CROSS-STANDARD public interest · Battery energy storage (BESS)
China-to-Madagascar 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 Madagascar BNM conformity assessment requirements, ORE electricity regulatory licensing, JIRAMA grid-connection requirements, ADER off-grid electrification standards (IEC TS 62257, VeraSol), IEC 62619 and IEC 62933 international safety standards, UN 38.3 transport requirements, and Madagascar's 220/380 V 50 Hz grid context — versus China GB/T 36558-2023, GB/T 34120-2023, and NB/T 42090-2016 baselines.
GAP MATRIX
Compliance Gap Matrix
| Compliance item | Common China baseline | Madagascar (BNM / ORE / JIRAMA) | Gap / action | Source + verification date |
|---|---|---|---|---|
| BESS Fire Safety Installation — Madagascar Local Fire and Building Authority Requirements | China manages BESS fire safety under a combination of mandatory standards and project-level fire-safety review. GB 44240-2024 (Secondary Lithium Cells and Batteries Used in Electrical Energy Storage Systems — Safety Requirements, mandatory from August 1, 2025) includes fire-safety provisions for BESS cells and modules. GB/T 36276-2023 and GB/T 36558-2023 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 in Madagascar as equivalent to IEC 62619 or IEC 62933-5-2. Donor-financed BESS projects in Madagascar require IEC-standard fire-safety evidence regardless of Chinese GB compliance. BESS fire-safety design must be documented in French for Madagascar local authority review.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) |
Madagascar does not have a confirmed standalone mandatory national BESS fire-safety installation regulation equivalent to NFPA 855 or IEC 62933-5-2 enforced by a central authority as of the dataset date. Fire safety for commercial and industrial installations in Madagascar is administered through the local fire and building authority (Direction Générale de la Sécurité Civile and municipal building inspection bodies). For BESS projects — particularly utility-scale and C&I installations — international safety standards are typically required by project owners and donor/lender technical specifications. IEC 62619:2022 covers safety requirements for lithium cells and modules including thermal abuse tolerance and failure mode requirements relevant to fire risk. IEC 62933-5-2 covers electrochemical BESS system-level safety requirements including hazard mitigation relevant to fire prevention. For off-grid and mini-grid BESS projects financed by the World Bank, AfDB, or through ADER, project-level environmental and social risk management frameworks (e.g., World Bank Environmental and Social Standards ESS1/ESS3) and donor technical specifications typically require evidence of compliance with IEC 62619 and IEC 62933-5-2 as minimum safety baselines. No Madagascar-specific BESS fire code equivalent to NFPA 855 has been confirmed from official sources. Exporters and project teams should confirm applicable fire and building requirements with Madagascar local authorities, the project owner, and any appointed lender technical adviser (LTA) for the specific installation site.IEC 62619:2022 — Safety Requirements for Secondary Lithium Cells and Batteries for Use in Industrial Applications (internationally expected safety baseline for BESS cells/modules; required in donor-financed project specifications) IEC 62933-5-2 — Electrical Energy Storage Systems — Safety Requirements — Electrochemical-based systems (system-level safety standard; required in donor-financed project specifications) IEC 62933-5-1:2024 — Electrical Energy Storage Systems — Safety considerations — Hazard identification, risk assessment and risk mitigation Direction Générale de la Sécurité Civile (Madagascar) — local fire authority; confirm site-specific fire-safety installation requirements directly World Bank Environmental and Social Standards (ESS1, ESS3) — applicable to World Bank-financed projects; require IEC-standard safety evidence for BESS |
Gap: Madagascar does not have a confirmed nationally mandated BESS fire-safety installation code equivalent to NFPA 855. However, donor-financed and IPP-led BESS projects are subject to project-level fire-safety requirements based on IEC 62619 and IEC 62933-5-2 as the internationally expected safety baselines. Chinese GB-standard fire-safety documentation does not satisfy these requirements. Project teams should: (a) confirm applicable local fire and building authority requirements for the specific installation municipality in Madagascar — engage the Direction Générale de la Sécurité Civile and local building inspection body at the earliest project stage; (b) obtain IEC 62619 test evidence from an ILAC-accredited laboratory for cells and modules, and IEC 62933-5-2 design compliance documentation for the BESS system; (c) prepare BESS fire-safety design documentation in French, including thermal-runaway propagation mitigation, gas detection or ventilation design, emergency shutdown procedures, and separation distances; (d) confirm donor/lender (World Bank, AfDB) environmental and social risk requirements for fire-safety evidence with the project's appointed lender technical adviser (LTA) before equipment specification is finalised; (e) note that BNM (Bureau des Normes de Madagascar) may require conformity assessment evidence for imported electrical equipment — confirm BNM scope for BESS directly with BNM.[INFORMATIONAL] No confirmed nationally mandated BESS fire-safety installation code has been identified for Madagascar as of the dataset date. Donor-financed and IPP-led BESS projects require IEC 62619 and IEC 62933-5-2 safety evidence as the internationally expected baseline — Chinese GB-standard documentation does not satisfy this requirement. Confirm site-specific local fire and building authority requirements with Madagascar local authorities before installation design is finalised. Prepare French-language fire-safety design documentation for local authority review. Engage the lender technical adviser (LTA) for any World Bank or AfDB-financed project to confirm donor environmental and social risk requirements for fire safety. | International Electrotechnical Commission (IEC)2026-06-14 · unverified |
| JIRAMA Grid Connection for BESS — 50 Hz System, IEC 62933, ORE Licensing, and Project-Specific 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 — nominally identical to Madagascar's grid voltage. This reduces the voltage-level reconfiguration risk for PCS, but Chinese grid-connection approvals and NEA procedures are not transferable to Madagascar: JIRAMA and ORE operate independent regulatory frameworks and the grid characteristics (low system inertia, diesel-hybrid topology, variable frequency range) differ materially from the large interconnected grids in China for which Chinese grid codes are designed.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) |
JIRAMA (Jiro sy Rano Malagasy — Madagascar Electricity and Water Company) is the national utility responsible for electricity generation, transmission, and distribution in Madagascar. Grid-connected BESS projects require JIRAMA technical review and grid-connection agreement. The Office de Régulation de l'Electricité (ORE) is the electricity sector regulator and issues operating licences for electricity generation, storage, and supply activities. All grid-connected BESS projects — including utility-scale and behind-the-meter installations — require both an ORE licence and JIRAMA connection approval before commissioning. Madagascar's grid operates at 220/380 V 50 Hz (220 V single-phase, 380 V three-phase), nominally the same voltage system as China, which reduces PCS voltage reconfiguration risk compared with markets operating at different nominal voltages. However, JIRAMA grid stability, power quality parameters, and protection relay settings may differ from those used in China due to Madagascar's predominantly diesel-hybrid and small-hydro grid infrastructure with low system inertia. Project-specific connection agreement terms must be obtained directly from JIRAMA. ORE and JIRAMA may reference IEC 62933 (Electrical Energy Storage Systems) series standards — including IEC 62933-5-2 (Safety Requirements for electrochemical-based systems) and IEC 62933-2-1 (Unit Parameters and Testing Methods) — in project specifications and connection agreements for grid-scale BESS, particularly for donor-financed projects under World Bank or AfDB technical specifications. Madagascar's overall electrification rate is approximately 35%, making BESS critical for solar mini-grid, diesel-hybrid grid stabilisation, and JIRAMA grid stability applications.ORE (Office de Régulation de l'Electricité) — electricity sector regulator; operating licence required for grid-connected BESS generation and storage activities JIRAMA — national utility; grid-connection agreement and technical review 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 in donor-financed projects) IEC 62933-5-2 — Electrical Energy Storage Systems — Safety Requirements — Electrochemical-based systems (expected project-specification reference) Madagascar grid parameters: 220/380 V 50 Hz (220 V single-phase, 380 V three-phase) |
Gap: Chinese GB/T BESS grid-connection certificates and NEA approvals do not satisfy ORE licensing or JIRAMA grid-connection requirements. Key issues requiring attention: (a) obtain an ORE electricity generation/storage licence before commissioning — this is a standalone regulatory gate independent of JIRAMA technical approval; (b) engage JIRAMA at the earliest project stage to obtain connection agreement technical requirements, including SCADA/communication interface protocols (IEC 61850 or project-specific) and protection relay settings appropriate to Madagascar's low-inertia grid; (c) although Madagascar's nominal grid voltage (220/380 V) matches China, PCS control parameters must be validated against JIRAMA's actual power quality tolerances, frequency deviation range (which can exceed ±0.1 Hz in weak-grid areas), and islanding detection requirements; (d) for donor-financed projects (World Bank, AfDB), IEC 62933-2-1 and IEC 62933-5-2 evidence will typically be required in technical specifications — prepare accordingly; (e) French-language technical and safety documentation is required for Madagascar regulatory submissions.[INFORMATIONAL] Chinese GB/T BESS grid-connection compliance and NEA approvals do not satisfy Madagascar's ORE licensing or JIRAMA grid-connection requirements. Although Madagascar and China share the same nominal grid voltage (220/380 V 50 Hz), PCS parameters must be validated for Madagascar's low-inertia, diesel-hybrid grid characteristics. Obtain an ORE licence and engage JIRAMA at the earliest project stage. For donor-financed projects, confirm IEC 62933 evidence requirements in the project technical specification before equipment procurement. | ORE (Office de Régulation de l'Electricité — Madagascar Electricity Regulator)2026-06-14 · unverified |
| Cell and Module Safety — IEC 62619 and Off-Grid Quality Standards (IEC TS 62257, VeraSol) for Madagascar BESS Project Acceptance | 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. These Chinese standards are not accepted as equivalents to IEC 62619 in Madagascar project or donor specifications, nor do they cover the off-grid quality requirements of IEC TS 62257 or VeraSol test protocols. Exporters must obtain IEC 62619 type-test evidence from an ILAC-accredited laboratory for grid-connected BESS, and VeraSol or IEC TS 62257 quality evidence for off-grid applications, in addition to any Chinese GB compliance.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) |
Madagascar does not currently have a confirmed standalone mandatory BESS product safety regulation requiring a specific pre-market certification equivalent to IEC 62619 or the EU Battery Regulation. BNM (Bureau des Normes de Madagascar) is the national standards body responsible for adopting and enforcing technical standards and conformity assessment for products in Madagascar; BNM adopts IEC standards. Exporters should verify BNM's current regulated-product scope for stationary BESS electrical equipment directly with BNM before shipment. For grid-connected BESS projects, IEC 62619:2022 (Safety Requirements for Secondary Lithium Cells and Batteries for Use in Industrial Applications) is the internationally expected safety baseline required by project owners, ORE, JIRAMA, and donor/lender technical specifications (World Bank, AfDB). For off-grid and solar mini-grid BESS applications — which represent the majority of near-term BESS demand in Madagascar given the country's approximately 35% electrification rate — the applicable quality standards are: IEC TS 62257 series (Recommendations for Small Renewable Energy and Hybrid Systems for Rural Electrification), which sets requirements for battery systems used in rural electrification; and VeraSol (formerly Lighting Global) quality standards for off-grid solar products including solar home systems (SHS) and solar mini-grids, which include battery performance and safety test protocols verified by accredited laboratories. IEC 62133 (Secondary Cells and Batteries Containing Alkaline or Other Non-Acid Electrolytes) may also be referenced for smaller off-grid storage applications. ADER (Agence de Développement de l'Electrification Rurale) is the agency responsible for rural electrification and off-grid projects; donor-financed off-grid BESS procured through ADER typically requires VeraSol or IEC TS 62257 quality evidence in addition to IEC 62619.IEC 62619:2022 — Safety Requirements for Secondary Lithium Cells and Batteries for Use in Industrial Applications (internationally expected baseline for grid-connected BESS cell/module safety in Madagascar project and donor specifications) IEC TS 62257 series — Recommendations for Small Renewable Energy and Hybrid Systems for Rural Electrification (applicable to off-grid and mini-grid BESS in Madagascar; required by ADER and donor-financed rural electrification projects) VeraSol (formerly Lighting Global) quality standards — off-grid solar and BESS product quality and safety test protocols (required by donor-financed off-grid solar BESS projects in Madagascar) IEC 62133 — Secondary Cells and Batteries Containing Alkaline or Other Non-Acid Electrolytes (may be referenced for smaller off-grid storage applications) IEC 62933-5-1:2024 — Electrical Energy Storage Systems — Safety considerations — Hazard identification, risk assessment and risk mitigation BNM (Bureau des Normes de Madagascar) — national standards body adopting IEC standards; verify current regulated-product scope for BESS electrical equipment directly with BNM ADER (Agence de Développement de l'Electrification Rurale) — rural electrification agency; sets procurement quality requirements for off-grid BESS projects |
Critical gap: Madagascar project owners, JIRAMA, ORE, and donor/lender technical specifications (World Bank, AfDB) reference IEC 62619 as the expected safety evidence for BESS cells and modules. For off-grid and mini-grid BESS — representing the dominant near-term application in Madagascar — VeraSol quality standards and IEC TS 62257 are the applicable quality frameworks required by ADER and donors. Chinese GB 44240-2024 and GB/T 36276-2023 are not harmonised with IEC 62619 and are not accepted as substitutes in project specifications. Neither standard covers VeraSol or IEC TS 62257 off-grid requirements. Exporters should: (a) verify BNM's current regulated-product scope for stationary BESS electrical equipment before shipment — confirm whether BNM conformity assessment is required as a pre-import obligation; (b) obtain IEC 62619 type-test certificates from an ILAC-accredited laboratory for cells and modules supplied to grid-connected Madagascar BESS projects; (c) for off-grid and mini-grid applications, obtain VeraSol quality verification or IEC TS 62257 compliance evidence — confirm the applicable quality framework with ADER, the project owner, and the donor/lender before procurement; (d) confirm the applicable IEC 62619 edition and VeraSol/IEC TS 62257 version referenced in the project specification before committing to a test programme; (e) prepare French-language product safety documentation for submission to BNM and local authorities.[INFORMATIONAL] No confirmed standalone mandatory BESS product safety regulation has been identified for Madagascar as of the dataset date. However, IEC 62619 is the internationally expected technical baseline for BESS cell and module safety in Madagascar grid-connected project and donor specifications; VeraSol and IEC TS 62257 are the required quality frameworks for off-grid and mini-grid BESS applications. Chinese GB 44240-2024 and GB/T 36276-2023 certification alone is not sufficient for Madagascar project acceptance in either application segment. Verify BNM regulated-product scope, confirm IEC 62619 or VeraSol/IEC TS 62257 evidence requirements with the project owner, ADER, ORE, JIRAMA, and any appointed donor technical adviser before shipment. Prepare French-language product safety documentation. | International Electrotechnical Commission (IEC)2026-06-14 · unverified |
| UN 38.3 Transport Safety Testing — Mandatory for Lithium Battery Imports to Madagascar via Toamasina (Tamatave) Port | 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 Madagascar imports — the key gap is ensuring the test summary covers the specific cell model, chemistry, capacity, and configuration of the BESS units being shipped, and that it is maintained current with any cell design changes. Importers and freight forwarders must also ensure that IMDG Code packaging, marking, and documentation requirements are met for sea freight through Toamasina, and that Madagascar customs procedures for dangerous goods are complied with.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 | 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). Madagascar is a party to international transport conventions and this requirement applies universally to all lithium battery imports by air or sea. The primary import route for BESS equipment to Madagascar is via sea freight through the Port de Toamasina (Tamatave), which is Madagascar's main international commercial port on the east coast. There is no Madagascar-specific exemption from UN 38.3 requirements. BESS cells and modules exported from China to Madagascar must be covered by a valid UN 38.3 Test Summary from an accredited laboratory before shipment. Customs clearance for dangerous goods at Toamasina requires compliance with IMDG Code dangerous-goods documentation, packaging, marking, and labelling requirements. Air freight for large BESS modules to Antananarivo (Ivato International Airport) is subject to IATA DGR requirements.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) IATA Dangerous Goods Regulations (DGR) — applies to all air freight of lithium batteries to Antananarivo (Ivato International Airport) IMDG Code — applies to all sea freight of lithium batteries to Port de Toamasina (Tamatave), Madagascar's main commercial port UN Model Regulations, 7th revised edition (2021) — Test Summary requirement in force since January 1, 2020 |
The gap is documentation scope, currency, and port-specific customs compliance — not standard equivalence. UN 38.3 is a universal requirement and Chinese-origin test summaries from accredited laboratories are accepted for Madagascar-bound shipments. 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 ILAC-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) IMDG Code documentation (Dangerous Goods Declaration, packing certificates, emergency schedules) in French is required for sea freight through Port de Toamasina — engage a Madagascar-experienced dangerous-goods freight forwarder; (f) customs clearance at Toamasina may require additional Madagascar customs documentation for dangerous goods in addition to standard commercial invoice, bill of lading, and packing list — confirm with a local customs broker before shipment.[INFORMATIONAL] UN 38.3 transport compliance is universal — a Chinese-origin test summary from an accredited laboratory is accepted for Madagascar shipments provided it covers the specific cell model and is current. The primary risks are scope mismatch (wrong cell model or capacity in the summary), an outdated summary after a cell design change, and inadequate port-specific dangerous-goods documentation for Toamasina customs. Verify test summary coverage and currency before each shipment. Engage a Madagascar-experienced dangerous-goods freight forwarder familiar with Port de Toamasina (Tamatave) IMDG Code procedures and Madagascar customs to confirm French-language DG documentation, packaging, marking, and labelling requirements for BESS cell and module shipments. | United Nations Economic Commission for Europe (UNECE) — Recommendations on the Transport of Dangerous Goods2026-06-14 · unverified |
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- International Electrotechnical Commission (IEC) · accessed 2026-06-14 · unverified · used in 2 rows
- ORE (Office de Régulation de l'Electricité — Madagascar Electricity Regulator) · accessed 2026-06-14 · unverified · used in 1 rows
- United Nations Economic Commission for Europe (UNECE) — Recommendations on the Transport of Dangerous Goods · accessed 2026-06-14 · unverified · used in 1 rows