Data, access and durability
What happens to an old version of a passport
EU law requires passport data to be accurate and up to date. It does not say if you must keep the version you replaced.
No European Union (EU) law says what happens to an old version of a digital product passport. Article 77(4) of the battery regulation, in force, requires the information in a battery passport to be accurate, complete and up to date. It sets no retention period for the version you replaced.
This page states that gap. No source that this site can verify settles the question today.
Here is what the gap can cost you. If you overwrite a value, you cannot show what you declared on the day of sale. Keep your own dated record of every change. That record costs time only. It answers a question that a buyer or an authority can ask you years later.
The law requires current data, and no history
The battery regulation carries the first binding passport duty in EU law.
| Item | Detail |
|---|---|
| Instrument | Regulation (EU) 2023/1542, in force |
| Passport duty | Article 77 |
| Date the duty starts | 18 February 2027 |
The duty 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 carries the duty. The Commission web page on digital product passports writes "certain types of batteries, including", and that list is open. See batteries for the scope.
Article 77(4) reads:
The economic operator placing the battery on the market shall ensure that the information in the battery passport is accurate, complete and up to date. It may give written authorisation to any other operator to act on its behalf.
Article 78 sets the technical requirements for the battery passport. Point (g) requires data authentication, reliability and integrity. Article 78 uses lettered points, from (a) to (h). It has no numbered paragraphs. Article 78 governs the battery passport alone.
| Provision | What it requires | What it does not say |
|---|---|---|
| Article 77(4) | The information is accurate, complete and up to date | If you must keep the value you replaced |
| Article 78(g) | Data authentication, reliability and integrity | How you prove what the data held last year |
Read the two together. The law asks for a current record you can trust. It does not ask for a history of that record, and it does not forbid one.
The standard that would answer this is paywalled and unread here
The European Commission cites six European standards for digital product passports. One of them covers this subject.
| Standard | Subject |
|---|---|
| EN 18216 | Data exchange protocols |
| EN 18219 | Unique identifiers |
| EN 18220 | Data carriers |
| EN 18221 | Data storage, archiving, and persistence |
| EN 18222 | Application programming interfaces for product passport lifecycle management and searchability |
| EN 18223 | System interoperability |
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.
EN 18221 is the standard that covers data storage, archiving, and persistence. The Commission cites it in the Official Journal. The standard stays voluntary.
| Item | Detail |
|---|---|
| Standard | EN 18221:2026, published late May 2026 |
| Official title | Digital product passport - Data storage, archiving, and persistence |
| Cited by | Implementing Decision (EU) 2026/1736, in force 15 July 2026 |
| Status | Voluntary |
This site has not bought the text. The price is 190 to 370 euros on the distributor listings. So this site states no archive rule, no retention period and no version history requirement from EN 18221. See EN 18221 and why the texts are paywalled.
Warning: treat any quoted retention period as unverified until the person quotes the purchased text.
The draft standard on data authentication, prEN 18246, settles nothing either. It is not published, and the Official Journal does not cite it. See prEN 18246.
Both answers cost you: lost evidence, or work on every copy you keep
The question matters because each answer costs something. No rule tells you which cost to accept.
If you overwrite a field, you lose your evidence. Take the e-bike batteries that you sell into Germany. You publish a passport for each battery. A year later you change cell supplier. You write the new values over the old ones.
A market surveillance authority then asks about a battery sold before the change. You hold the current values, but you cannot show the values you declared at the time. See data accuracy: who is liable.
If you keep every version, you have a different problem. You must decide how long you hold each copy, who may read it, and how you answer a deletion request. See passports and personal data.
This site does not tell you which to choose. The choice is yours today. A future standard may remove that choice.
A materially changed product gets a new passport
One point in this subject is settled, and it comes from the battery regulation.
The battery passport is per item. Article 77(3) requires a unique identifier for each battery.
Article 77(7) requires a new passport when a battery is repurposed. It is also the only route in the regulation that transfers responsibility. That route covers re-use, repurposing, remanufacture and waste status.
Article 77(8) reads:
the battery passport shall cease to exist after the battery has been recycled
So the law treats a materially changed item as a new object rather than a new version of an old one. It also ends the record when the item ends.
| Event | Effect on the passport |
|---|---|
| A repairer replaces one cell | Repair is not in the Article 77(7) list, so the passport continues |
| A company repurposes an electric vehicle battery into a storage unit | A new passport, and the duty moves to that company |
| A recycler processes the battery | The passport ceases to exist |
See lifecycle events.
The EU keeps no copy of what you declared
The European Commission runs a digital product passport registry. It became operational in July 2026, and it stores at least the unique identifiers. The passport itself sits with the economic operator or with a service provider. The Ecodesign for Sustainable Products Regulation (ESPR) requires a decentralised data system.
The registry does not confirm that your data is correct. Its communication is not proof of compliance with the regulation. See the EU registry.
The registry does version its own record. Article 10(2) of the registry implementing act requires the registry to support versioning, and to store a Commission time stamp for each update. Article 14 logs every data change for the full life of the registration.
Warning: that rule covers the registry record, and not your passport. It gives you no version history of the passport data that you keep.
The ESPR sets no passport duty for a product group until a delegated act covers that group. The Commission has adopted no such act for any group. So no operator is yet obliged to upload anything.
The record of what you declared is thus yours to keep.
Keep your own record of what you declared and when
- Record each passport field, its value, the date you set it, and the approver.
- Keep that entry when you change the field. Do not write over it.
- Store the record where it survives a change of software supplier.
- Name the party that keeps the record after your company stops.
- Write that answer into your supply agreement. See agreeing data duties.
- Do not buy EN 18221 because a supplier says the law requires a version history.
This site searched for New Zealand material on 16 August 2026, in fifteen separate searches, and read 104 separate pages. The Ministry of Foreign Affairs and Trade wrote the substantial government account, in a market report of October 2025. See what New Zealand agencies have said.
That report tells exporters to prepare, and to put data tracking and reporting systems in place. It names no retention period, and no other page in the search names one either. See what New Zealand agencies have said and the MFAT market report.