EEE Certification 2026: what changes for companies exporting to Norway, Iceland and Liechtenstein

Key data

Companies operating in the European Economic Area (EEA) have had new technical standards to comply with since 6 February 2026. Decision 24/2026 of the EEE Joint Committee amends Annex II of the EEE Agreement, which specifically regulates technical regulations, standards, testing and product certification. The practical result: Norway, Iceland and Liechtenstein must now apply the same technical standards as EU Member States, and any company that markets products in these markets must verify that its conformity documentation remains valid.

This update is not a minor procedural change. It directly affects the ability to access the market of three countries with which Spain maintains active commercial relations, and non-compliance can range from barriers to free trade to administrative sanctions.

What does this regulation establish?

The EEE Agreement is the legal framework that allows Norway, Iceland and Liechtenstein to participate in the European internal market without being EU members. For this market to function homogeneously, the Agreement includes a series of annexes that incorporate EU regulations as they are approved.

Annex II specifically covers technical regulations, standards, testing and certification. When the EU approves new regulations in these matters, the EEE Joint Committee must adopt a formal decision to incorporate them into the EEE Agreement. That is exactly what Decision 24/2026 does: incorporate new EU regulations into the EEE legal framework on technical standards.

The direct consequence is that products marketed between the EU and these three countries must comply with updated technical standards. If the certification or testing requirements for a product have changed, previous conformity certificates may have become outdated.

Economic and operational impact

The impact of this regulation is not measured in direct figures of published fees or fines, but in the operational cost of not adapting in time. The specific consequences covered by the regulation are two:

• Barriers to free trade: products that do not comply with the new technical standards may be rejected at the border or withdrawn from the market in Norway, Iceland or Liechtenstein.
• Administrative sanctions: non-compliance with certification requirements may result in sanctioning procedures in the destination countries.

At the operational level, affected companies must assess the cost of reviewing and, if necessary, updating their conformity certificates. This process typically involves the intervention of notified bodies, with the audit, testing and re-certification costs that this entails. Acting preventively is always more economical than managing cargo rejection at destination or a sanctioning procedure.

Who does it affect?

The regulation directly affects all companies that market products in the EEA, that is, in the market formed by the EU plus Norway, Iceland and Liechtenstein. Specifically:

• Spanish companies that export products to Norway, Iceland or Liechtenstein.
• Companies that import products from these three countries to the EU.
• Manufacturers, distributors and importers that have conformity certificates for products marketed in the EEA.
• Compliance and operations directors in companies with commercial activity in the EEA.
• Advisors and consultants who manage technical documentation of products for clients with presence in these markets.
• Companies in sectors with high technical regulation: machinery, electrical equipment, medical devices, construction products, toys, personal protective equipment, among others.

Practical example

A Spanish industrial machinery manufacturer has valid CE conformity certificates for its products, with which it has been exporting to Norway for years without incident. Following the entry into force of Decision 24/2026 on 6 February 2026, the technical standards applicable in the EEA have been updated to incorporate new EU regulations.

If the certification or testing requirements applicable to that machinery have changed as a result of this update, the previous certificates may not be sufficient to demonstrate compliance with the new standards. In that case, the company must contact its notified body to verify whether the current certificates remain valid or whether a re-certification process is necessary before making new shipments to Norway.

Failing to review this situation in time could result in a shipment being rejected at destination, with the logistical, commercial and reputational costs that this entails.

What should companies do now?

1. Identify if you market products in the EEA: determine whether your company exports or imports products between the EU and Norway, Iceland or Liechtenstein. If so, this regulation directly affects you.
2. Review current conformity certificates: verify that your products' conformity certificates remain valid under the new technical standards incorporated into Annex II of the EEE Agreement.
3. Verify if certification or testing requirements have changed: analyze whether the products you market in the EEA are subject to technical requirements that have been modified by the new EU regulations incorporated into the Agreement.
4. Consult with notified bodies: if you have doubts about the validity of your current certificates, contact the notified body that issued them for an updated assessment.
5. Update technical documentation if necessary: if requirements have changed, start the process of updating certificates or tests before making new shipments to the affected EEA countries.
6. Alert your compliance and logistics team: ensure that those responsible for technical documentation, exports and regulatory compliance are aware of this update and its operational implications.