Technical certification in the EEA 2026: what changes for exporting companies

Key data

Companies operating in the European Economic Area have a new review obligation: Decision No. 134/2026 of the EEA Joint Committee amends Annex II of the EEA Agreement, which regulates the technical regulations, standards, testing and certification applicable throughout the common area. The change entered into force on April 30, 2026, although it was officially published on July 23, 2026.

This means that any company marketing products in Norway, Iceland or Liechtenstein—or importing from those countries into the EU—must check whether their current technical certifications remain compliant with the new requirements incorporated into Annex II.

What does this regulation establish?

The EEA Agreement allows non-EU countries—Norway, Iceland and Liechtenstein—to participate in the European internal market. For this to work, they must apply the same technical rules that govern the EU: product standards, testing requirements, certification procedures and marking.

The Annex II of the EEA Agreement is the living document that contains all that harmonized technical regulation. Each time the EU updates its technical regulations, the EEA Joint Committee must adopt a Decision to incorporate those changes into Annex II and extend them to the three non-EU EEA countries.

Decision 134/2026 does exactly that: it incorporates or adjusts harmonized technical standards that affect products and services circulating between EU member states and EEA countries. Affected companies must review whether their products or certification processes fall within the scope of the changes introduced.

Economic and operational impact

The impact of this decision is not uniform: it depends on the sector and the type of product each company markets. However, there are three direct operational consequences that any exporting or importing company in the EEA must take into account:

• Review of current certifications: If the technical standard that supports your current certification has been modified or replaced by Decision 134/2026, that certification may have become outdated. Operating with a non-compliant certification is equivalent to a risk of border rejection or regulatory sanction.
• Recertification cost: Adapting a product to new technical requirements may involve new tests, new reports from notified bodies and, in some cases, product redesign. These costs vary by sector, but can be significant in industries such as electronics, machinery, medical devices or construction materials.
• Risk of operational paralysis: Non-compliance with updated technical requirements can result in market access barriers. In practice, this can translate into goods retention, product returns or suspension of contracts with customers in EEA countries.

Who does it affect?

This decision affects all companies marketing products in the European Economic Area that are subject to technical certification. Specifically:

• Spanish manufacturers and exporters selling products in Norway, Iceland or Liechtenstein.
• Importers bringing products from those three countries into the EU.
• Companies operating in highly regulated technical sectors: machinery, electrical and electronic equipment, medical devices, construction materials, personal protective equipment, toys, vehicles and components, among others.
• Certification bodies and testing laboratories providing services to companies operating in the EEA.
• Technical advisors and compliance consultants managing CE marking or equivalent processes for clients with presence in the EEA.

Practical example

Imagine a Spanish industrial machinery manufacturer that regularly exports to Norway. Its product is certified as compliant with a harmonized technical standard that, following Decision 134/2026, has been updated or replaced in Annex II of the EEA Agreement.

If the company does not review whether its current certification remains valid under the new requirements, it may find that its Norwegian customer—or Norwegian market authorities—reject the product for not meeting the current version of the standard. The practical result: supply paralysis, urgent recertification cost and possible contractual penalty with the customer.

The preventive action is simple: compare the technical standard that supports the current certification with the changes introduced by Decision 134/2026 and, if there is a discrepancy, initiate the update process before the problem reaches the market.

What should companies do now?

1. Identify whether your products are subject to technical certification in the EEA: Check whether the products you market in Norway, Iceland or Liechtenstein require certification in accordance with Annex II of the EEA Agreement. If so, this decision directly affects you.
2. Consult the full text of Decision 134/2026: Access the official source on EUR-Lex to identify which specific technical standards have been incorporated or modified in Annex II.
3. Compare with your current certifications: Compare the technical standards that support your current certifications with the changes introduced. If there is a divergence, your certification may have become outdated.
4. Contact your notified body or testing laboratory: If you detect that any of your certifications may be affected, consult with the corresponding notified body to determine whether a recertification or update process is necessary.
5. Update technical documentation: If recertification is necessary, start the process as soon as possible. Operating with a non-compliant certification can result in market access barriers or regulatory sanctions in EEA countries.
6. Inform your sales and logistics team: Ensure that those managing exports to EEA countries are aware of the change and know that they must verify technical compliance before each shipment.

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_202601488