EEE Technical Certification 2025: what changes for manufacturers and importers

Key data

If your company manufactures, imports or distributes products that require technical certification to circulate in the European market, this update affects you directly. The Decision 282/2025 of the EEE Joint Committee modifies Annex II of the Agreement on the European Economic Area, which is the framework that regulates which technical standards, testing and certification schemes are valid in the 30 EEE countries.

The decision entered into force on 5 December 2025, although its official publication in the Official Journal took place on 16 April 2026. This means that the changes are already applicable and that any company that has not reviewed its compliance situation has accumulated time of exposure to risk.

What does this regulation establish?

The Annex II of the EEE Agreement is the document that harmonises technical regulations between the countries of the European Union and the three EEE countries not belonging to the EU: Norway, Iceland and Liechtenstein. Each time the EU approves new technical regulations, the EEE Joint Committee must incorporate them into the agreement through a formal decision so that they are also applicable in those three countries.

Decision 282/2025 does exactly that: it incorporates new EU technical regulations into the EEE legal framework, ensuring regulatory homogeneity throughout the area. The objective is that a product certified under EEE standards can circulate freely in the 30 countries without the need for additional certifications by country.

For Spanish companies, the practical impact is that the technical requirements that already apply in the EU are extended or updated also for operations with non-EU EEE countries. If your company exports to Norway, for example, this decision may modify the certification requirements you must comply with.

Economic and operational impact

The economic impact of this update depends directly on the type of products your company markets and whether the changes incorporated into Annex II affect the technical standards under which they are certified.

The specific risks identified in the regulation are two:

• Market access barriers: If products do not comply with updated technical standards, they may be rejected at customs or withdrawn from the market in EEE countries.
• Administrative sanctions: Non-compliance with current certification requirements may result in enforcement proceedings by market surveillance authorities.

From an operational perspective, affected companies may need to review their technical documentation, update declarations of conformity, repeat testing or renew certificates issued under standards that have been modified or replaced by this decision.

Who does it affect?

This regulation specifically affects companies that market products in the European Economic Area subject to technical certification. Specifically:

• Manufacturers of products that require CE marking or other certification schemes recognised in the EEE.
• Importers who introduce products into the EEE market from third countries.
• Distributors who market products within the EEE and are responsible for verifying the conformity of what they distribute.
• Spanish exporting companies that sell products to Norway, Iceland or Liechtenstein and must comply with EEE technical requirements.
• Compliance and technical directors of industrial, consumer or technology companies with certified products.
• Advisors and consultants who manage technical compliance for their clients in European markets.

Practical example

A Spanish company manufacturing electrical equipment exports its products to Norway, a member of the EEE but not of the EU. Its products are certified under certain harmonised technical standards and bear the CE mark.

Following the entry into force of Decision 282/2025 on 5 December 2025, Annex II of the EEE Agreement incorporates new EU technical regulations. If any of those standards affect the electrical equipment manufactured by this company, its current certificates may have become outdated with respect to the requirements in force in the EEE.

If the company does not verify this point and continues to export with the previous documentation, its products could face barriers to access the Norwegian market or administrative sanctions from market surveillance authorities. The solution involves reviewing which specific standards have been incorporated into Annex II and checking whether its products are affected, updating the technical documentation if necessary.

What should companies do now?

1. Identify whether your products are subject to technical certification in the EEE: Check whether your products require CE marking or other certification schemes to circulate in the EEE market, including Norway, Iceland and Liechtenstein.
2. Verify which technical standards have been incorporated into Annex II: Consult the full text of Decision 282/2025 in the Official Journal of the EU to identify which specific technical regulations have been incorporated into the EEE agreement.
3. Check whether your current certificates remain valid: Compare the incorporated standards with the certificates and declarations of conformity of your products. If any standard has been updated or replaced, your documents may need review.
4. Update technical documentation if necessary: If any of your products are affected, update declarations of conformity, technical files and certificates issued by notified bodies.
5. Inform your distribution chain: If you are a manufacturer or importer, communicate to your distributors in the EEE any changes in the technical documentation of the products to avoid problems in market surveillance.
6. Consult with a technical compliance specialist: If you have doubts about the specific impact on your products, a consultant specialised in technical regulations and CE marking can help you assess the real scope of the changes.