EN 18221: data storage, archiving, and persistence

EN 18221:2026 is the European standard for data storage, archiving, and persistence in a digital product passport. The European Commission cites it in an implementing decision. The standard stays voluntary.

European Union law requires a battery passport to stay readable after the responsible company stops trading. That duty applies from 18 February 2027.

If you plan to host your passports on your own website, read this page before you build. A website stops when nobody pays for it, so a passport on that website stops too.

EN 18221 is one of six cited standards, and it stays voluntary

CEN and CENELEC, the European standards bodies, wrote it. The work sits with their joint technical committee, CEN/CLC/JTC 24.

The Decision cites six standards, and EN 18221 is one of them.

There is no EN 18217 and no EN 18218. Never write the set as a range, because a range names two documents that do not exist. See which standards apply.

A battery passport must stay available after the company stops

Regulation (EU) 2023/1542 is the EU battery regulation, and it is in force. Article 78 sets the technical requirements for the battery passport. Point (e) reads:

the battery passport shall remain available after the economic operator responsible for the fulfilment of the obligations under Article 77(4) or (7) ceases to exist or ceases its activity in the Union

Article 78 has lettered points and no numbered paragraphs. Some summaries print a numbered form anyway.

The passport duty applies from 18 February 2027. It covers three categories and nothing else:

• each light means of transport (LMT) battery, such as an e-bike battery
• each industrial battery with a capacity greater than 2 kilowatt hours
• each electric vehicle battery

Warning: some guidance calls this a rule for large batteries. An e-bike battery is not large, and it is covered. The Commission web page on digital product passports writes "certain types of batteries, including", and that list is open. See batteries and the battery regulation.

Article 78 governs the battery passport alone, and not a passport under any other regulation.

The word insolvency comes from the ecodesign regulation

The Ecodesign for Sustainable Products Regulation (ESPR) uses the word insolvency. The battery regulation does not use it. The two regulations name the same commercial event in different words.

Use the words of the regulation that covers your product. A summary that mixes the two gives you the wrong test.

The ESPR has been in force since 18 July 2024. Under the ESPR the passport must also stay available for at least the expected lifetime of the product. See how long a passport lasts.

The law keeps the data with you, and not with the EU

ESPR Article 10(c) requires the passport to be "stored by the economic operator responsible for its creation or by digital product passport service providers". Recital 41 of the same regulation requires a decentralised data system.

The European Commission runs a registry, and it became operational in July 2026. That registry holds at least the unique identifiers. The law puts the passport itself with the economic operator or with a service provider. See the EU registry.

Read the two rules together. The law makes the passport survive the company. The European Union does not store the passport for you.

A passport on your own website stops when your website stops

This is the commercial consequence, and it is why the title of EN 18221 matters to you.

Consider a New Zealand company that sells e-bike batteries into Germany. It publishes each passport as a page on its own site. The company closes, the domain lapses, and every code on every battery then returns an error. A recycler in Hamburg gets nothing.

A company website fails at exactly the event that Article 78(e) names. So a company web server is a weak place to keep a passport.

The ESPR answers the same problem in its own way. Article 10(4) requires a back-up copy through a digital product passport service provider. The passport must carry the reference of that provider. That ESPR duty waits for a delegated act, because no product group has one yet.

See what a service provider does and what happens if the company closes.

This site states no retention period, no archive format and no backup method

The text is paywalled, and this site has not bought it. The price is in the table above.

So this site states no retention period from EN 18221. It states no archive format and no backup method either. The scope summaries in circulation come from a CEN and CENELEC webinar deck, not from the standard itself. See why the texts are paywalled.

Warning: treat any quoted retention period as unverified until the person quotes the purchased text.

Citation in the Official Journal does not make EN 18221 mandatory. It gives a presumption of conformity for the requirements in Articles 10 and 11 of the ecodesign regulation. See presumption of conformity. The Decision itself sits in the Official Journal.

Name who keeps each passport available after your company stops

1. If you sell one of the three battery categories above, plan for 18 February 2027.
2. Name the party that keeps each passport available after your company stops.
3. Ask any passport supplier what happens to your data if that supplier closes.
4. Write both answers into the contract with your European importer. See agreeing data duties with your EU importer.
5. Do not buy EN 18221 because a supplier says the law requires it.