EEE Certification 2026: What Changes for Companies Selling in Europe

Key data

If your company exports or distributes industrial products, equipment or materials in the European Economic Area, there is a date you need to know: March 20, 2026. From that date, Decision No. 87/2026 of the EEE Joint Committee comes into force, which amends Annex II of the EEE Agreement and incorporates new EU technical regulations into the regulatory framework applicable also in Norway, Iceland and Liechtenstein.

The objective is to ensure regulatory homogeneity between EU member states and EEE countries not belonging to it. In practice, this means that the certification, testing and marking requirements you already apply for the EU market are extended—with possible nuances—to these three countries. If you have not reviewed your procedures since March 20, you may be operating with outdated documentation.

What does this regulation establish?

The EEE Agreement integrates Norway, Iceland and Liechtenstein into the European internal market. Its Annex II regulates the technical regulations, standards, testing and certification that products must comply with to circulate freely throughout the EEE.

Decision 87/2026 updates that Annex II by incorporating EU regulatory acts that were not previously applicable in the three non-EU EEE countries. The incorporated acts may include:

• Directives or sectoral regulations on industrial products
• Regulations on equipment and machinery
• Technical requirements on materials and components
• Procedures for conformity assessment and marking

The mechanism is the usual one of the EEE Joint Committee: when the EU approves new technical regulations, this committee incorporates them into the EEE Agreement so that they are also enforceable in Norway, Iceland and Liechtenstein. With this decision, economic operators in those countries—and European exporters accessing those markets—are subject to the same technical standards as in the EU.

Economic and operational impact

The concrete impact depends on which specific regulatory acts have been incorporated into Annex II with this decision. However, the usual operational effects of this type of updates are:

• Review of existing certifications: If the incorporated acts affect your sector, you may need to update or renew conformity certificates to continue marketing in Norway, Iceland or Liechtenstein.
• Update of technical documentation: Declarations of conformity, technical manuals and product sheets may require adjustments to reflect the new requirements.
• Review of product marking: Some regulatory changes imply modifications to CE marking or mandatory product indications.
• Adaptation cost: Costs vary depending on the sector and number of affected products, but may include new laboratory testing, updating of technical files and fees for notified bodies.

The retroactive entry into force on March 20, 2026—with publication on June 25, 2026—means that the adaptation period is already underway. Companies that have not initiated the review are accumulating weeks of delay.

Who does it affect?

• Spanish and European manufacturers and exporters that market products in Norway, Iceland or Liechtenstein.
• Importers and distributors that introduce products into the EEE market and are responsible for technical compliance.
• Industrial companies with products subject to technical directives (machinery, electrical equipment, personal protective equipment, construction products, etc.).
• Quality and regulatory compliance managers (compliance officers, technical directors, product managers).
• CFOs and operations directors who must budget for possible recertification costs.
• Legal advisors and foreign trade consultants who advise companies with activity in the EEE.

Practical example

Imagine a Spanish company manufacturing personal protective equipment (PPE) that exports to Norway through a local distributor. Until now, its technical documentation and declaration of conformity complied with EU requirements, and that was sufficient to access the Norwegian market thanks to the EEE Agreement.

With Decision 87/2026, if any of the regulatory acts incorporated into Annex II affects PPE—for example, an update to the conformity assessment regulation—the company will need to:

1. Verify whether the new incorporated regulation applies to its product category.
2. Review whether its current certification remains valid under the new requirements.
3. Update the declaration of conformity and, if necessary, repeat testing with a notified body.
4. Communicate the changes to its distributor in Norway to avoid problems at customs or market inspections.

The cost of this process can range from a few hundred euros (documentary update) to several thousand (new laboratory testing), depending on product complexity and the scope of incorporated regulatory changes.

What should companies do now?

1. Identify whether you market products in Norway, Iceland or Liechtenstein. If you do not have activity in these three countries, this decision does not directly affect you.
2. Consult the full text of Decision 87/2026 to identify which specific regulatory acts have been incorporated into Annex II of the EEE Agreement and whether any apply to your products.
3. Review your current certifications and technical documentation to verify whether they remain valid under the new incorporated requirements.
4. Contact your notified body or technical advisor to assess whether new testing, file updates or marking changes are required.
5. Update the declaration of conformity if the regulatory changes require it, and communicate it to your distributors or authorized representatives in the affected EEE countries.
6. Establish a regulatory alert system to not miss future updates to Annex II of the EEE Agreement, which occur periodically.

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_202601292