EEE 2025 Rules: What Changes in Certification for Exporters

Key data

If your company exports or distributes products in Norway, Iceland or Liechtenstein, there is a regulatory change you need to review now. The Decision 278/2025 of the EEE Joint Committee, adopted on December 5, 2025 and published on April 16, 2026, modifies Annex II of the EEE Agreement, which regulates the technical regulations, standards, testing and certification applicable throughout the European Economic Area.

The purpose of this decision is to incorporate new EU regulations into the legal framework of the EEE, ensuring that the three non-EU countries of the EEE—Norway, Iceland and Liechtenstein—apply exactly the same technical rules as the Member States of the European Union. For Spanish companies operating in these markets, this can translate into new certification or conformity requirements that must be verified immediately.

What does this regulation establish?

The EEE Agreement is the legal framework that allows Norway, Iceland and Liechtenstein to participate in the European internal market without being EU members. For this to work, these countries must apply the same technical regulations that govern the EU. When the EU updates its rules, the EEE Joint Committee adopts decisions to incorporate those updates into the EEE Agreement.

Decision 278/2025 specifically modifies Annex II of the EEE Agreement, which is the annex dedicated to technical regulations, standards, testing and certification. This annex covers the standards that products must meet in order to circulate freely in the EEE.

The decision ensures regulatory homogeneity between the 27 EU Member States and the three non-EU EEE countries. When the EU approves new technical standards, these must be transferred to the EEE Agreement through this type of decision so that they continue to be applicable throughout the economic area.

Economic and operational impact

The direct impact of this decision depends on the sector and the type of products your company markets. The most relevant operational effects are as follows:

• Review of current certifications: If your products have conformity certifications for the EEE market, you must verify that they remain valid under the new standards incorporated into Annex II.
• Possible need for recertification: If the new technical standards incorporated affect your product category, you may need to update the technical documentation or initiate a new certification process.
• Risk of commercial blockade: Non-compliance with the new technical standards can prevent the free movement of goods in the EEE, which represents a direct risk to commercial operations in Norway, Iceland and Liechtenstein.
• Variable adaptation cost: The cost will depend on the sector and the scope of the regulatory changes incorporated. There is no fixed amount established in the decision.

The main risk is not a direct economic sanction, but the loss of market access: if your products do not comply with the new technical standards, they will not be able to circulate freely in the EEE, which can result in significant commercial losses.

Who does it affect?

This decision directly affects all companies that market products in the European Economic Area. Specifically:

• Spanish manufacturers and exporters who sell products in Norway, Iceland or Liechtenstein.
• Importers and distributors operating in the EEE market who manage the technical compliance of products.
• Companies with current product certifications for the EEE market that must verify their validity.
• Compliance officers and operations directors in companies with presence in the three non-EU EEE countries.
• Advisors and consultants who manage the technical and certification documentation of their clients in the EEE field.
• CFOs and executives who must anticipate possible recertification costs or risks of commercial blockade in these markets.

Practical example

Imagine a Spanish company that manufactures electrical equipment and regularly exports to Norway. Its products bear the CE mark and have proper technical documentation for the EU market.

With the entry into force of Decision 278/2025 on December 5, 2025, Norway—as part of the EEE—must apply the same new technical standards as the EU Member States. If any of those new standards incorporated into Annex II affect the category of electrical equipment manufactured by this company, its current technical documentation could become outdated.

The practical result: if the company does not review and update its certification, its products could be held at Norwegian customs or withdrawn from the market for non-compliance with the new technical standards, thus blocking its commercial operations in that country. The immediate action is to identify what new standards have been incorporated into Annex II and verify whether they affect its product category.

What should companies do now?

1. Identify if your company operates in the non-EU EEE: Verify whether your products are marketed in Norway, Iceland or Liechtenstein. If so, this decision directly affects you.
2. Review the technical standards applicable to your sector: Consult with your certification body or technical advisor what new standards have been incorporated into Annex II of the EEE Agreement and whether they affect your product category.
3. Verify the validity of your current certifications: Check that the technical documentation and conformity certificates of your products remain valid under the new standards.
4. Update technical documentation if necessary: If the new standards affect your products, initiate the process of updating the documentation or recertification with your notified body.
5. Consult the official source: Access the full text of Decision 278/2025 in the Official Journal of the EU to precisely identify what specific regulations have been incorporated into Annex II.
6. Alert your operations and compliance team: Ensure that those responsible for product, quality and export are aware of this change and its implications before making new shipments to EEE countries.