EEE Certification 2026: What Changes for Manufacturers and Importers

Key data

If your company manufactures, imports or exports products that require technical certification to circulate in Europe, this decision affects you from 30 April 2026. The Decision 129/2026 of the EEA Joint Committee amends Annex II of the EEA Agreement, which is the framework that regulates which technical standards, tests and certifications are valid throughout the European Economic Area.

The immediate effect is clear: the three non-EU countries of the EEA—Norway, Iceland and Liechtenstein—are obliged to apply the same technical standards as the 27 EU Member States. For Spanish companies operating in these markets, this can mean both a simplification (if they already comply with updated EU regulations) and a barrier (if their certifications do not reflect the latest incorporated modifications).

What does this regulation establish?

The EEA Agreement allows Norway, Iceland and Liechtenstein to participate in the European internal market without being EU members. For this to work, the EEA Joint Committee periodically publishes decisions that incorporate EU technical regulations into the EEA Agreement.

Decision 129/2026 specifically updates the Annex II of the EEA Agreement, which covers:

• Technical regulations applicable to products
• Harmonised reference standards
• Recognised testing procedures
• Certification and marking requirements

By incorporating new EU technical regulations into this Annex, it is ensured that a product that meets technical requirements in Spain also meets them in Norway, Iceland and Liechtenstein, and vice versa. Without this update, divergences could exist that block the free trade of regulated products.

It is relevant to note that the date of entry into force (30 April 2026) is earlier than the date of publication in the Official Journal (23 July 2026), which means that the changes are already in application months before the formal publication.

Economic and operational impact

The direct impact of this decision translates into two possible scenarios for companies:

The operational cost of adaptation depends on the sector and type of product, but typically includes: review of technical documentation, possible new laboratory tests, updating of declarations of conformity and, in some cases, modification of the product or its manufacturing process.

The cost of not acting is clearer: the inability to market in the markets of Norway, Iceland and Liechtenstein, which together represent a market of more than 5 million consumers with high purchasing power.

Who does it affect?

• Manufacturers of products with regulated technical requirements that market in the EEA (including the three non-EU countries)
• Importers who introduce into the EEA market products manufactured outside the European area
• Spanish exporters who sell to Norway, Iceland or Liechtenstein products subject to technical certification
• Distributors operating in the supply chain of technically regulated products in the EEA
• Compliance officers (compliance officers, technical directors, quality managers) of companies with presence in the EEA
• Technical advisors and consultants who accompany companies in certification processes for European markets

Sectors with high technical regulation are especially relevant: machinery, electrical and electronic equipment, construction products, medical devices, toys, personal protective equipment and chemical products, among others.

Practical example

A Spanish industrial machinery manufacturer that regularly exports to Norway must check whether the harmonised standards on which it bases its CE declaration of conformity have been updated as a result of this Decision 129/2026.

If the company issued its declaration of conformity referencing a version of a standard that has been superseded by the new regulations incorporated into Annex II of the EEA, Norwegian authorities could consider that the product does not meet current technical requirements and block its marketing or require additional documentation at the border.

The update process in this case would involve: identifying which specific technical standards have been modified, verifying whether the product still complies with the new requirements, updating the declaration of conformity and, if necessary, conducting new accredited laboratory tests.

What should companies do now?

1. Identify whether you market technically regulated products in the EEA — If you sell in Norway, Iceland or Liechtenstein products that require CE marking or other technical certifications, this decision directly affects you.
2. Review current certifications and declarations of conformity — Check that the technical standards referenced in your conformity documents remain the updated versions recognised in Annex II of the EEA.
3. Consult with your certification body or testing laboratory — Specifically ask whether the standards under which you certified your products have been modified by Decision 129/2026 or by the EU regulations it incorporates.
4. Update technical documentation if necessary — If divergences are detected, update the declaration of conformity and, if regulatory changes require it, submit the product to new tests.
5. Establish a continuous regulatory monitoring system — EEA Joint Committee decisions are published periodically. Having alerts about new modifications to Annex II prevents surprises in future commercial operations.

Official source

Consult complete regulations 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_202601498