Key data
| Regulation | Decision of the EEA Joint Committee No. 121/2026 |
|---|---|
| Publication | July 23, 2026 |
| Entry into force | April 30, 2026 |
| Affected parties | Companies that market products with technical certification in the European Economic Area |
| Category | European Regulation |
| Official reference | OJ:L_202601503 — EUR-Lex |
| Territorial scope | European Economic Area: EU + Norway, Iceland and Liechtenstein |
| Modified annex | Annex II of the EEA Agreement — Technical regulations, standards, testing and certification |
If your company sells or intends to sell products with CE marking or any type of technical certification in Norway, Iceland or Liechtenstein, this decision directly affects you. Decision 121/2026 of the EEA Joint Committee, adopted on April 30, 2026 and published in the Official Journal on July 23, 2026, amends Annex II of the EEA Agreement, which regulates the technical regulations, standards, testing and certification applicable throughout the European Economic Area.
The mechanism is clear: when the EU approves new technical regulations, the EEA Joint Committee formally incorporates them into the EEA Agreement through decisions like this one, making them binding also in the three non-EU EEA countries. If your company already complies with the technical regulations in force in the EU, the changes are likely to be manageable. If not, the impact could be significant.
What does this regulation establish?
The EEA Agreement allows Norway, Iceland and Liechtenstein to participate in the European internal market without being EU members. For this to work, both parties must apply the same technical rules. When the EU updates its technical regulations, the EEA Joint Committee adopts decisions to incorporate them into the Agreement.
Decision 121/2026 specifically amends Annex II, which covers:
- Technical regulations applicable to products in the expanded internal market
- Harmonized technical standards (EN, ISO/IEC standards adopted in the EEA)
- Testing procedures and conformity assessment procedures
- Certification requirements for access to the EEA market
The decision was adopted on April 30, 2026, a date that also marks its entry into force. This means that the new technical requirements incorporated are enforceable from that date, although the official publication in the EU Official Journal took place on July 23, 2026.
Economic operators must review the specific technical standards incorporated in this decision to determine whether their products or certification processes require adaptation.
Economic and operational impact
The impact varies depending on whether your company already operates under EU technical regulations or has differentiated certification processes for non-EU EEA markets.
| Business scenario | Expected impact | Required action |
|---|---|---|
| Company that already complies with current EU technical regulations | Low — EEA changes replicate EU regulations | Verify that conformity documentation covers the EEA scope |
| Company with specific certifications for Norway, Iceland or Liechtenstein | Medium-high — may require homologation updates | Review incorporated technical standards and update files |
| Company planning to enter non-EU EEA markets in 2026 | High — must comply with new requirements from the start | Adapt certification process before commercializing |
| Company that does not market in non-EU EEA | None | No action required |
The main risk is not direct economic, but market access blockage: non-compliance with updated technical standards may prevent product commercialization in the expanded EEA internal market, with the resulting impact on sales and active contracts.
Who does it affect?
- Manufacturers and importers of products subject to technical certification (machinery, electrical equipment, construction products, medical devices, toys, PPE, etc.) that market in Norway, Iceland or Liechtenstein
- Spanish exporters with customers in the three non-EU EEA countries
- Notified bodies and testing laboratories that issue conformity certificates valid in the EEA
- Regulatory compliance managers and technical directors of industrial companies with presence in the EEA
- Distributors and authorized representatives in Norway, Iceland or Liechtenstein who act as conformity managers
- Legal advisors and certification consultants who support companies with activity in the EEA
Practical example
A Spanish manufacturer of personal protective equipment (PPE) has customers in Norway and markets its products under CE marking in accordance with Regulation (EU) 2016/425. Until now, its declaration of conformity and tests carried out by a Spanish notified body were sufficient to access the Norwegian market.
With Decision 121/2026, the EEA Joint Committee incorporates into Annex II new harmonized technical standards that the EU has updated. If any of those standards affect the category of PPE manufactured by this company, it must:
- Identify what specific technical standards have been incorporated into Annex II
- Verify whether its products already comply with those standards or require new testing
- Update the declaration of conformity and, if necessary, obtain a new certificate from the notified body
- Communicate the change to its distributors in Norway before they market the product
If it does not act, its products could be withdrawn from the Norwegian market for non-compliance with technical requirements in force from April 30, 2026.
What should companies do now?
- Identify whether you market products in Norway, Iceland or Liechtenstein — If you have no presence in these markets, this decision does not affect you.
- Review the full text of Decision 121/2026 on EUR-Lex to identify what specific technical standards have been incorporated into Annex II.
- Compare the new standards with your current certifications — Verify whether your products already comply with the incorporated standards or whether they require updated testing or documentation.
- Contact your notified body or certification laboratory to assess whether it is necessary to repeat tests or update the technical file.
- Update the declaration of conformity if the new standards affect your products, with a date after April 30, 2026.
- Inform your distributors in the non-EU EEA about any changes in conformity documentation to avoid customs or market inspection issues.
Frequently asked questions
From when are the new technical requirements of Annex II of the EEA enforceable?
The new requirements are enforceable from April 30, 2026, the date of adoption of Decision 121/2026 by the EEA Joint Committee. Although the official publication in the EU Official Journal took place on July 23, 2026, the entry into force is retroactive to the adoption date.
Does this decision affect companies that only sell in the EU, without presence in Norway, Iceland or Liechtenstein?
No. Decision 121/2026 extends EU technical regulations to the three non-EU EEA countries (Norway, Iceland and Liechtenstein). If your company only markets within the EU, this decision does not generate additional obligations, since the underlying technical regulations were already applicable in the EU market.
What happens if my company does not update its certifications in accordance with Decision 121/2026?
Non-compliance with updated technical standards may prevent access to the expanded EEA internal market. In practice, this may result in product withdrawal from the Norwegian, Icelandic or Liechtenstein market, customs blockages or the inability to renew contracts with customers in those countries.
How do I know what specific technical standards this decision incorporates?
You must consult the full text of Decision 121/2026 available on EUR-Lex. The document specifies what EU regulatory acts are incorporated into Annex II of the EEA Agreement. It is recommended that a technical manager or certification advisor analyze whether any of those standards affect your company's products.
Is CE marking sufficient to market in Norway, Iceland and Liechtenstein after this decision?
In general, CE marking remains valid in the EEA, as these countries apply the same technical directives and regulations as the EU. However, following Decision 121/2026, you must verify that your declaration of conformity references the updated versions of the technical standards incorporated into Annex II, especially if harmonized standards relevant to your sector have been updated.
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_202601503