Key data
| Regulation | Commission Implementing Decision (EU) 2026/901 of April 17, 2026 |
|---|---|
| Publication | April 27, 2026 (EU Official Journal) |
| Entry into force | April 17, 2026 |
| Affected parties | Manufacturers, importers and distributors of consumer products in the EU |
| Category | European Regulation |
| Supporting standard | Regulation (EU) 2023/988 on general product safety |
| Repealed standard | Commission Implementing Decision (EU) 2019/1698 |
Manufacturers, importers and distributors of consumer products in the EU have a new technical reference framework as of April 17, 2026. The Implementing Decision (EU) 2026/901 updates the European harmonized standards that support the Regulation (EU) 2023/988 on general product safety and repeals the previous Decision 2019/1698. If your company markets consumer products in Europe, this change directly affects how you demonstrate that your products are safe.
What does this regulation establish?
Decision 2026/901 publishes the updated list of European harmonized standards that serve as technical reference for compliance with Regulation (EU) 2023/988. This regulation is the legal framework governing general consumer product safety throughout the European Union.
The central mechanism is the presumption of conformity: if a manufacturer, importer or distributor applies these harmonized standards, it is automatically presumed that their product complies with the safety requirements required by European regulations. It is not mandatory to follow these standards, but doing so greatly simplifies the burden of proof before market surveillance authorities.
| Aspect | Decision 2019/1698 (previous) | Decision 2026/901 (new) |
|---|---|---|
| Reference standard | Directive 2001/95/EC on general product safety | Regulation (EU) 2023/988 on general product safety |
| Status | Repealed | In force as of April 17, 2026 |
| Harmonized standards | List of technical standards from 2019 | Updated list of technical standards 2026 |
| Presumption of conformity | Applicable under Directive 2001/95/EC | Applicable under Regulation (EU) 2023/988 |
The shift from a Directive to a Regulation as the reference standard is relevant: European regulations are directly applicable in all Member States without the need for national transposition, which standardizes requirements throughout the EU.
Economic and operational impact
The main impact is not a new fee or fixed amount: it is the cost of non-compliance. Companies that fail to adapt their technical documentation and certifications to the new harmonized standards are exposed to:
- Product withdrawal from the European market, with consequent logistics costs, reputational damage and lost sales.
- Administrative sanctions by market surveillance authorities in each Member State.
- Loss of the presumption of conformity, which requires proving product safety by other means, generally more costly and time-consuming.
SMEs with limited resources are the most exposed, as the process of reviewing certifications and technical documentation requires time and, in many cases, the hiring of notified bodies or specialized consultants. Identifying exactly which standards have changed compared to Decision 2019/1698 is the first step in sizing the effort required.
Who does it affect?
This regulation affects all companies involved in the supply chain of consumer products in the EU:
- Manufacturers of consumer products marketing in the European market, regardless of where they are established.
- Importers introducing consumer products into the EU from third countries.
- Distributors making products available to the end consumer in the European market.
- SMEs with limited resources, especially vulnerable to the costs of reviewing and adapting certifications.
- Compliance and technical directors of companies with consumer products in their portfolio.
Practical example
A Spanish company that manufactures and markets household products in several EU countries currently has its technical documentation referenced to the harmonized standards published under Decision 2019/1698.
As of April 17, 2026, that documentation must be aligned with the updated harmonized standards published in Decision 2026/901. If the company maintains the old documentation without reviewing it, it loses the presumption of conformity with Regulation (EU) 2023/988. In a market surveillance inspection, it will have to demonstrate by other means that its products are safe, which may involve additional testing, technical reports and delays in commercialization. If it cannot demonstrate this, the authorities may order the product to be withdrawn from the market.
The cost of a product withdrawal—including reverse logistics, destruction or adaptation, customer communication and possible sanctions—far exceeds the cost of a preventive review of technical documentation.
What should companies do now?
- Identify affected products: Review the catalog of consumer products marketed in the EU and determine which are certified under harmonized standards referenced in Decision 2019/1698.
- Compare old and new standards: Compare the harmonized standards of Decision 2019/1698 with those published in Decision 2026/901 to identify which standards have changed, been updated or replaced.
- Review and update technical documentation: Update the declaration of conformity and technical file of each product to reference the new harmonized standards in force.
- Coordinate with notified bodies or laboratories: If changes in technical standards require new tests or evaluations, start the process as soon as possible to avoid interruptions in commercialization.
- Train the compliance team: Ensure that those responsible for quality, regulatory compliance and supply chain are aware of the changes and deadlines.
- Review contracts with suppliers and importers: If the company acts as an importer or distributor, verify that the original manufacturers have also updated their technical documentation in accordance with the new standards.
Frequently asked questions
What is the presumption of conformity and how does it benefit me as a manufacturer?
If your company complies with the European harmonized standards published in Implementing Decision 2026/901, it is automatically presumed that your products comply with the safety requirements of Regulation (EU) 2023/988. This simplifies the burden of proving conformity to market surveillance authorities.
What happens if my company does not adapt its products to the new technical standards?
Non-compliance may result in product withdrawal from the European market and administrative sanctions, according to Decision 2026/901. SMEs with limited resources are especially vulnerable to these non-compliance costs.
When does Implementing Decision 2026/901 on product safety come into force?
Implementing Decision (EU) 2026/901 came into force on April 17, 2026.
What is the difference between Decision 2019/1698 and Decision 2026/901?
Decision 2019/1698 published harmonized standards under Directive 2001/95/EC on general product safety. Decision 2026/901 updates that list and references it to Regulation (EU) 2023/988, which is the new legal framework for general product safety in the EU.
Do I have to follow the harmonized standards or can I use other methods to prove safety?
Following harmonized standards is not mandatory, but it provides the presumption of conformity, which simplifies compliance. If you do not follow them, you must prove safety by other means, which is generally more costly and time-consuming.
Who publishes the harmonized standards referenced in Decision 2026/901?
Harmonized standards are developed by European standardization bodies (CEN, CENELEC and ETSI) and published in the EU Official Journal through implementing decisions like 2026/901.
Official source
Commission Implementing Decision (EU) 2026/901 of April 17, 2026, on the publication of references of harmonized standards under Regulation (EU) 2023/988 of the European Parliament and of the Council on general product safety.
Disclaimer: This article is for informational purposes only and does not constitute legal advice. The information provided is based on the regulatory text available as of the publication date. Regulations and their interpretation may change. Companies should consult with legal and compliance specialists to ensure full compliance with applicable regulations in their specific jurisdiction and sector. The author and publisher are not responsible for any damages or losses arising from the use of this information.