Technical certification in the EEA 2026: what manufacturers and importers must review

Key data

If your company manufactures, imports or distributes products in Norway, Iceland or Liechtenstein, this decision affects you directly. EEA Joint Committee Decision 22/2026 modifies the Annex II of the EEA Agreement, which regulates the technical regulations, standards, testing and certification applicable in the European Economic Area, and incorporates new EU technical regulations into these three markets.

The practical result: the certification and testing requirements that already apply in the EU are now extended to the EEA. This may involve changes in technical documentation, testing procedures or recognition of existing certificates for those operating in these markets.

What does this regulation establish?

The EEA Agreement allows Norway, Iceland and Liechtenstein to participate in the EU internal market without being full members. To do this, the EEA Joint Committee periodically updates the annexes of the Agreement to incorporate EU regulations as they are approved.

The Annex II of the EEA Agreement specifically covers technical regulations, standards, testing and certification. Each time the EU approves or modifies regulations in this area, the Joint Committee must decide whether to incorporate them into the EEA Agreement so that they also apply in the three non-EU countries.

Decision 22/2026, adopted on 6 February 2026 and published on 21 May 2026, does precisely that: new EU technical regulations become enforceable in Norway, Iceland and Liechtenstein.

The specific effects that this update can have are:

• New testing requirements for certain product categories.
• Modifications to conformity certification procedures.
• Updated recognition of certificates between EEA and EU countries.
• Possible changes in the technical documentation required to market products in these markets.

Economic and operational impact

The direct economic impact depends on the type of product and the degree of change introduced by the incorporated technical regulation. In general terms, companies may face two types of costs:

• Immediate adaptation costs: review of technical documentation, updating of declarations of conformity and, in some cases, repetition of testing with notified bodies.
• Opportunity costs: if products do not meet the new requirements, they may be blocked at customs or withdrawn from the market in Norway, Iceland or Liechtenstein until the deficiencies are remedied.

On the positive side, regulatory harmonization between the EU and the EEA reduces regulatory fragmentation. If your company already complies with technical requirements in the EU, it is likely that adaptation to the EEA will be minimal or non-existent, as the purpose of these decisions is precisely to align both frameworks.

The real risk lies with companies operating in the EEA with certifications that have not been recently updated or that use certification bodies whose recognition may have changed.

Who does it affect?

• Manufacturers that produce goods subject to technical standards and market them in Norway, Iceland or Liechtenstein.
• Importers that introduce products into the EEA market and are responsible for technical compliance.
• Distributors that market third-party products in these markets and must verify that conformity documentation is up to date.
• Compliance and quality managers in companies with presence in the EEA.
• Technical advisors and certification consultants that manage conformity documentation for clients with activity in these markets.
• Export and international trade departments of companies that include Norway, Iceland or Liechtenstein in their sales strategy.

Practical example

A Spanish manufacturer of industrial electrical equipment that regularly exports to Norway has its products certified under EU technical regulations. With the entry into force of Decision 22/2026 on 6 February 2026, it must verify that the specific technical regulations incorporated into Annex II of the EEA Agreement do not introduce additional or modified requirements compared to those it already complies with.

If the incorporated regulation affects its product category, the quality manager will need to review the declaration of conformity, check whether the tests performed remain valid under the new standards and, if necessary, contact the notified body to update the certification before making the next shipment to Norway.

If the company fails to detect the change and continues to export with outdated documentation, it may face problems in Norwegian customs clearance or claims from the local distributor for non-compliance with applicable technical requirements.

What should companies do now?

1. Identify whether your products fall within the scope of Annex II of the EEA Agreement. If you market products subject to technical standards in Norway, Iceland or Liechtenstein, this decision is relevant to you.
2. Consult the full text of Decision 22/2026 in the EU Official Journal to identify what specific technical regulations have been incorporated into Annex II.
3. Review the technical documentation and declarations of conformity of the affected products to verify that they remain valid under the new requirements.
4. Contact your notified body or technical advisor if you detect that requirements have changed and it is necessary to update testing or certifications.
5. Inform your export and logistics team about the changes to avoid problems in customs clearance in the affected EEA countries.
6. Establish a monitoring process for EEA Joint Committee decisions if you regularly operate in these markets, as these updates are periodic.