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From Document No. 136 to Document No. 394: The Great Transformation of Energy Storage under the Poli
Release time:2025.05.08 Number of views:8

In February 2025, the National Development and Reform Commission and the Energy Administration issued Document No. 136, which explicitly stated that energy storage configuration should not be used as a prerequisite for the approval of new energy projects, ending the "mandatory storage allocation" policy that had been implemented in Qinghai since its first launch in 2017.

Industry insiders believe that Document No. 136 is an innovative measure to implement the Renewable Energy Law and Energy Law under the new situation. On the one hand, it requires the improvement of market trading and pricing mechanisms, and promotes the comprehensive entry of new energy into the electricity market and fair participation in trading. On the other hand, it provides support for wind and solar new energy by establishing a "settlement mechanism" or "mechanism" for sustainable development of new energy.

The "settlement mechanism" will be a government authorized differential contract mechanism that adapts to the Chinese electricity market. The implementation of this mechanism can promote the synergy between the government and the market, as well as the sustainable development of renewable energy. The significance of Document No. 136 lies in the government's focus on addressing market failures and other issues, encouraging new energy to actively participate in the market, proactively reducing the consumption cost of the system, allowing the market to play a decisive role in resource allocation, restoring the price of the electricity market, and promoting the integration of different policies.

On April 29th, the General Office of the National Development and Reform Commission and the Comprehensive Department of the National Energy Administration issued the "Notice on Accelerating the Construction of the Electricity Spot Market in an All round Way (NDRC Office Ti Gai [2025] No. 394)", which clearly requires the basic realization of full coverage of the electricity spot market by the end of 2025.

The core of Document No. 394 is to address the pain point of insufficient flexibility in the power system through market-oriented mechanisms. The document clearly requires the promotion of spot market construction in different provinces: six provinces and cities including Hubei and Zhejiang need to complete formal operation by the end of 2025, 16 provinces including Fujian and Sichuan need to start continuous settlement trial operation, and the southern region needs to explore cross provincial trading mechanisms simultaneously. Industrial and commercial users need to have the ability to independently declare and settle by the end of 2025, and the price signal in the spot market will be directly transmitted to the terminal electricity consumption link.

In terms of price mechanism innovation, the spot market adopts a 15 minute rolling clearing mode. According to pilot data from Zhejiang, the lowest electricity price during the photovoltaic peak period drops to -0.18 yuan/kWh, and the highest electricity price during the evening peak period reaches 1.45 yuan/kWh. The fluctuation range of intraday price differences generally exceeds 1.5 yuan/kWh. This institutional design upgrades energy storage from a traditional "peak shaving and valley filling" tool to a "dynamic balancer" for the power system, but its requirements for energy storage response speed and prediction accuracy have also been raised to the level of minutes.

Obviously, this upcoming electricity market test will not only reshape the entire power industry landscape, but also profoundly change the commercial logic and development path of industrial and commercial energy storage.

Jiangsu's new policy: Time of use electricity prices are not the iron rice bowl for industrial and commercial energy storage

On April 30th, the Jiangsu Provincial Development and Reform Commission officially issued the "Notice on Optimizing the Time of Use Electricity Price Structure for Industry and Commerce, Promoting the Consumption of New Energy, Reducing Enterprise Electricity Costs, and Supporting Economic and Social Development". This adjustment has increased the fluctuation ratio of peak and valley electricity prices, and added a midday off peak period. The document will be executed from June 1st.

The document clearly encourages industrial and commercial users to actively reduce electricity consumption during peak hours and increase electricity consumption during off peak hours by configuring energy storage devices and implementing comprehensive energy management. By optimizing electricity consumption during peak hours, electricity costs can be effectively reduced. Optimize the setting of time slots for commercial users and add a midday valley time slot. Implement valley electricity pricing during the summer and winter seasons (June August and December February) from 11:00 to 13:00 (2 hours) and during the spring and autumn seasons (March May and September November) from 10:00 to 14:00 (4 hours). Time division setting for industrial and commercial users: Adjust the fluctuation ratio of electricity prices, use the user's purchase price as the flat segment, and fluctuate up and down based on this.

Regarding the issue of how energy storage projects, which are the most concerned in the industry, can actively adapt to the adjustment of time of use electricity pricing structure and achieve a new round of development, Jiangsu Development and Reform Commission's response is as follows:

The optimization of the time of use electricity price this time has expanded the scope of implementation of the time of use electricity price for industrial and commercial purposes to power users who implement the electricity price for industrial and commercial purposes, except for the traction electricity for electrified railways that are specifically regulated by the state. This has added new potential partners for industrial and commercial enterprises to cooperate with energy storage projects. With the advancement of technology and the increase of production capacity, the cost of energy storage projects continues to decrease, which will also bring more profit space to energy storage projects. In addition, with the construction and development of the electricity market, energy storage projects can cooperate with new energy generation projects to obtain market value through peak shaving for new energy generation. After the normalization of the electricity spot market operation, it will better play the role of discovering prices and optimizing resource allocation in the market. The price difference of market transactions by time period will further widen, and energy storage projects can directly participate in electricity market transactions, especially in the spot market, to obtain profits from low charging and high discharging. During the peak summer (winter) season, energy storage projects can also serve as load integrators or virtual power plant users, participating in our province's electricity demand response and further increasing revenue.

Some experts believe that the formation of time of use electricity prices in each province needs to consider multiple purposes, but the development of industrial and commercial energy storage is not its main purpose, let alone the iron rice bowl of industrial and commercial energy storage. The decision-making cost of adjusting local time of use electricity pricing policies is often lower than that of adjusting electricity storage policies. The closer the connection between the time of use electricity pricing structure and the electricity market price signal, the more conducive it is to achieving all the main objectives in Document No. 1093. Its stability, similar to administrative orders, becomes increasingly difficult to maintain.

In fact, based on the "user purchase price" as the pricing basis, Jiangsu is not the first, nor will it be the last. In the future, energy storage enterprises will rely more on market-oriented mechanisms and technological innovation, and different application scenarios will also put forward more differentiated requirements for energy storage technology, continuously promoting the industry's development towards refinement. For future industrial and commercial energy storage, high-quality homeowners are scarce resources, excellent operators are key players, and the various types of operating income derived from this foundation are the direction that industrial and commercial energy storage should quickly break through.

New policy orientation: local subsidies shift, safety supervision becomes stricter

Local subsidies have obvious turning signals

At the same time, local subsidy policies have shifted from "installed capacity" to "discharge capacity" and "technological breakthroughs". For example, the Inner Mongolia Energy Bureau has issued a notice on accelerating the construction of new energy storage, which compensates for the discharge of independent new energy storage power stations included in the autonomous region's planning to the public grid. The compensation standard is fixed for one year, and the compensation standard for 2025 is 0.35 yuan/kWh, with a duration of 10 years.

It is reported that as early as November 2023, the Inner Mongolia Energy Bureau issued the "Implementation Rules for Independent New Energy Storage Power Station Projects in Inner Mongolia Autonomous Region (Provisional)", which pointed out that independent energy storage power stations on the grid side included in demonstration projects would enjoy capacity compensation, with a maximum compensation limit of 0.35 yuan/kWh for discharge and a compensation period of 10 years. At that time, the policy required still distinguishing between grid side and power side energy storage, and power side energy storage would obtain profits through capacity leasing, selling capacity, and other methods. The document did not propose a compensation standard of one year. The Notice further cancels the division between the power supply side and the grid side, and independent energy storage stations are entitled to capacity compensation.

In addition, Ouhai District in Zhejiang Province provides a subsidy of 0.8 yuan/kWh for user side energy storage based on the amount of discharge, Songjiang District in Shanghai provides graded incentives for virtual power plants based on the amount of regulation, and Changzhou in Jiangsu Province implements new subsidy policies such as a maximum subsidy of 0.3 yuan/kWh for new energy storage power plants.

The safety supervision of energy storage power stations is becoming stricter

On May 7th, the National Energy Administration and five other departments issued a notice on strengthening the safety management of electrochemical energy storage. The notice proposed to improve the intrinsic safety level of battery systems, carry out safety condition and facility evaluation of electrochemical energy storage projects, further improve the relevant standards and specifications of electrochemical energy storage, implement the safety supervision responsibility of electrochemical energy storage projects, strengthen departmental work linkage and information sharing, and implement the main responsibility of enterprise safety production.

This involves improving the intrinsic safety level of battery systems; Conduct safety condition and facility evaluation for electrochemical energy storage projects; Further improve the standards and specifications related to electrochemical energy storage; Implement safety supervision responsibilities for electrochemical energy storage projects; Strengthen departmental work linkage and information sharing; Implement the main responsibility of enterprise safety production.

Previously, various provinces and cities have issued management standards for fire protection and grid connection acceptance of energy storage power stations. For example, Sichuan requires the elimination of "grid connection with diseases", Guangdong clarifies the fire protection responsibilities of energy storage power stations, and the East China Bureau has designated a restricted area - all energy storage power stations in densely populated areas and high-rise buildings will be shut down, and projects that do not meet the standards will be forcibly withdrawn before 2025. At the national level, the production date and accident records of battery cells have also been included in the bidding assessment, forcing enterprises to improve product quality, which has also led to an accelerated increase in industry concentration.

Industry Trend: Concentration Rising, Chinese Enterprises Accelerate Going Global

Under the influence of multiple factors such as policy shift, technological iteration, and price competition, the energy storage industry continues to show a trend of strong top enterprises remaining strong while the survival space for small and medium-sized manufacturers narrows. Data shows that by 2024, the CR10 (top 10 enterprise concentration) of the energy storage battery industry has exceeded 90%, and the CR10 of integrators has exceeded 80%.

With the full operation of the electricity spot market and the accelerated clearance of inefficient production capacity by 2025, enterprises lacking technical barriers and capital reserves will disappear in batches, while some leading technology and strong capital enterprises will further expand their advantages. It is expected that the market share of energy storage CR10 enterprises will further increase by 2025.

While domestic policies are undergoing drastic changes, the demand for energy storage in markets such as Europe, America, and the Middle East is surging. Some institutions predict that the overseas installed capacity of large energy storage will double by 2025, and leading companies have accelerated their overseas expansion. For example, BYD Energy's European market share for energy storage has exceeded 25%, EVE Energy's North American orders have surged by 300%, Yuanjing Energy has won a £ 240 million energy storage order in the UK, and CATL has consolidated its advantages by deeply binding with Tesla. At the same time, small and medium-sized energy storage enterprises are heading to emerging markets such as Asia, Africa, and Latin America to break through and survive. The overseas market in 2025 is already a red ocean.

conclusion

Industry insiders believe that in the process of building a new type of power system in China, the rapid development of new energy promotes the transformation of the power structure, and then the time of use electricity pricing policies in various provinces continue to optimize, ultimately enriching the value connotation of energy storage. This is an inevitable historical process for the energy storage industry to enter a rational development period.

In the long run, after policy relaxation, independent energy storage power plants, virtual power plants and other models are expected to become mainstream. The energy storage industry will also move from "wild growth" and "crazy internal competition" to high-quality competition and differentiated competition, providing more solid support for supporting the country's "dual carbon" goals and building a new type of power system. So, the series of "policy storms" from "Document No. 136" to "Document No. 394" are destined not to be the end of energy storage, but the starting point of the construction of a new power system.