EEE 2026 Certification: What Changes for Manufacturers and Importers

Key data

If your company manufactures, exports or imports regulated products to or from Norway, Iceland or Liechtenstein, this decision directly affects you. The Decision No. 85/2026 of the EEE Joint Committee, adopted on 20 March 2026, updates Annex II of the EEE Agreement by incorporating new EU technical regulations. This means that the three non-EU countries that are part of the EEE must apply the same technical standards as EU Member States, including Spain.

The practical result: if your product was already certified for the European market, it will likely remain valid. But if there is new technical regulation incorporated that affects your sector, you need to verify this before a customs authority or control body points it out to you.

What does this regulation establish?

The Agreement on the European Economic Area (EEE) extends the EU internal market to three additional countries: Norway, Iceland and Liechtenstein. For this market to function without friction, these countries must apply the same technical standards as EU Member States.

The Annex II of the EEE Agreement is the instrument that contains all technical regulations, standards, testing and certifications applicable in this expanded market. Each time the EU approves new technical regulations, the EEE Joint Committee must formally incorporate them into Annex II through a decision. That is exactly what Decision 85/2026 does.

In operational terms, this update implies:

• New EU technical regulations are incorporated into the EEE scope.
• Norway, Iceland and Liechtenstein are obliged to apply those same standards.
• Companies trading with these countries must comply with updated technical requirements to maintain market access.
• Certification bodies operating in the EEE must take new standards into account in their conformity assessment processes.

The decision was adopted on 20 March 2026 and published in the EU Official Journal on 25 June 2026, which means that entry into force is prior to publication: companies already operating in these markets should have adapted their processes since March.

Economic and operational impact

The direct economic impact of this decision is not measured in fixed fines, but in trade barriers: if a product does not comply with the new technical standards incorporated into Annex II, it can be rejected at the border, withdrawn from the market or blocked by the control authorities of the non-EU EEE countries.

Potential operational costs for affected companies include:

• Review of current certifications: cost of internal or external audit to verify whether current certificates cover new requirements.
• New testing or conformity assessment tests: if the incorporated regulation introduces additional testing requirements, it will be necessary to repeat tests with notified bodies.
• Update of technical documentation: declarations of conformity, CE marking and technical files may need review.
• Risk of export paralysis: non-compliance may result in goods being held at the border or suspension of marketing in the affected EEE countries.

For companies with significant business volume in Norway, Iceland or Liechtenstein, the cost of inaction can far exceed the cost of a preventive conformity review.

Who does it affect?

• Manufacturers of regulated products marketed in the EEE (machinery, electrical equipment, construction products, medical devices, toys, personal protective equipment, etc.).
• Spanish exporters selling products to Norway, Iceland or Liechtenstein.
• Importers bringing products from these three countries to the Spanish or European market.
• Certification bodies and testing laboratories that issue conformity certificates for the EEE market.
• Authorized representatives of non-European manufacturers placing products on the EEE market.
• Distributors operating in the supply chain of regulated products in the EEE.

The sectors with the greatest exposure are those with denser technical regulations: electronics, industrial machinery, construction, medical products, packaged food, telecommunications equipment and chemical products.

Practical example

A Spanish manufacturer of industrial electrical equipment regularly exports to Norway, its main market outside the EU. Until now, its CE marking and certification obtained under the applicable European directive were sufficient to market in that country, since Norway applies Annex II of the EEE Agreement.

With Decision 85/2026, new EU technical standards are incorporated into Annex II. If any of these standards affect this company's product category (for example, new testing or technical documentation requirements), its current certification could be insufficient to continue marketing in Norway.

The immediate step for this company is to identify what specific technical regulations have been incorporated into Annex II, verify whether its product falls within the scope of that regulation, and consult with its notified body whether the current certification covers the new requirements. If it does not, it must initiate the update process before Norwegian market control authorities detect non-compliance.

What should companies do now?

1. Identify if you market products in Norway, Iceland or Liechtenstein: if the answer is yes, this decision is relevant to your operation.
2. Consult the full text of Decision 85/2026: review what specific technical regulations have been incorporated into Annex II of the EEE Agreement to identify whether they affect your sector or product.
3. Review your current certifications: compare the requirements of the new incorporated regulations with your current certificates, declarations of conformity and technical files.
4. Contact your notified body or testing laboratory: if there are doubts about the validity of current certifications, request a conformity assessment with the new standards.
5. Update technical documentation if necessary: EU declarations of conformity, technical manuals and labeling may require updating.
6. Inform your export and logistics team: ensure that operations managers are aware of the changes to avoid border incidents.

Remember that the decision has been in force since 20 March 2026. If your company was already exporting to these markets on that date, the adaptation period has already begun.

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_202601285