EN 18221: data storage, archiving and persistence for digital product passports

EN 18221 is the European standard for how a digital product passport is stored, how its history is archived and how it stays available for as long as the law requires. It is written for companies that place products with a passport on the EU market and for the service providers that store passports on their behalf.

The question it answers is easy to ask and hard to solve: what happens to the passport when the product outlives the company that made it, or when the data changes after the product was sold? EN 18221 is one of the six harmonised passport standards whose references the Commission published in the Official Journal in July 2026.

What the standard covers

The full title is Digital product passport – Data storage, archiving, and data persistence. It was approved by CEN on 3 May 2026, adopted by SIS as SS-EN 18221:2026 on 27 May 2026, and runs to 13 pages, the shortest of the six. The published scope covers three things:

• Decentralised storage. Passports are held by the economic operator or a service provider, not in a central EU database. The registry set up under ESPR Article 13 stores at least the unique identifiers, not the content of the passports.
• Archiving. An archiving service securely stores historical passport data, keeping a complete record of past information. SIS's summary adds that this matters in particular for market surveillance.
• Persistence. The data in a passport must remain available even when the economic operator that created it is no longer active.

The standard also sets requirements for replication between economic operators and back-up operators, and rules for how a passport's lifetime is defined. In their webinar of 25 June 2026, CEN and CENELEC summarised its purpose as keeping data accurate, unaltered, complete and up to date in every phase of the life cycle, allowing versioning and archiving with trusted back-up service providers, and staying technology-agnostic.

What it requires in practice

Every change is archived

A passport is not a record you overwrite. Under clause 4.2 of the standard, archiving starts with the first change to the passport, and every change is archived unless the product rules expressly exempt it, real-time sensor data for example. Archived versions are kept for the passport's whole lifetime, both by whoever created the passport (or its main service provider) and by the back-up provider. The version that applied at a given point in time must be retrievable by actors who are authenticated and authorised. The archive is meant to be queried, not just written to.

For a market surveillance authority this is the point. If the material composition or recycled content in a passport is changed after the product was sold, it has to be possible to see what the passport said when the product was placed on the market.

A back-up copy with a service provider

ESPR Article 10(4) requires the economic operator, when placing the product on the market, to make a back-up copy of the passport available through a digital product passport service provider. Annex III, point (l), lists the reference of the provider hosting the back-up among the data a passport can carry. EN 18221 describes how this works technically: the back-up holds the current version and the historical versions required, and general access to the passport through the back-up opens once the economic operator is no longer active on the market.

The standard's wording is conditional: a back-up copy can be required, and whether it is comes from the rules for the product. For products under ESPR, Article 10(4) requires it. Batteries have their own equivalent protection, described below.

Economic operatorthat created the passport

v3 · currentv2v1

every change is archived (clause 4.2)

replicated

Back-upat a service provider

v3 · currentv2v1

current version and the history required

If the operator is no longer active, general access opens through the back-up.

The lifetime comes from the law, not the standard

EN 18221 does not give a number of years. It defines the passport's lifetime as the period during which regulation requires the passport to be available, and every duration requirement points back to that definition. How long a textile or furniture passport must last is therefore set in the delegated act for the product group. ESPR Article 9(2)(i) says the period must correspond to at least the expected lifetime of the product.

How it relates to the other standards and the law

CEN and CENELEC describe the eight standards as modular and interlinked. In the workflow presented in June 2026, EN 18221 covers steps 3 and 4: storing the passport data at model, batch or item level, and storing it in a back-up.

• EN 18219 requires the identifier to be persistent, including after insolvency or liquidation. That promise only holds if there is still a passport to point to, which is what EN 18221 secures.
• EN 18223 defines the passport header, including lastUpdated and dppStatus. Changes are logged and archived under EN 18221, keyed to the passport's identifier.
• EN 18222 describes the API that reads and updates passports. The archive is what keeps an update from erasing history.
• EN 18239 and EN 18246 cover who may read what and how to show that data has not been altered. Both are approved but not cited in the Official Journal.

ESPR

Commission Implementing Decision (EU) 2026/1736 of 14 July 2026 published the reference of EN 18221:2026 in the Official Journal on 15 July 2026. The decision finds that the six standards satisfy the requirements of ESPR Articles 10 and 11. Under ESPR Article 41(2), a passport that conforms to a harmonised standard is presumed to meet the requirements of Articles 10 and 11 that the standard covers.

Annex ZA of the standard links it to two ESPR requirements: Article 10(4) (clauses 4.3 and 4.5, covering only the technical side of the back-up, not whether one exists) and Article 11(c) (clause 4.5). The ESPR requirements on storage and persistence are:

• Article 10(4): a back-up copy through a digital product passport service provider,
• Article 11(c): the passport is stored by the economic operator responsible for creating it or by service providers,
• Article 11(e): the passport remains available for the period set in the delegated act, including after insolvency, liquidation or cessation of activity in the Union,
• Article 11, second subparagraph: a service provider storing the passport may not sell, reuse or process the data beyond what the service requires, unless agreed with the economic operator.

The Batteries Regulation

The Batteries Regulation (EU) 2023/1542 has its own rules. From 18 February 2027 a battery passport is required for each LMT battery, each industrial battery over 2 kWh and each electric vehicle battery (Article 77(1)). Article 78(c) says the data is stored by the responsible economic operator or by operators authorised to act on its behalf, and 78(e) that the passport must remain available after that operator ceases to exist or ceases its activity in the Union. Article 77(8) sets the end point: the battery passport ceases to exist once the battery has been recycled.

Common misunderstandings

"Storing the latest version is enough"

It is not. A system that keeps only the current state of each passport lacks the history EN 18221 requires, and that history cannot be added afterwards: versions already overwritten are gone.

"The EU stores the passports for us"

It does not. The registry under ESPR Article 13 stores at least the unique identifiers, and for products to be released for free circulation the commodity code. The content of the passports is held decentrally by economic operators and service providers, which is why the standard exists.

"The standard says how many years a passport must last"

It does not. It refers to the lifetime set by regulation. The number of years is in the delegated act for the product group, or for batteries in the Batteries Regulation.

"A back-up host in the passport means the copy exists"

Naming where the back-up should be is a promise, not proof. What counts is that the copy has actually been replicated there and is kept current.

How this looks in practice

In DPP Agent, built by Blippa, every change to a passport is saved as a new version rather than overwriting the old one. The open validator checks whether a passport names a back-up host. A host name alone is not taken as proof: if the publisher itself states that the copy has never been replicated, the requirement is reported as partly met. The rule applies to DPP Agent's own passports too. The whole series is in the overview of the DPP standards, and identifiers and data carriers per product category are on the DPP standards page.