EEE Certification 2026: what changes for companies selling in Norway, Iceland and Liechtenstein

Key data

If your company sells or distributes products in Norway, Iceland or Liechtenstein, this decision directly affects you. Decision No. 69/2026 of the EEE Joint Committee, adopted on 20 March 2026 and published on 25 June 2026, amends Annex II of the EEE Agreement, which regulates the technical regulations, standards, testing and certification applicable throughout the European Economic Area.

The objective is to ensure that the three non-EU EEE countries apply the same technical standards as EU Member States. When the EU updates its technical regulations, the EEE Joint Committee incorporates them into the Agreement through decisions such as this one. The practical result: what is valid in the EU must also be valid in Norway, Iceland and Liechtenstein, and vice versa.

What does this regulation establish?

The EEE Agreement creates an expanded internal market that extends beyond the borders of the European Union. For that market to function, technical standards must be homogeneous across all participating countries. When the EU approves new technical regulations—on products, testing or certification—the EEE Joint Committee transfers them to the Agreement through decisions modifying its annexes.

This Decision 69/2026 specifically amends Annex II, which covers the block of technical regulations, standards, testing and certification. The specific changes incorporated are as follows:

• Incorporation of new EU technical regulations into the EEE scope, ensuring regulatory homogeneity between EU Member States and non-EU EEE countries (Norway, Iceland and Liechtenstein).
• Update of certification and conformity requirements applicable to products marketed in the expanded internal market.
• Extension of technical testing specifications in force in the EU to the three non-EU EEE countries.

The decision was adopted on 20 March 2026, a date that also marks its entry into force, although its publication in the Official Journal took place on 25 June 2026.

Economic and operational impact

The main impact is not a new fee or direct penalty: it is the risk of market access blockade. If a product does not comply with the new technical specifications incorporated into Annex II, it may be excluded from marketing in Norway, Iceland and Liechtenstein.

The operational costs derived depend on each company, but the most common scenarios are:

• Review of existing certificates: If the new technical regulation affects the product category, current certificates may need updating or revalidation by notified bodies.
• New conformity testing: Some technical changes may require repeating tests already performed under previous standards, with the laboratory cost and time involved.
• Adaptation of technical documentation: Declarations of conformity, technical datasheets and CE markings may require updating to reflect the new reference standards.
• Risk of border rejection or market withdrawal: Products that do not comply with the new specifications may be withdrawn from the market or rejected in customs controls or market surveillance checks.

Regulatory homogeneity also has a positive side: companies that already comply with EU technical regulations do not need to adapt their products for the three EEE countries. The update to Annex II eliminates divergences that could have generated different requirements.

Who does it affect?

• Manufacturers of products subject to technical certification that market in Norway, Iceland or Liechtenstein.
• Importers who introduce products into the EEE market from third countries.
• Spanish and European exporters with commercial activity in non-EU EEE countries.
• Distributors and authorized representatives acting as conformity managers in the EEE market.
• Notified bodies that issue conformity certificates valid for the EEE scope.
• Foreign trade advisors and certification consultants who manage their clients' technical documentation for these markets.

It does not affect companies operating exclusively in the EU internal market without commercial activity in Norway, Iceland or Liechtenstein.

Practical example

A Spanish electrical equipment manufacturer has valid CE certification and regularly exports to Norway. Until now, its certificate covered the requirements of the EEE Agreement without issue.

With Decision 69/2026, Annex II of the EEE Agreement incorporates new EU technical regulations. If that regulation affects the category of electrical equipment of this company, its notified body will need to verify whether the existing certificate remains valid under the new reference standards, or whether additional testing and an updated certificate are necessary.

If the company does not act and sends a shipment to Norway with technical documentation that no longer references the correct standards, Norwegian market surveillance authorities may reject the batch or require its withdrawal. The cost of that situation—return logistics, loss of the order, reputational damage with the Norwegian customer—far exceeds the cost of a preventive review of the technical documentation.

What should companies do now?

1. Identify whether you market products in Norway, Iceland or Liechtenstein subject to technical certification under the EEE Agreement. If you do not have activity in these markets, this decision does not affect you.
2. Review what EU technical regulations have been incorporated into Annex II through this Decision. Consult the full text in the Official Journal of the EU to identify the affected product categories.
3. Contact your notified body to verify whether current conformity certificates remain valid under the new reference standards incorporated into Annex II.
4. Update technical documentation if necessary: declarations of conformity, technical datasheets and markings must reference the standards in force after the amendment to Annex II.
5. Inform your distributors and representatives in EEE countries about the conformity status of the products, especially if there are changes in the technical documentation.
6. Establish a monitoring process for EEE Joint Committee decisions that amend Annex II, as these updates are recurring and may affect your product portfolio in the future.

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_202601298