Key data
| Regulation | Decision of the EEE Joint Committee No. 123/2026, of 30 April 2026 |
|---|---|
| Official reference | OJ:L_202601499 — [2026/1499] |
| Publication | 23 July 2026 |
| Entry into force | 30 April 2026 |
| Affected parties | Companies marketing products in the European Economic Area (EU + Norway, Iceland, Liechtenstein) |
| Category | European Regulation — Technical regulations, standards, testing and certification |
| Amended Annex | Annex II of the EEE Agreement |
If your company sells products in any of the 30 countries of the European Economic Area, this decision directly affects you. Decision No. 123/2026 of the EEE Joint Committee, adopted on 30 April 2026, amends Annex II of the EEE Agreement—the chapter dedicated to technical regulations, standards, testing and certification—incorporating into the EEE legal framework new technical regulations approved by the EU.
The practical effect is immediate: the updated technical standards now apply not only in the 27 EU countries, but also in Norway, Iceland and Liechtenstein. If your certification process or product compliance does not account for these changes, you may encounter market access barriers.
What does this regulation establish?
The EEE Agreement allows the three non-EU countries of the European economic area—Norway, Iceland and Liechtenstein—to participate in the EU internal market. To do so, the EEE Joint Committee periodically incorporates EU technical regulations into Annex II of the Agreement, which regulates technical regulations, standards, testing and certification.
With Decision 123/2026, the technical standards contained in that Annex II are updated. This means that:
- The new EU technical regulations become applicable in the 30 EEE countries.
- Companies operating in these markets must adapt their certification and compliance processes to the new standards.
- The requirements for CE marking may be affected depending on the technical changes introduced.
- Certification and testing bodies in EEE countries must apply the new standards in their evaluations.
The decision was adopted on 30 April 2026 and published in the EU Official Journal on 23 July 2026, with entry into force retroactive to the date of adoption.
Economic and operational impact
The economic impact of this decision depends on the degree of exposure of each company to the EEE market and the nature of its products. The main cost vectors are:
- Review of current certifications: If the new technical standards modify the conformity requirements of an already certified product, the company must initiate a new evaluation process. This involves testing costs, technical documentation and, where applicable, fees for notified bodies.
- CE marking update: Changes in harmonized standards may require updating the Declaration of Conformity and, in some cases, the product marking itself.
- Risk of market access barrier: A product that does not comply with the new standards may be withdrawn from the market or blocked at customs in any of the 30 EEE countries. The cost of a market withdrawal far exceeds that of preventive adaptation.
- Penalties for non-compliance: The regulation expressly warns that non-compliance with updated technical standards may result in sanctions, the amount of which depends on the national legislation of each EEE country.
Who does it affect?
- Manufacturers and importers of products requiring CE marking for marketing in the EEE.
- Spanish exporting companies selling in Norway, Iceland or Liechtenstein.
- Distributors and authorized representatives of products in the EEE market.
- Quality, regulatory compliance and product certification managers.
- Certification bodies, testing laboratories and notified entities operating in the EEE field.
- CFOs and operations directors managing supply chains destined for non-EU EEE markets.
Practical example
A Spanish manufacturer of low-voltage electrical equipment that regularly exports to Norway has its product certified under the technical standards harmonized to date. Following the entry into force of Decision 123/2026 on 30 April 2026, the technical standards applicable in the EEE are updated.
The company's quality manager must verify whether the new standards incorporated into Annex II affect the family of products marketed in Norway. If the new standards modify testing or design requirements, the company must:
- Update its technical documentation and EU Declaration of Conformity.
- Submit the product to new testing before a notified body if the changes are substantial.
- Update the CE marking if applicable.
If it does not act, the product may be subject to market surveillance action in Norway, with risk of withdrawal and penalty. Preventive review, although it has a cost, is significantly less than a market withdrawal.
What should companies do now?
- Identify affected products: Review the catalog of products marketed in the EEE and determine which are subject to harmonized technical standards contained in Annex II of the EEE Agreement.
- Consult the new incorporated standards: Access the full text of Decision 123/2026 in the EU Official Journal to identify which specific technical standards have been updated.
- Review the current Declaration of Conformity: Verify whether the standards referenced in the Declaration of Conformity of each product remain valid or have been replaced by the new standards.
- Contact the notified body: If the product certification was issued by a notified body, consult with them about the impact of the new standards and the need for re-evaluation.
- Update technical documentation: Adapt the technical file, Declaration of Conformity and, if applicable, the product marking to the new requirements.
- Establish a regulatory alert system: Implement a process to monitor updates to Annex II of the EEE to anticipate future changes and avoid non-compliance situations.
Frequently asked questions
What is Annex II of the EEE Agreement and why is it important for my company?
Annex II of the EEE Agreement regulates the technical regulations, standards, testing and certification applicable in the European Economic Area, which includes the 27 EU countries plus Norway, Iceland and Liechtenstein. When this Annex is updated, the new EU technical standards become mandatory also in those three countries. If your company sells products in any of them, you must comply with the updated standards to maintain market access.
When do the new technical standards of Decision 123/2026 come into force?
Decision No. 123/2026 of the EEE Joint Committee was adopted on 30 April 2026, which is also its date of entry into force. It was published in the EU Official Journal on 23 July 2026, but the new standards are applicable from 30 April 2026.
What happens if my product does not comply with the new EEE technical standards?
According to the regulation itself, non-compliance with updated technical standards may result in market access barriers or sanctions. In practice, this can translate into product withdrawal from the market by market surveillance authorities in EEE countries, customs blocking or administrative penalties whose amount depends on the national legislation of each country.
Do I need to renew the CE marking of my products because of this decision?
It depends on whether the new technical standards incorporated into Annex II affect the conformity requirements of your specific products. The regulation expressly recommends reviewing CE marking and product certification requirements in light of the changes introduced. If the standards referenced in your Declaration of Conformity have been replaced or modified, you must update the documentation and possibly submit the product for new evaluation.
Does this decision affect only exports to Norway, Iceland and Liechtenstein, or also the EU market?
Decision 123/2026 extends EU technical regulations to the EEE legal framework, making them applicable also in Norway, Iceland and Liechtenstein. If your company already complies with EU technical standards in the community market, it is likely that you already comply with the new EEE requirements. However, you must verify this expressly, as the process of incorporation into the EEE Agreement may introduce particularities or specific application timelines.
Official source
Consult complete regulation in official source
Notice: 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_202601499