How long a digital product passport must stay available

A digital product passport must stay available after your last sale of the product. The EU battery regulation is in force, and its passport duty applies from 18 February 2027. For a battery, European Union law requires the passport to stay available after the responsible company stops.

The law sets an event as the end point. It does not set a number of years. No adopted European act gives a retention period in years for any product group. This page explains why nobody can give you that number yet.

Here is what happens if you ignore this. You publish each passport as a page on your own website. Your company stops, or your hosting contract stops. Every code on every product then returns an error. European law requires the opposite result for a battery passport.

The battery passport is the first duty, and its date is firm

Regulation (EU) 2023/1542 is the EU battery regulation. It is in force. Its passport duty applies from 18 February 2027, and it covers three categories:

• 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 for the scope.

The duty is per battery. One passport belongs to one physical battery, not to a model and not to a production run.

A battery passport must stay available after the company stops

Article 78 of the battery regulation sets the technical requirements. 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

Cite that point as Article 78(e). Article 78 carries lettered points and no numbered paragraphs. So a citation to Article 78(5) is wrong, and some summaries print that numbered form anyway.

Read the words the regulation uses. It names two events: the operator ceases to exist, and the operator ceases its activity in the Union. It does not use the word insolvency. See what happens if the company closes.

A battery passport ends when the battery is recycled

The duty has a defined end, and a physical event sets that end.

Article 77(8) says the passport "shall cease to exist after the battery has been recycled".

The duty does not end on a sale date. It does not end when the warranty ends. A repurposed battery gets a new passport under Article 77(7), and the duty moves to the operator that repurposed the battery. See lifecycle events.

Every rule in that table comes from Regulation (EU) 2023/1542, which is in force. The passport duty starts on 18 February 2027.

The ecodesign regulation uses different words, and it binds nothing yet

The Ecodesign for Sustainable Products Regulation (ESPR) is Regulation (EU) 2024/1781. It came into force on 18 July 2024. It is the framework for passports on products such as a merino jumper or an office chair. It creates a duty for a product group only through a delegated act.

The ESPR uses the word insolvency, and that word belongs to its Article 10(e). The battery regulation never uses that word, and it names two events instead. Use the words of the regulation that covers your product.

Warning: no ESPR passport duty binds any product today. A duty starts only when the European Commission adopts a delegated act for your product group, and it has adopted none. Read what a delegated act is.

The ESPR sets the period by the product. It requires the passport to stay available for at least the expected lifetime of the product.

Your own website cannot meet a duty that continues after the company stops

Read this page before you buy a passport service.

A company web server stops when the company does not pay for it. Article 78(e) requires the opposite result. So your own website stops at the exact moment the law requires the passport to stay available.

European law answers this in two places. 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".

A service provider is a separate legal person. It can keep the passport available after the operator stops. See what a service provider does.

The European Commission does not hold the passport for you. Its registry became operational in July 2026. Article 13(1) of the ESPR requires the registry to store at least the unique identifiers. No operator must upload to the registry yet, because no delegated act applies. The operator or the service provider keeps the passport. See the EU registry.

No retention period in years is verified for any product group

Warning: treat any quoted retention period in years as unverified. Ask the person to quote a purchased standard text or an adopted act. See why the texts are paywalled.

This site gives no figure in years, for three reasons.

• No ESPR delegated act exists, so no product group has data rules yet.
• EN 18221 is the cited European standard for data storage, archiving, and persistence. Its text is paywalled, and this site has not bought it.
• The battery regulation names two events, and it names no period.

The European Commission cites six standards for the passport. The table names each one.

There is no EN 18217 and no EN 18218. Never accept the set written as a range. See EN 18221, data storage, archiving, and persistence.

One period is set, and it covers the registry record

Warning: the period below is not a rule for your passport. It covers the identifiers and the registration information that the registry holds. The passport itself stays with the operator or the service provider, and no adopted act gives that passport a period in years.

The registry implementing act sets a period for the record inside the registry. Article 10(3) deletes the registration data automatically ten years after the registration, where Union law sets no other period. Where Union law does set a period, the act follows that period.

Name who keeps each passport available after your company stops

If you sell wine, honey or any other food product, no ESPR passport reaches your product at all. Read food and feed are excluded.

For every other product, the duty belongs to the company that places the product on the European Union market. If you have no EU establishment, that company is usually the EU importer. You still supply the data, and the importer cannot keep available what you never sent. See what this means for New Zealand exporters.

That rule binds a battery from 18 February 2027. For an ESPR product group, it binds only after the European Commission adopts a delegated act.

1. Name the party that keeps each passport available after your company stops.
2. Ask any supplier what happens to your data if the supplier closes.
3. Ask for an export of every field, on request, in a format a machine can read.
4. Keep every version of a passport, not only the current one. See versioning and archives.
5. Write the answers into your contract with the importer. See agreeing data duties.

Point four is easy to miss. A passport that changes after the sale needs a history. A market surveillance officer may ask what the record said on the day of the sale.