Key data
| Regulation | Decision of the EEE Joint Committee No. 281/2025, of 5 December 2025 |
|---|---|
| Official reference | OJ:L_202600652 [2026/652] |
| Publication | 16 April 2026 |
| Entry into force | 5 December 2025 |
| Affected parties | Manufacturers, importers and distributors of products with technical requirements in the EEE |
| Geographic scope | European Economic Area: EU (27 countries) + Norway, Iceland and Liechtenstein |
| Category | European Regulation — Technical regulations, standards, testing and certification |
| Modified Annex | Annex II of the EEE Agreement |
From 5 December 2025, companies marketing products with technical requirements in the European Economic Area must operate under an updated regulatory framework. The Decision 281/2025 of the EEE Joint Committee amends Annex II of the EEE Agreement, the document that regulates which technical regulations, testing standards and certification procedures are applicable in the 30 EEE countries.
The practical impact is clear: if your company manufactures, imports or distributes products subject to technical certification—from industrial machinery to regulated consumer products—you must check whether the new technical regulation incorporated affects your declarations of conformity, your current testing or your CE marking.
What does this regulation establish?
The EEE Agreement is the treaty that allows Norway, Iceland and Liechtenstein to participate in the European internal market without being EU members. For this to work, both blocs must apply the same technical rules. When the EU approves new technical regulation, the EEE Joint Committee must formally incorporate it into the Agreement through decisions such as this one.
Annex II of the EEE Agreement is the specific annex that contains all technical regulations, standards, testing and certification procedures applicable in the EEE. Its modification through Decision 281/2025 means that new EU technical regulation becomes mandatory in Norway, Iceland and Liechtenstein as well.
The concrete effects that this update can generate on companies include:
- New testing requirements for already marketed products
- Changes in applicable conformity assessment procedures
- Update of CE marking or other technical marking requirements
- Need to review or update existing declarations of conformity
The regulatory homogeneity pursued by this decision is a guarantee for companies operating throughout the EEE: the same rules in 30 countries. But it also means that any change in EU technical regulation is automatically transferred to the three non-EU EEE countries.
Economic and operational impact
The economic impact of this update depends directly on which specific technical regulation has been incorporated into Annex II. The most common operational effects in this type of updates are:
- Re-testing costs: If the new technical requirements require additional or different testing than already performed, companies must bear the cost of repeating them with notified bodies.
- Technical documentation update: Declarations of conformity, technical files and product manuals may require review and update.
- Possible commercialization halt: Products that do not comply with the new requirements cannot be legally marketed in the EEE until non-conformity is remedied.
- Supply chain impact: Distributors acting as importers in the EEE assume additional responsibilities if the manufacturer has not updated their compliance.
The entry into force date—5 December 2025—is prior to the official publication date (16 April 2026), which means that the obligations are already active. Companies that have not reviewed their situation since December 2025 must do so urgently.
Who does it affect?
This decision directly affects any company operating in the EEE market with products subject to technical regulation:
- Manufacturers of industrial or consumer products that require CE marking or other conformity assessment procedures for commercialization in the EEE
- Importers who introduce products into the EEE market from third countries and are responsible for technical compliance before the authorities
- Distributors who market products in Norway, Iceland or Liechtenstein and must verify that products comply with the technical regulation in force in those countries
- Quality and regulatory compliance managers of companies with presence in the EEE
- Notified bodies that perform conformity assessments for products intended for the EEE market
- Technical advisors and certification consultants who assist companies in their EEE market access processes
Practical example
A Spanish industrial machinery manufacturer that exports its equipment to Norway has a CE declaration of conformity issued in 2023 under the technical regulation in force at that time.
With the entry into force of Decision 281/2025 on 5 December 2025, new EU technical regulation has been incorporated into Annex II of the EEE Agreement. If any of those standards affect the machinery category manufactured by this company, its 2023 declaration of conformity may have become outdated.
The immediate step for this manufacturer is to identify what specific technical regulation has been incorporated into Annex II, verify whether it applies to its products and, if so, update its technical file, repeat the necessary testing and issue a new declaration of conformity before continuing to market in Norway, Iceland or Liechtenstein. Failure to do so may result in its products being considered non-compliant in those markets.
What should companies do now?
- Identify what specific technical regulation has been incorporated into Annex II through Decision 281/2025, by consulting the full text in the EU Official Journal.
- Verify whether that regulation affects your company's products marketed in the EEE, particularly in Norway, Iceland and Liechtenstein.
- Review current declarations of conformity and technical files to verify whether they remain valid under the new technical requirements.
- Contact the corresponding notified body if new testing or updated conformity assessment procedures are required.
- Update technical documentation—declarations of conformity, manuals, markings—if the new requirements so require.
- Inform distributors and importers in non-EU EEE countries about the updated compliance status of the products.
- Establish a monitoring system for future updates to Annex II of the EEE Agreement to anticipate regulatory changes before they come into force.
Frequently asked questions
What changes with Decision 281/2025 of the EEE Joint Committee?
Decision 281/2025 amends Annex II of the EEE Agreement, which regulates the technical regulations, standards and certification procedures applicable in the 30 EEE countries. The specific changes depend on which EU technical regulations have been incorporated into the Annex through this decision.
When does Decision 281/2025 come into force?
The decision came into force on 5 December 2025. Although it was officially published on 16 April 2026, the obligations are already active as of the entry into force date.
Does this decision affect only EU companies or also those in Norway, Iceland and Liechtenstein?
It affects all companies operating in the EEE market, regardless of where they are established. The EEE Agreement ensures that the same technical regulations apply in the 27 EU countries, Norway, Iceland and Liechtenstein.
What should a company do if its products are already on the market in the EEE?
The company must immediately verify whether the new technical regulation incorporated affects its products. If so, it must update its technical documentation, conduct any necessary new testing and issue updated declarations of conformity before continuing to market the products.
Who is responsible for ensuring compliance with the new requirements?
The manufacturer is primarily responsible. However, importers and distributors also have responsibilities to ensure that products comply with applicable technical regulations in the countries where they market them.
Official source
Decision of the EEE Joint Committee No. 281/2025, of 5 December 2025, amending Annex II (Technical regulations, standards, testing and certification) of the EEE Agreement. Published in the Official Journal of the European Union on 16 April 2026 (OJ:L_202600652).
Disclaimer: This article is for informational purposes only and does not constitute legal advice. The information provided is based on the regulatory text and is intended to help companies understand the scope of Decision 281/2025. For specific advice on how this decision affects your company's products and compliance obligations, consult with a qualified legal or technical advisor specializing in EEE regulations and product certification.