EEE Certification 2026: what changes for manufacturers and importers

Key data

Manufacturers and importers selling in the European Economic Area have a new review obligation following Decision No. 11/2026 of the EEE Joint Committee, adopted on 6 February 2026. This decision amends Annex II of the EEE Agreement—the chapter dedicated to technical regulations, standards, testing and certification—to incorporate new EU technical legislation that will now also apply in Norway, Iceland and Liechtenstein.

The practical result is clear: if your company markets products in the EEE and is subject to CE marking or conformity assessment procedures, you must check whether the new standards affect your current certifications. Failing to do so could result in blocked access to those markets.

What does this regulation establish?

The European Economic Area Agreement allows Norway, Iceland and Liechtenstein to participate in the European single market without being EU members. For this to work, these three countries must apply the same technical legislation as EU Member States in areas such as industrial products, safety, environment and health.

The mechanism for updating this equivalence is the EEE Joint Committee, which periodically adopts decisions to incorporate new EU regulations into the EEE Agreement. Decision 11/2026 is one of these updates: it amends the Annex II of the EEE Agreement, which specifically regulates technical regulations, standards, testing and certification.

In practical terms, this means that the new EU technical legislation that has been incorporated becomes enforceable also in Norway, Iceland and Liechtenstein. Companies that already comply with requirements in the 27 EU countries must verify that this compliance correctly extends to these three additional markets under the new standards.

The areas most directly affected are:

• Product conformity assessment procedures
• CE marking requirements applicable in the EEE
• Technical standards for product testing and certification
• Market access for manufacturers and importers in the EEE

Economic and operational impact

The direct impact of this decision is not a new fee or specific economic penalty: it is a risk of market access blockade. If a company's products do not comply with the new technical standards incorporated into the EEE, they cannot be legally marketed in Norway, Iceland or Liechtenstein.

For Spanish exporting companies, this has concrete operational consequences:

• Cost of certification review: Companies will need to audit whether their current conformity certificates cover the new technical requirements incorporated. Depending on the product and the notified body, this may involve technical consulting costs and, in some cases, new testing.
• Risk of export paralysis: Products that cannot demonstrate compliance with the new standards may be retained or rejected in the markets of Norway, Iceland and Liechtenstein.
• Update of technical documentation: Technical files and declarations of conformity may need updating to reflect the new requirements.

The actual scope of the impact depends on what specific technical legislation has been incorporated through this decision. Companies should consult the full text of Decision 11/2026 to identify the specific legal acts affected.

Who does it affect?

This regulation directly affects:

• Manufacturers of industrial, consumer or regulated products marketed in the EEE and subject to CE marking or conformity assessment
• Importers who introduce products into the EEE market and are responsible for ensuring their compliance
• Distributors operating in Norway, Iceland or Liechtenstein who must verify that the products they market comply with updated standards
• Quality and regulatory compliance managers in companies with presence in the EEE
• Notified bodies and testing laboratories that certify products for the EEE market
• Technical advisors and certification consultants who advise companies on European market access processes

Practical example

A Spanish manufacturer of electrical equipment regularly exports to Norway, a market that represents 15% of its international sales. Its products have CE marking and certification in accordance with current EU regulations.

Following Decision 11/2026, the EEE Joint Committee has incorporated new EU technical legislation into Annex II of the EEE Agreement. If any of those technical standards affect the category of electrical equipment manufactured by this company, its current certifications may not cover the new requirements applicable in Norway.

The immediate step for this company is to identify what specific legal acts have been incorporated through Decision 11/2026, check whether any apply to its products and, if so, contact its notified body to determine whether certification update is necessary before continuing to export to that market.

What should companies do now?

1. Consult the full text of Decision 11/2026 in the EU Official Journal to identify what specific legal acts have been incorporated into Annex II of the EEE Agreement.
2. Verify whether the new standards affect your products by comparing the incorporated legislation with the product categories you market in Norway, Iceland or Liechtenstein.
3. Review current certifications and declarations of conformity to check whether they cover the new technical requirements or whether updates are necessary.
4. Contact the notified body or testing laboratory responsible for your certifications to assess whether new testing or documentary updates are required.
5. Update the technical documentation of affected products, including technical files and EU declarations of conformity, where applicable.
6. Inform local distributors in Norway, Iceland and Liechtenstein about the compliance status of products to avoid customs or market inspection issues.