Exporting to Norway, Iceland or Liechtenstein: new technical and energy requirements 2025

Key data

Spanish companies selling or operating in the European Economic Area—Norway, Iceland and Liechtenstein—should pay attention to EEA Joint Committee Decision 269/2025, adopted on 5 December 2025 and published on 16 April 2026. This decision modifies two key annexes of the EEA Agreement: Annex II, relating to technical regulations, standards, testing and certification, and Annex IV, relating to energy.

The practical result is that the three non-EU EEA countries must adapt their internal legislation to align with the incorporated European regulatory acts. For Spanish exporting companies, this can translate into changes in market access requirements: new certifications, updated technical standards or different conditions in the energy market of those countries.

What does this regulation establish?

The EEA Agreement allows Norway, Iceland and Liechtenstein to participate in the European internal market without being EU members. To maintain regulatory coherence, the EEA Joint Committee periodically updates the annexes of the agreement by incorporating new EU legislation.

Decision 269/2025 specifically modifies:

• Annex II — Technical regulations, standards, testing and certification: Incorporates new EU regulatory acts on technical standards, testing procedures and product certification requirements. This means that products marketed in Norway, Iceland and Liechtenstein must comply with the same updated standards that apply in the EU.
• Annex IV — Energy: Incorporates new European energy sector regulations, which may affect the conditions of the energy market in the three EEA countries and, by extension, companies with activity in that sector in those markets.

Entry into force occurred on 5 December 2025, but effective application in each EEA State may require a national transposition process, which introduces variability in the actual timelines for enforcement.

Economic and operational impact

The concrete impact depends on the type of product or service your company markets in the EEA markets. The main operational effects are:

• New product certifications: If the incorporated regulatory acts modify certification requirements, products already circulating in those markets may need recertification or updating of technical documentation.
• Technical adaptations: The standards for product design, manufacturing or testing may change, which may require modifications to the product or quality control processes.
• Energy market conditions: Companies with activity in the energy sector in Norway, Iceland or Liechtenstein should review whether the new regulations incorporated into Annex IV alter the conditions of operation, network access or local regulatory requirements.
• Variable adaptation costs: The regulation does not establish specific cost or penalty amounts, but the costs of recertification, technical adaptation or legal advice can be significant depending on the sector and the volume of affected products.

National transposition in each EEA State may generate different timelines, making it necessary to monitor the specific legislation of Norway, Iceland and Liechtenstein independently.

Who does it affect?

• Spanish companies exporting industrial, technological or consumer products to Norway, Iceland or Liechtenstein that are subject to technical certification or testing standards.
• Companies in the energy sector with activity, contracts or investments in the three EEA countries.
• Manufacturers and distributors whose products require CE marking or other certifications to access the European internal market and the EEA.
• Importers and distributors acting as responsible parties for technical compliance of products in the EEA markets.
• Advisors, consultants and regulatory compliance departments managing the strategy for market access in Europe for their clients or companies.
• Companies with subsidiaries or commercial representations in Norway, Iceland or Liechtenstein.

Practical example

A Spanish electrical equipment manufacturer exporting to Norway has its products certified under the technical standards in force until 2025. Following Decision 269/2025, Annex II of the EEA Agreement incorporates new EU regulatory acts that update the testing and certification requirements for that product category.

Once Norway transposes the decision into its national legislation, this company's equipment must comply with the new standards. If the company does not review whether its current certifications remain valid under the new requirements, it may find that its products cannot be legally marketed in that market until it obtains updated certification, with the resulting recertification cost and possible interruption of sales.

The first step is to identify which specific regulatory acts have been incorporated into Annex II and Annex IV, and verify whether they affect the product category or sector of activity of the company in the EEA markets.

What should companies do now?

1. Identify if your products or services are affected: Review whether you operate in Norway, Iceland or Liechtenstein with products subject to technical certification, testing standards or activity in the energy sector. If so, this decision is relevant to you.
2. Consult the full text of Decision 269/2025: Access the official publication on EUR-Lex to identify the specific regulatory acts incorporated into Annex II and Annex IV, and determine which ones affect your sector.
3. Monitor national transposition in each EEA State: Effective application depends on when and how each country (Norway, Iceland, Liechtenstein) transposes the decision into its internal legislation. Establish a regulatory monitoring system for each relevant market.
4. Review your current product certifications: Verify with your certification body whether current certifications remain valid under the new incorporated standards, or if updating or recertification is required.
5. Evaluate the impact on the energy sector: If your company operates in the energy market of the EEA countries, analyze with specialized advice whether the changes in Annex IV alter the regulatory conditions of your activity.
6. Update technical and commercial documentation: If applicable changes are detected, update technical sheets, declarations of conformity and any documentation required by the new standards before national transposition becomes enforceable.