Energy Storage Europe replies to the European Commission’s public consultation on the Methodology for the Calculation of the recycled content of industrial and EV batteries. Under the Batteries Regulation, several categories of batteries, including industrial batteries, will have to contain a certain percentage of recycled metals to be allowed to be placed on the EU market.
September 2026 / Policy Papers
Cybersecurity in Battery Energy Storage Systems
Energy Storage Europe welcomes the European Commission's focus on cybersecurity in the energy sector and supports the direction of travel across the Cyber Resilience Act (CRA), the Network Code on Cybersecurity (NCCS), and the proposed Cybersecurity Act (CSA) 2.0, while raising targeted concerns. Battery Energy Storage Systems (BESS) regulate the grid in real time, providing frequency response, balancing, black start, and grid-forming services. They are not inherently more vulnerable than other grid-connected technologies, but control-layer failures can escalate rapidly to grid-stability events. With BESS reaching 50 GW today and 200 GW projected by 2030, these risks are no longer isolated asset-level concerns.
The current EU framework still has accountability gaps, particularly for legacy assets, outsourced operations, special purpose vehicle structures, and manufacturers without an EU legal entity. Divergent implementation of NIS2 raises compliance costs and slows deployment. Industry calls for a clear, risk-based, component-level approach with proportionate obligations and realistic timelines.
Energy Storage Europe recommendations:
On the overall framework, we call on the EU to:
Reclassify the components that matter most: BMS, PCS and EMS as Critical products under the CRA, moving to third-party conformity assessment.
Harmonise connectivity requirements at distribution level, ending market-specific configurations across the Single Market.
Publish joint NIS 2 and NCCS implementation guidance, clarifying overlap and reducing duplicative audits.
Give industry early clarity on CSA 2.0 supply-chain scope and timelines.
On the Cybersecurity Act 2.0 specifically, we ask legislators to:
Define "non-technical risk" with operational precision, based on ownership, jurisdiction and state-compelled access, not supplier location alone.
Give credit for technical and operational (where appropriate) mitigating measures, reflected in Articles 103(1) and 103(2).
Harmonise application across Member States and sectors, strengthening ENISA's role with a meaningful right of response.
Mandate risk-based transition periods of at least one year, reflecting 15-to-20-year asset lifecycles on multi-year contracts.
Make CSA 2.0 the single reference instrument, coherent with the CRA and NIS 2 Article 21, with interim high-risk-supplier measures deferring to it.
Energy Storage Europe replies to the European Commission’s public consultation on the Methodology for the Calculation of the recycled content of industrial and EV batteries. Under the Batteries Regulation, several categories of batteries, including industrial batteries, will have to contain a certain percentage of recycled metals to be allowed to be placed on the EU market.
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Energy Storage Europe welcomes the European Commission's growing focus on cybersecurity in the energy sector and supports the direction of travel across the Cyber Resilience Act (CRA), the Network Code on Cybersecurity, and the proposed Cybersecurity Act (CSA) 2.0. Yet raises concerns that require targeted corrections to ensure these frameworks deliver on their security objectives without inadvertently slowing battery storage deployment.
Energy Storage Europe replies to the European Commission’s public consultation on the Methodology for the Calculation of the recycled content of industrial and EV batteries. Under the Batteries Regulation, several categories of batteries, including industrial batteries, will have to contain a certain percentage of recycled metals to be allowed to be placed on the EU market.
Energy Storage Europe welcomes the proposed revision of the Network Code for generators and the explicit integration of storage, including grid-forming capabilities. Further clarity is needed on requirements for bidirectional storage and the treatment of existing projects.
