Technical certification in the EEA 2026: what changes for companies with regulated products

Key data

If your company exports or markets regulated products in the European Economic Area, this decision directly affects you. Decision 136/2026 of the EEA Joint Committee, adopted on 30 April 2026, modifies Annex II of the EEA Agreement, which is the framework that regulates technical regulations, standards, testing and certification applicable throughout the EEA.

In practical terms, this means that EU technical regulations are incorporated or adapted to the EEA framework, extending them to the three non-EU countries in the area: Norway, Iceland and Liechtenstein. If you sell products that require technical certification in these markets, the standards you must comply with may have changed.

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, their technical regulatory frameworks must be aligned with those of the EU. The mechanism to achieve this is precisely these decisions of the EEA Joint Committee, which periodically incorporate EU regulations into the EEA Agreement.

Decision 136/2026 modifies Annex II, which specifically covers the field of technical regulations, standards, testing and certification. The concrete effects it may have on your company are as follows:

• New testing requirements: products that previously did not require certain tests may now need them to access EEA markets.
• Certificate recognition: there may be a change in which certificates are valid or recognized in non-EU EEA countries.
• Update of applicable standards: the technical reference standards for product compliance may have been updated or replaced.
• Extension of EU regulations to the EEA: technical regulations that you already applied to the EU market are formally extended to Norway, Iceland and Liechtenstein, which may simplify or complicate management depending on your current situation.

The modification affects industrial sectors with regulated products, that is, those that require CE marking, declaration of conformity or other certification mechanisms for their commercialization.

Economic and operational impact

The economic impact depends directly on whether the changes introduced in Annex II affect the standards under which your products are currently certified. The possible scenarios are:

• No immediate impact: if the standards applicable to your products have not changed, your current certification remains valid in the EEA.
• Compliance review: if the reference standards have been updated, you will need to review your technical documentation and, if necessary, update the declaration of conformity.
• New testing: in the most demanding case, it may be necessary to submit products to new tests in accredited laboratories, with the associated cost and time.
• Market access blockade: if compliance is not updated in time, products may not be able to be marketed in Norway, Iceland or Liechtenstein until the situation is regularized.

The regulation entered into force on 30 April 2026, although it was published on 23 July 2026. This means that the adaptation period may be very tight or may have already expired for some companies, so the review must be immediate.

Who does it affect?

• Manufacturers and importers of industrial products with CE marking that export to Norway, Iceland or Liechtenstein.
• Companies in sectors with regulated products: machinery, electrical equipment, medical devices, construction materials, personal protective equipment, toys, chemical products and similar.
• Distributors and economic operators acting as compliance managers in non-EU EEA markets.
• Notified bodies and testing laboratories providing certification services for the EEA scope.
• Technical advisors, compliance consultants and quality managers of companies exporting to the EEA.
• CFOs and operations directors managing the supply chain to the three non-EU EEA countries.

Practical example

Imagine a Spanish industrial machinery manufacturer that regularly exports to Norway. Its product is certified under a European machinery directive and has valid CE marking.

If Decision 136/2026 incorporates into Annex II of the EEA Agreement an update to the harmonized standard of reference for that type of machinery, the company must:

1. Identify whether the updated standard affects the essential safety requirements of its product.
2. Review its technical file and declaration of conformity to check whether it remains valid under the new standard.
3. If the standard has changed substantially, coordinate with its notified body to carry out new tests or update the technical documentation.
4. Update the marking and documentation before making new shipments to Norway.

If it does not act in time, its products could be held at customs or rejected by Norwegian market surveillance authorities, with the resulting logistical, commercial and reputational costs.

What should companies do now?

1. Identify if you export regulated products to the EEA: check whether your company markets products in Norway, Iceland or Liechtenstein that require technical certification or CE marking.
2. Review the modified Annex II: access the full text of Decision 136/2026 in the EU Official Journal to identify which specific standards or regulations have been incorporated or modified.
3. Compare with your current certifications: verify whether the standards under which your products are certified remain the reference standards after the modification of Annex II.
4. Consult with your notified body or technical advisor: if you detect changes affecting your product, contact the notified body responsible for your certification to determine the necessary actions.
5. Update technical documentation if necessary: review and update the declaration of conformity, technical file and product marking if applicable standards have changed.
6. Act with urgency: entry into force was on 30 April 2026. If you have not yet reviewed your compliance, the risk of non-compliance is already active.

Official source

Consult complete regulation at 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_202601489