EEE Certification 2026: What companies selling in Norway, Iceland and Liechtenstein must review

Key data

Companies marketing products in the European Economic Area have an immediate obligation: to verify whether their certifications and technical conformity procedures remain valid. The Decision 23/2026 of the EEE Joint Committee, adopted on February 6, 2026 and published on May 21, 2026, modifies Annex II of the EEE Agreement, which regulates technical regulations, standards, testing and certification in the three non-EU countries of the EEE: Norway, Iceland and Liechtenstein.

This is not a minor bureaucratic change. Any company that manufactures, imports or distributes products in these markets must verify whether the technical requirements applicable to its products have changed. If it does not, it risks losing access to the market.

What does this regulation establish?

The Agreement on the European Economic Area allows Norway, Iceland and Liechtenstein to participate in the EU single market without being Member States. To do so, the EEE Joint Committee periodically incorporates new EU legislation into the EEE legal framework through decisions modifying its annexes.

In this case, Decision 23/2026 modifies Annex II, which specifically covers:

• Technical regulations applicable to products
• Testing and verification standards
• Certification and conformity procedures

The practical effect is that the new EU technical legislation incorporated becomes mandatory also in Norway, Iceland and Liechtenstein. Companies that already complied with EU legislation in these areas may be affected if the specific requirements have changed, or if certification procedures have been updated.

The regulation does not specify in the published text which specific EU regulations are incorporated in this decision, so it is recommended to consult the full text in the official source on EUR-Lex to identify the specific acts affected.

Economic and operational impact

The impact is not a direct fine or a new fee. The risk is operational and commercial: if your products do not meet the new EEE technical requirements, they cannot be marketed in Norway, Iceland or Liechtenstein. This can translate into:

• Blocking of shipments or customs detention in EEE countries
• Need to recertify products with notified bodies
• Costs of technical adaptation of products or processes
• Review of conformity documentation (CE declarations, markings, test reports)
• Possible product recalls from the market if already distributed

The cost of adaptation will depend on the sector and type of product, but in sectors with high technical regulation (machinery, electrical equipment, construction products, medical devices, toys, etc.) recertification processes can involve weeks of work and significant costs with certification bodies.

Who does it affect?

This decision directly affects:

• Spanish and European manufacturers that export products to Norway, Iceland or Liechtenstein
• Importers and distributors that introduce products into the EEE market through these three countries
• Quality and certification managers of companies with activity in the EEE
• Foreign trade and logistics departments that manage shipments to these markets
• Technical advisors and conformity consultants that support exporting companies
• Notified bodies and testing laboratories that work with affected companies

It does not affect companies that operate exclusively in the Spanish market or in EU countries without activity in the three non-EU EEE countries.

Practical example

A Spanish industrial machinery manufacturer that regularly exports to Norway must, following the publication of this decision, verify whether any of the technical regulations incorporated into Annex II of the EEE affects its product category.

If the incorporated EU legislation modifies, for example, the marking requirements or the conformity assessment procedures applicable to its machinery, the company will need to update its declaration of conformity, review existing test reports and, if necessary, submit the product for a new assessment by a notified body before continuing to market it in Norway.

If it does not act and the product is already on the Norwegian market without complying with the new requirements, it may face a market withdrawal order from Norwegian surveillance authorities, with the logistical, reputational and commercial costs that this entails.

What should companies do now?

1. Consult the full text of Decision 23/2026 on EUR-Lex to identify which specific EU regulations have been incorporated into Annex II of the EEE and whether they affect your product categories.
2. Review current conformity and certification procedures for each product marketed in Norway, Iceland or Liechtenstein, comparing them with the new incorporated requirements.
3. Contact the notified body or testing laboratory you work with to assess whether it is necessary to update certificates, test reports or declarations of conformity.
4. Update technical documentation (declarations of conformity, markings, manuals) if the requirements have changed for your products.
5. Inform the foreign trade and logistics team about the changes to prevent shipments of products that do not meet the new technical requirements.
6. Establish a monitoring process of EEE Joint Committee decisions to anticipate future changes that may affect your export activity.