESS fire-safety design documentation aligned with the confirmed applicable standard — including thermal-runaway propagation mitigation, gas detection or ventilation design, suppression system design, emergency shutdown procedures, and separation distances; (c) where BESS equipment falls under EAEU TR CU 004/2011 (LVD) or TR CU 020/2011 (EMC), ensure EAC certification from an EAEU-accredited certification body is obtained — Chinese GB certifications are not accepted as equivalent; (d) engage a qualified local fire protection engineer familiar with Armenian regulatory requirements for design review and application submission before project commissioning.[INFORMATIONAL] Local fire authority approval is a mandatory installation gate for commercial and industrial BESS in Armenia. Chinese GB-standard fire-safety documentation does not automatically satisfy Armenian local fire authority or EAEU-based requirements. The applicable fire code framework (IEC, GOST, or EAEU TR-based) must be confirmed with the local authority having jurisdiction. Where BESS equipment is in scope under EAEU TR CU 004/2011 or TR CU 020/2011, EAC certification from an EAEU-accredited body is required — this is a genuine pathway for Armenian market access. Engage the local Armenian fire authority and a qualified local fire protection engineer at the earliest project stage to confirm the applicable fire code and design requirements before committing to system layout or equipment specification. SARM — National Body of Standards and Metrology of Armenia2026-06-14 · unverified
ENA / PSRC Grid Connection for BESS — 50 Hz System, IEC 62933, and EAEU-Aligned Connection Requirements China's grid-connection requirements for BESS are governed by GB/T 36558-2023 (General Technical Requirements for Electrochemical Energy Storage Systems in Power Systems) and GB/T 34120-2023 (Technical Specification for Electrochemical Energy Storage System Connected to Distribution Network). The PCS (energy storage converter) is assessed under NB/T 42090-2016 (Technical Code for Testing of Energy Storage Converters). Chinese BESS products are validated by grid operators through National Energy Administration (NEA)-authorised procedures. China's grid operates at 50 Hz, 220/380 V — the same nominal values as Armenia, which means no voltage level re-parameterisation is required at the grid interface level. However, PSRC and ENA protection relay settings, anti-islanding requirements, and SCADA/communication protocol specifications are independent of Chinese NEA approvals and must be met separately.GB/T 36558-2023 — 电力系统电化学储能系统通用技术条件 (General Technical Requirements for Electrochemical Energy Storage Systems in Power Systems)
GB/T 34120-2023 — 电化学储能系统接入配电网技术规范 (Technical Specification for Electrochemical Energy Storage System Connected to Distribution Network)
NB/T 42090-2016 — 储能变流器检测技术规程 (Technical Code for Testing of Energy Storage Converters)		 ENA (Electric Networks of Armenia) is the main electricity distribution network operator in Armenia, responsible for grid connection of distributed and utility-scale generation and storage assets. The Public Services Regulatory Commission (PSRC) is the sector regulator that sets rules for grid-connected energy installations. All grid-connected BESS installations in Armenia require PSRC-authorised technical review and ENA interconnection approval. Armenia's grid operates at 50 Hz, 220/380 V (same nominal frequency and voltage as China), which reduces the voltage-reconfiguration burden on Chinese BESS power conversion systems (PCS) compared to markets such as Qatar (240/415 V). However, PSRC and ENA define their own protection parameter specifications, communication interface requirements, and technical acceptance criteria — Chinese GB/T grid-connection certificates and NEA approvals are not transferable. Armenia is an EAEU member and EAEU Technical Regulations may impose additional requirements on in-scope BESS equipment. Where project specifications reference IEC 62933 (Electrical Energy Storage Systems) series standards including IEC 62933-2-1 and IEC 62933-5-2, BESS suppliers must prepare documentation accordingly. A publicly accessible PSRC or ENA technical specification document specifically for BESS grid connection had not been confirmed as of the dataset date; project-specific connection terms must be obtained directly from PSRC and ENA.PSRC (Public Services Regulatory Commission of Armenia) — regulatory authority for grid-connected energy installations; technical requirements are project-specific and defined in connection agreements
ENA (Electric Networks of Armenia) — distribution network operator; interconnection approval required for all grid-connected BESS
IEC 62933-2-1:2017+AMD1:2021 — Electrical Energy Storage Systems — Unit Parameters and Testing Methods — General Specification (expected project-specification reference)
IEC 62933-5-2 — Electrical Energy Storage Systems — Safety Requirements — Electrochemical-based systems (expected project-specification reference)
EAEU Technical Regulations TR CU 004/2011 and TR CU 020/2011 — may impose in-scope equipment requirements; verify with SARM or an EAEU-accredited certification body		 Gap: Chinese GB/T BESS grid-connection certificates and NEA approvals do not satisfy PSRC/ENA grid-connection requirements in Armenia. Key considerations: (a) grid voltage and frequency — Armenia and China share the same 50 Hz, 220/380 V nominal values, reducing voltage-reconfiguration burden; however, PSRC/ENA-specific protection relay settings, anti-islanding parameters, and ride-through thresholds must be verified and configured to Armenian specifications; (b) PSRC and ENA project-specific connection agreement terms — engage PSRC and ENA at the earliest project stage to obtain technical requirements before equipment design is finalised; (c) IEC 62933 series compliance — where project specifications require IEC 62933-2-1 or IEC 62933-5-2 evidence, prepare test and design documentation accordingly; Chinese GB/T standards are not accepted as equivalent; (d) EAEU compliance — where in-scope under EAEU TR CU 004/2011 (LVD) or TR CU 020/2011 (EMC), EAC certification from an EAEU-accredited certification body is required for the BESS equipment; Chinese GB certifications are not accepted; (e) communication protocols — confirm the SCADA/communication interface protocol required by ENA for BESS monitoring (IEC 61850, Modbus, or project-specific specification); (f) renewable integration context — Armenia's grid is experiencing solar growth and PSRC may impose specific grid-support requirements (frequency response, reactive power) for storage assets.[INFORMATIONAL] Chinese GB/T BESS grid-connection compliance and NEA approvals do not satisfy PSRC/ENA Armenia grid-connection requirements. Armenia and China share the same 50 Hz, 220/380 V nominal grid parameters, reducing voltage-level reconfiguration burden; however, PSRC/ENA protection settings, anti-islanding requirements, and SCADA/communication specifications must be met independently. Where BESS equipment is in scope under EAEU TR CU 004/2011 or TR CU 020/2011, EAC certification from an EAEU-accredited body is required — this is a genuine pathway unique to EAEU member states. Engage PSRC and ENA at the earliest project stage to determine connection agreement technical requirements, applicable IEC 62933 evidence, and SCADA/communication protocol specifications before equipment procurement is finalised. Public Services Regulatory Commission of Armenia (PSRC)2026-06-14 · unverified
Cell and Module Safety — EAEU TR CU / EAC Certification and IEC 62619 as Compliance Gates for Armenia BESS China's primary mandatory standard for BESS cells from August 2025 is GB 44240-2024 (Secondary Lithium Cells and Batteries Used in Electrical Energy Storage Systems — Safety Requirements), which replaces the prior GB/T 36276 series as the mandatory safety baseline for large-format BESS batteries over 100 kWh. The prior voluntary standard GB/T 36276-2023 (Lithium-Ion Batteries for Electrical Energy Storage) provides the technical framework for cells, modules, and battery clusters used in EES. Chinese CCC (China Compulsory Certification) applies to certain battery product categories domestically. These Chinese standards and CCC marks are not accepted as equivalents to EAEU TR CU / EAC requirements in Armenia. Exporters must obtain EAC certification from an EAEU-accredited certification body for in-scope BESS equipment, in addition to any IEC 62619 evidence required by project specifications.GB 44240-2024 — 电化学储能系统用二次锂电池安全要求 (Secondary Lithium Cells and Batteries Used in Electrical Energy Storage Systems — Safety Requirements; mandatory, effective August 1, 2025)
GB/T 36276-2023 — 电力储能用锂离子电池 (Lithium-Ion Batteries for Electrical Energy Storage; voluntary, effective July 1, 2024)		 Armenia is a member of the Eurasian Economic Union (EAEU), which means EAEU Technical Regulations (TR CU / TR EAEU) and the EAC (Eurasian Conformity) mark are mandatory for in-scope products placed on the Armenian market. This is a critical difference from non-EAEU markets: the EAC certification route is a genuine mandatory pathway for Chinese BESS exporters to Armenia — not an optional add-on. The primary EAEU Technical Regulations applicable to BESS equipment are TR CU 004/2011 (On the Safety of Low-Voltage Equipment) and TR CU 020/2011 (Electromagnetic Compatibility of Technical Products). EAC certification must be obtained from an EAEU-accredited certification body (not a Chinese certification body); Chinese GB certifications and CCC marks are not accepted as equivalent. SARM (National Body of Standards and Metrology of Armenia) is Armenia's national standards body within the EAEU framework. SARM may adopt IEC standards nationally — including IEC 62619:2022 (Safety Requirements for Secondary Lithium Cells and Batteries for Use in Industrial Applications) and IEC 62133 — as the technical basis for BESS cell and module safety assessments alongside or within EAEU TR requirements. IEC 62619 is also the internationally expected safety standard referenced in project specifications for utility-scale and C&I BESS projects. Exporters must verify: (a) which EAEU TR CU apply to their specific BESS product configuration; (b) whether SARM has adopted IEC 62619 as an Armenian national standard; and (c) any additional product registration, customs union import permit, or PSRC/ENA technical acceptance requirements.EAEU TR CU 004/2011 — On the Safety of Low-Voltage Equipment (mandatory EAC certification required for in-scope BESS equipment; Chinese GB/CCC not accepted as equivalent)
EAEU TR CU 020/2011 — Electromagnetic Compatibility of Technical Products (mandatory EAC certification required for in-scope BESS equipment)
IEC 62619:2022 — Safety Requirements for Secondary Lithium Cells and Batteries for Use in Industrial Applications (internationally expected baseline for BESS cell/module safety in project specifications; may be adopted by SARM as Armenian national standard — verify with sarm.am)
IEC 62133 — Safety requirements for portable sealed secondary lithium cells and batteries (may be relevant for module-level assessment; verify SARM adoption status)
IEC 62933-5-1:2024 — Electrical Energy Storage Systems — Safety considerations — Hazard identification, risk assessment and risk mitigation (system-level safety standard; may be referenced in project specifications)
SARM — National Body of Standards and Metrology of Armenia (verify current adopted national standards for BESS at sarm.am)		 Critical gap (dual): (1) EAEU EAC certification gap — Armenia is an EAEU member and TR CU 004/2011 (LVD) and TR CU 020/2011 (EMC) are mandatory for in-scope BESS equipment. Chinese GB 44240-2024, GB/T 36276-2023, and CCC marks are not accepted as substitutes for EAC certification. Exporters must engage an EAEU-accredited certification body to determine which TR CU apply to their product configuration and to obtain EAC certification before market placement. (2) IEC 62619 evidence gap — project owners and project specifications for utility-scale and C&I BESS in Armenia are expected to reference IEC 62619 as the technical safety baseline for cells and modules, consistent with international project practice. Chinese GB standards are not harmonised with IEC 62619 and are not accepted as substitutes in project technical specifications. Exporters should: (a) determine EAC certification scope via an EAEU-accredited certification body; (b) obtain IEC 62619 type-test certificates from an ILAC-accredited laboratory for cells and modules supplied to Armenian BESS projects; (c) verify with SARM (sarm.am) whether IEC 62619 or IEC 62133 have been adopted as Armenian national standards; (d) confirm the applicable IEC 62619 edition referenced in the project specification before committing to a test programme.[INFORMATIONAL] Armenia's EAEU membership means EAC certification under TR CU 004/2011 (LVD) and TR CU 020/2011 (EMC) is a mandatory gateway for in-scope BESS equipment — this is a genuine and enforceable requirement that does not apply in non-EAEU markets. Chinese GB 44240-2024, GB/T 36276-2023, and CCC certifications alone are not sufficient for Armenian market placement. In addition, IEC 62619 is the internationally expected technical baseline for BESS cell and module safety in project specifications. Verify EAEU TR CU applicability with an EAEU-accredited certification body, obtain EAC certification for in-scope equipment, confirm IEC 62619 evidence requirements with the project owner, and verify SARM's current adopted national standards for BESS (sarm.am) before shipment. International Electrotechnical Commission (IEC)2026-06-14 · unverified
UN 38.3 Transport Safety Testing — Mandatory for Lithium Battery Shipments to Armenia (Landlocked Routing) Chinese BESS cell and module manufacturers are required to comply with UN 38.3 for export shipments under international transport conventions. Chinese manufacturers typically hold UN 38.3 test reports and test summaries from CNAS-accredited testing laboratories such as UL, SGS, Bureau Veritas, TÜV, or CAICT. The UN 38.3 Test Summary (required since January 1, 2020) must cover the specific cell or battery type being shipped. A Chinese-origin UN 38.3 test summary from an accredited laboratory is acceptable for Armenia-bound shipments provided it covers the specific cell model, chemistry, capacity, and configuration of the BESS units being shipped. The key additional complexity for Armenia versus sea-port destinations is the multi-modal, multi-jurisdiction routing: exporters must ensure UN 38.3 and dangerous-goods documentation is valid under IMDG (sea leg), ADR (road leg through Georgia and Armenia), and any SMGS requirements (rail leg if applicable), and that transit documentation satisfies Georgian and Iranian customs and dangerous-goods authorities along the transit route.UN 38.3 test reports and test summaries from CNAS-accredited Chinese laboratories (CAICT, UL China, SGS China, Bureau Veritas China, TÜV Rheinland China) — acceptable for international transport if the test summary covers the specific cell/battery type being shipped
IMDG, ADR, and SMGS compliance required for multi-modal routing to landlocked Armenia — Chinese DG agents must coordinate across all transit legs		 UN 38.3 (Recommendations on the Transport of Dangerous Goods — Manual of Tests and Criteria, Part III, Section 38.3) specifies eight mandatory transport safety tests (T1 Altitude Simulation, T2 Thermal Test, T3 Vibration, T4 Shock, T5 External Short Circuit, T6 Impact/Crush, T7 Overcharge, T8 Forced Discharge) for lithium metal and lithium-ion cells and batteries of all sizes including cells, modules, and battery packs used in stationary BESS. Since January 1, 2020, a UN 38.3 Test Summary is mandatory documentation that must accompany lithium battery shipments under international transport regulations (IATA DGR, IMDG Code, ADR). Armenia is a landlocked country. Shipments from China typically route via: (a) Georgia/Poti port — sea freight from China to Poti (Georgia), then overland to Armenia via Georgia; or (b) Iran — overland via Iran. Both routing options involve multi-modal transport and cross-border dangerous-goods documentation under ADR (European Agreement concerning the International Carriage of Dangerous Goods by Road), SMGS (rail), or IMDG (sea leg). Each transit jurisdiction's dangerous-goods requirements must be satisfied in addition to Armenia's domestic import requirements. UN 38.3 Test Summaries must be current and cover the specific cell/module type being shipped. There is no Armenia-specific exemption from UN 38.3.UN 38.3 — Recommendations on the Transport of Dangerous Goods, Manual of Tests and Criteria, Part III, Section 38.3 (mandatory transport safety tests T1–T8 for all lithium cells and batteries)
IMDG Code — applies to the sea freight leg (China to Poti, Georgia) of lithium battery shipments
ADR — European Agreement concerning the International Carriage of Dangerous Goods by Road (applies to overland transit through Georgia and within Armenia)
SMGS — Agreement on International Goods Transport by Rail (may apply if rail routing is used)
UN Model Regulations, 7th revised edition (2021) — Test Summary requirement in force since January 1, 2020
IATA Dangerous Goods Regulations (DGR) — applies if any air freight leg is used		 The UN 38.3 gap is documentation scope, currency, and multi-modal routing complexity — not standard equivalence. UN 38.3 is a universal requirement and Chinese-origin test summaries from accredited laboratories are accepted for Armenia-bound shipments. However, the landlocked routing adds significant documentation and logistics complexity. Exporters should verify: (a) the UN 38.3 test summary covers the specific cell model (including chemistry, capacity, and format) being exported — a summary for a different cell model or capacity is not transferable; (b) the test summary is from a currently accredited laboratory; (c) any cell design change (electrolyte, separator, electrode, BMS firmware affecting charge/discharge) since the original UN 38.3 testing triggers a reassessment requirement; (d) module-level and battery-pack-level assemblies may require separate UN 38.3 assessment if they constitute a battery as defined under international transport regulations; (e) dangerous-goods documentation, packaging, marking, and labelling must comply with IMDG for the sea leg to Poti (Georgia), ADR for the overland leg through Georgia and Armenia, and (if applicable) SMGS for any rail segment; (f) transit permits and dangerous-goods approvals may be required from Georgian and/or Iranian authorities depending on the routing; (g) a specialist dangerous-goods freight forwarder with experience in China-to-Caucasus and China-to-Armenia logistics is strongly recommended to coordinate all transit documentation.[INFORMATIONAL] UN 38.3 transport compliance is universal — a Chinese-origin test summary from an accredited laboratory is accepted for Armenia-bound shipments provided it covers the specific cell model and is current. The primary risks are: (1) scope mismatch (wrong cell model or capacity in the summary) or an outdated summary after a cell design change; and (2) landlocked routing complexity — shipments via Georgia/Poti port or Iran require multi-modal dangerous-goods documentation under IMDG (sea leg), ADR (road leg), and potentially SMGS (rail leg), with transit permits and dangerous-goods approvals potentially required from Georgian and/or Iranian authorities. Engage a specialist dangerous-goods freight forwarder experienced in China-to-Armenia routing to coordinate all documentation across transit jurisdictions before shipment. United Nations Economic Commission for Europe (UNECE) — Recommendations on the Transport of Dangerous Goods2026-06-14 · unverified

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