EEA Agreement 2026: new technical requirements for exporters and importers with Norway, Iceland and Liechtenstein

Key data

If your company exports or imports industrial products between the EU and Norway, Iceland or Liechtenstein, this decision affects you directly. Decision No. 138/2026 of the EEA Joint Committee amends Annex II of the EEA Agreement—which regulates technical regulations, standards, testing and certification—to incorporate new EU technical regulations into the shared legal space with the three non-EU EEA countries.

The practical result: what was previously valid for circulation in the EU may require additional review to operate in these markets, or vice versa. The amendment entered into force on 30 April 2026, although it was published in the Official Journal on 23 July 2026.

What does this regulation establish?

The EEA Agreement allows Norway, Iceland and Liechtenstein to participate in the European single market without being EU members. For this to work, the EEA Joint Committee periodically updates the annexes of the Agreement to incorporate European legislation as it is approved.

This Decision specifically amends Annex II, which covers the scope of technical regulations, standards, testing and certification. In practical terms, this means that new technical regulations approved in the EU also become applicable in the three non-EU EEA countries.

The specific effects indicated by the regulation are:

• Incorporation of new EU technical regulations into the EEA legal framework.
• Possible new testing requirements for certain products or industrial sectors.
• Possible new CE marking or homologation requirements to access the markets of Norway, Iceland and Liechtenstein.
• Extension of compliance obligations to companies operating commercially between the EU and these three countries.

The regulation does not specify in its summary the specific sectors affected by this particular update, so each company must verify whether the changes incorporated into Annex II affect the products it markets.

Economic and operational impact

The impact varies depending on the sector and type of product. In operational terms, companies should consider three possible scenarios:

The economic cost depends directly on the affected sector. Updating a technical certification can involve anything from a few hundred euros in document review to several thousand if new tests are required in an accredited laboratory. The risk of not acting is the paralysis of exports or the withdrawal of products from the market in the affected EEA countries.

Who does it affect?

• Spanish exporters selling industrial, technical or consumer products in Norway, Iceland or Liechtenstein.
• Importers bringing products from these three countries to the Spanish or European market.
• Manufacturers whose products are subject to CE marking, technical homologation or conformity certification.
• Distributors and commercial representatives acting as responsible for conformity in the EEA market.
• Quality and regulatory compliance departments of industrial companies with activity in the EEA.
• Advisors and consultants in foreign trade managing operations between the EU and non-EU EEA countries.

Practical example

A Spanish electrical equipment manufacturer regularly exports to Norway with its current CE marking. Following Decision 138/2026, the Joint Committee has incorporated into Annex II a new EU technical directive that affects the category of product it manufactures.

In this case, the company must:

1. Identify what specific technical regulation has been incorporated into Annex II through this Decision.
2. Check whether that regulation affects the category of its products.
3. If there is an impact, review its declaration of conformity and, if necessary, submit the product to new tests with a notified body.
4. Update technical documentation before making new shipments to Norway, Iceland or Liechtenstein.

If the company does not carry out this verification and continues to export without complying with the new requirements, it risks having its products detained at customs or withdrawn from the Norwegian market for non-compliance with applicable technical standards.

What should companies do now?

1. Identify if you operate in non-EU EEA markets: Check whether your company exports or imports products to or from Norway, Iceland or Liechtenstein.
2. Consult the full text of Decision 138/2026: Access the official text on EUR-Lex to identify what specific technical regulation has been incorporated into Annex II.
3. Verify if your products are affected: Cross-reference the incorporated regulation with the category of products you market. If you have doubts, consult with your notified body or technical advisor.
4. Review the declaration of conformity and technical documentation: If there is an impact, update the documents before conducting new commercial operations in the affected EEA countries.
5. Evaluate the need for new tests: If the incorporated regulation requires additional tests, contact an accredited laboratory to plan the tests and estimate costs and timelines.
6. Document the verification performed: Even if you conclude there is no impact, keep a written record of the analysis for future audits or inspections.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202601515