Home Battery Permit Pack for Installers: UL 9540, R328, AS/NZS 5139

For a residential installer, the battery isn’t finished when it arrives. It is finished when the permit is issued and the inspection is passed. If the battery comes without the right listing, test data or paperwork, the job stalls at the permit desk, not at the warehouse. This guide sets out the documents a home battery installation is usually checked against in the US, Australia and the EU, so you can ask for them before you buy.

General information as of 30 October 2026, not legal advice. Codes are adopted and amended locally. Your authority having jurisdiction (AHJ), network operator or inspector decides what applies. This page does not state that any LJY-supplied model is UL 9540 listed or on the Clean Energy Council approved list; check any listing directly with the listing body.

Short answer

US: under the 2021 International Residential Code (IRC) Section R328, a home energy storage system (ESS) must be listed and labelled to UL 9540. Individual units are limited to 20 kWh, with aggregate limits of 40 kWh or 80 kWh depending on location, unless larger ratings are justified by fire test data. UL 9540A is the test method behind those exceptions.
Australia: installations follow AS/NZS 5139, amended in December 2025. Rebate schemes require a battery from the Clean Energy Council (CEC) approved list, and the Clean Energy Regulator inspects against a published checklist.
EU and other IEC markets: IEC 62619 covers the safety of lithium batteries for industrial uses, including stationary storage. The EU Battery Regulation adds its own obligations.
Before you buy: get the listing or test documents, the installation manual, the SDS and the labels for the exact model, and check them against the code your AHJ has adopted.

UL 9540 and UL 9540A: listing vs test method

UL’s code authority team describes UL 9540, the Standard for Safety for Energy Storage Systems and Equipment, as “the appropriate certification Standard for battery energy storage systems”, and says that “all the model installation codes require certification (Listing) for compliance with ANSI/CAN/UL 9540.” It also warns that “simply combining individual, independently certified products in the field does not result in a certified (Listed) system.” A listed battery plus a listed inverter is not automatically a listed system.

UL 9540A is different. UL describes it as the American and Canadian national standard for assessing fire propagation from thermal runaway in battery energy storage systems, and says it provides a method for testing a system’s behaviour “when the design or installation conditions of an ESS exceed the limits set by” NFPA 855, NFPA 1, the International Fire Code or the International Residential Code. UL also notes that in the 6th edition the unit-level test is still required for residential battery systems. A UL 9540A report is test data, not a certificate. Our LiFePO4 safety certifications guide explains the difference.

US: what IRC R328 asks for

The 2021 IRC Section R328, as reproduced by local building departments, sets these core rules for ESS in one- and two-family homes. Some jurisdictions apply it together with NFPA 855 and local amendments. Bellevue, Washington’s tip sheet, for example, cites “the 2021 International Residential Code R328 with Washington State Amendments and NFPA 855 Standard.”

Topic	2021 IRC R328 (check your adopted edition)
Listing	ESS listed and labelled to UL 9540 (R328.2)
Installation	Per the manufacturer’s instructions and the listing (R328.3)
Spacing	Units at least 3 ft (914 mm) apart, unless smaller distances are shown to be adequate by large-scale fire testing (R328.3.1)
Locations	Detached garages and accessory structures; attached garages separated from living space; outdoors or on exterior walls at least 3 ft from doors and windows; enclosed utility closets, basements, storage or utility spaces with finished or noncombustible walls and ceilings. Not in sleeping rooms, or closets or spaces opening directly into them (R328.4)
Energy ratings	Individual units max 20 kWh. Aggregate max 40 kWh in utility closets, basements and storage or utility spaces; 80 kWh in garages and accessory structures, on exterior walls or outdoors on the ground. Larger installations follow IFC Section 1207 (R328.5)
Electrical	Installed per NFPA 70. Inverters listed to UL 1741 or included in the UL 9540 listing (R328.6)
Fire detection	Smoke alarms in the rooms and areas where the ESS is installed; a listed, interconnected heat detector where smoke alarms can’t be used (R328.7)
Impact	Approved barriers where vehicles could hit the ESS (R328.8)
Documents and labels	Manufacturer’s installation, operation, maintenance and decommissioning instructions given to the owner or placed near the ESS, plus a label with the contact details of qualified maintenance and service providers (R328.11)

R328.1 lists two exceptions: ESS listed and labelled to UL 9540 and marked “For use in residential dwelling units”, where installed per the manufacturer’s instructions and NFPA 70; and ESS under 1 kWh. Bellevue’s tip sheet adds that the 20 kWh unit limit and the 40/80 kWh aggregate limits apply “except where larger kWh ratings are documented based on UL 9540A Test Report.”

What an AHJ submittal looks like (example)

Each city has its own forms. Bellevue is a useful public example. Its electrical permits page lists solar PV installations among the work that needs an electrical permit, and PV systems on single-family homes among the projects that need plan review. Its ESS tip sheet then lists what the inspector checks: UL 9540 listing, installation per the instructions and listing, separation, permitted locations, smoke and heat detection, and the kWh limits. Before you order, ask your AHJ for its checklist and make sure the battery documents answer each line.

Checking a battery against your permit checklist? Send us the checklist and the model you are considering. We’ll ask the manufacturer which documents exist for that exact model, and say plainly which don’t.

Ask about the document pack

Australia: AS/NZS 5139, the CEC list and the CER checklist

AS/NZS 5139 Amendment 1. The NSW Government’s advisory says Amendment 1 to AS/NZS 5139:2019 was published on 19 December 2025 and “is now mandatory.” Changes it highlights include:

battery systems may be installed within 600 mm of an opening if the opening is wider than 900 mm, such as a garage door
inverters are now treated as associated appliances and allowed in the restricted location
exempt materials used as a barrier to habitable rooms must be at least 6 mm thick
overcurrent protection for paralleled pre-assembled battery systems must have a kA rating that matches or exceeds their combined fault current
a physical copy of the SDS must be provided and protected from damage
a new Appendix I explains how to calculate cell short-circuit current

CEC approved batteries. The Clean Energy Council says its approved list contains over 1,000 lithium-based batteries, and that “state electricity networks and government rebate programs, including the Small-scale Renewable Energy Scheme (SRES), require that solar systems use batteries from this list.” New product specifications (SA TS 5398) are being phased in, and the expiry dates of more than 700 listed products were brought forward to 31 December 2027. Check the listing and its expiry date for the exact model and model number.

CER inspection checklist. The Clean Energy Regulator’s solar battery inspection checklist (version 1.2, July 2026) says inspectors assess over 90 items per installation, grouped into battery general, labelling, installation requirements, isolation, mechanical protection, overcurrent protection, protection from fire, restricted locations, switchboard, wiring and documentation. Items include whether an integrated BESS was on the CEC approved list at the time of installation, whether a hard-copy SDS is in a document holder at the main switchboard or meter box, and whether a full system manual has been given to the home owner. Our LiFePO4 battery SDS guide covers what a usable SDS should contain.

EU and IEC markets: IEC 62619 and the Battery Regulation

The IEC describes IEC 62619:2022 as specifying “requirements and tests for the safe operation of secondary lithium cells and batteries used in industrial applications, including stationary applications”, with electrical energy storage systems among its examples. EU market obligations for batteries are covered separately in our EU Battery Regulation guide.

Installer document pack checklist

Document	Why the permit or inspection needs it	What to check
Listing or test documents (UL 9540 in the US; IEC 62619 and others elsewhere)	Codes require listed systems; AHJs and inspectors verify the scope	Model number, configuration and inverter pairing match the system you install
UL 9540A report (where larger ratings or smaller spacing are claimed)	Basis for exceptions to kWh limits or spacing	That it covers the unit you install, and what your AHJ accepts
Installation, operation, maintenance and decommissioning manual	IRC R328.11 and AS/NZS 5139 documentation requirements	Matches the model and firmware; clearances and mounting stated
SDS (current revision)	Paper copy at the installation in Australia; site files elsewhere	Model, chemistry and company match the label
Datasheet and labels	kWh rating against unit and aggregate limits; signage	Rated energy per unit, and the label content required locally
Inverter compatibility record	Inverter listing (UL 1741 or within the UL 9540 listing) and correct battery settings	Exact inverter model and firmware
CEC approved list entry (Australia)	Needed for SRES and many rebates	Exact model number and expiry date

For the compatibility side, use our inverter battery compatibility calculator. If you are choosing between a 48V-class battery and a high-voltage stack, see our high-voltage vs low-voltage storage guide. For commercial sites, see the C&I battery storage RFQ checklist. Storing battery stock before installation has its own rules; see our warehouse storage fire code guide.

Sourcing from China: what can be arranged and who pays

LJY Energy is a Shenzhen supplier and OEM/ODM coordinator for LiFePO4 batteries, not a manufacturer. For installer projects we coordinate the battery configuration, datasheet, manual, SDS and UN38.3 documents with qualified manufacturing partners. Listings and test reports such as UL 9540, UL 9540A, IEC 62619 or a CEC listing are model-specific. Where they don’t already exist for the model you want, certification and testing are arranged per project, with fees borne by the buyer. Home storage options are on our home energy storage page, including stackable batteries and the 51.2V 200Ah battery. Installer support is on our installers page.

Planning home battery installs? Share your market, the inverter model and your AHJ’s or inspector’s document list. We’ll coordinate the documents with the manufacturer and tell you what would have to be arranged per project.

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FAQ

Can I install a battery that isn’t UL 9540 listed in a US home?

Usually not. IRC R328.2 requires ESS to be listed and labelled to UL 9540, and UL says all the model installation codes require UL 9540 listing. Your AHJ makes the final decision.

Is UL 9540A a certificate?

No. It is a test method for fire propagation from thermal runaway. Its report is used to justify larger ratings or smaller spacing than the code’s default limits.

What is the kWh limit for a home battery under the IRC?

Under the 2021 IRC R328.5, individual units are limited to 20 kWh. The aggregate is limited to 40 kWh in utility closets, basements and storage or utility spaces, and 80 kWh in garages, accessory structures, on exterior walls or outdoors on the ground, unless larger ratings are documented.

Do I need a CEC-listed battery in Australia?

For the Small-scale Renewable Energy Scheme and many state rebates and network connections, yes. The CEC says these programs require batteries from its approved list. Check the exact model number and expiry date.

Does the SDS have to be printed?

In Australia, yes. AS/NZS 5139 as amended requires a physical copy, and the CER checklist asks for a hard copy in a document holder at the switchboard or meter box.

Home Battery Permit Pack: UL 9540, UL 9540A, IRC R328, AS/NZS 5139 and IEC 62619 — the Documents to Get Before You Buy