For AAC producers selling into Europe, 2026 marks an important regulatory transition. The revised EU Construction Products Regulation (EU) 2024/3110 became mainly applicable on 8 January 2026, but implementation will occur gradually by product family.
Rather than treating 2026 as a single certification deadline, AAC manufacturers should prepare for stronger requirements around traceability, environmental data, digital documentation and factory control. For current and future EU exporters, preparation should begin at the production level.
Understand What Actually Changes in 2026
The revised CPR keeps the fundamental idea behind European construction-product regulation: manufacturers use harmonised technical rules to assess product performance, prepare the required declaration and apply CE marking where applicable.
What changes is the amount and structure of information surrounding the product.
The new CPR introduces or strengthens several areas, including environmental sustainability characteristics, a Declaration of Performance and Conformity (DoPC), Digital Product Passports, revised assessment and verification systems, technical documentation and market surveillance.
A simplified comparison looks like this:
| Area | Traditional CPR Approach | Direction Under CPR 2024 |
| Performance declaration | Declaration of Performance | Declaration of Performance and Conformity |
| CE marking | Remains central | Remains central |
| Environmental data | More limited | Increasingly integrated |
| Product information | Mostly document-based | Moving toward structured digital information |
| Traceability | Required | Greater emphasis |
| Environmental verification | Existing mechanisms | New AVS System 3+ |
| Digital Product Passport | Not central | Major future requirement |
| Market surveillance | Established | Strengthened |
There is one important warning for AAC manufacturers: do not assume that every requirement in the new CPR immediately replaces your existing AAC compliance route in January 2026.
The European Commission states that product families migrate individually. Products covered by standards cited under the previous CPR generally continue under that framework until the relevant new performance harmonised standard is cited under CPR 2024. When the previous citation is removed, a minimum one-year transition period is anticipated.
So 2026 is best viewed as a preparation and transition year rather than one universal cut-off date.
Review the Harmonised Standard Used for Your AAC Products
For AAC masonry units, EN 771-4 has been a central European product standard. It covers autoclaved aerated concrete masonry units for load-bearing and non-load-bearing wall applications and addresses characteristics such as density, compressive strength, dimensional properties, thermal performance, water-related properties, reaction to fire and other relevant performance characteristics.
The first practical task for an AAC producer should therefore be straightforward: map every product being exported against the applicable European technical specification and its intended use.
Do not build the compliance system around the general description “AAC block.”
A factory may produce several densities, strength grades, dimensions and configurations. Those variations need to be reflected in product identification, testing, factory production control and supporting documentation.
A useful internal product matrix could include:
| Product Data | Example Information to Control |
| Product type | AAC masonry block |
| Dimensions | Length × width × height |
| Dry density | Declared class/range |
| Compressive strength | Declared performance |
| Thermal properties | Applicable declared value |
| Reaction to fire | Applicable classification |
| Intended use | Load-bearing/non-load-bearing, etc. |
| Production line | Factory/line identification |
| Batch identification | Production traceability |
This may sound administrative, but it is fundamentally a production issue. If the commercial department describes products differently from the laboratory, and the laboratory uses different codes from the production line, regulatory documentation becomes unnecessarily difficult.
Factory Production Control Needs to Become More Data-Driven
For AAC producers, Factory Production Control should not be treated as a binder prepared for an audit.
It should show that the product manufactured on Tuesday afternoon is reasonably consistent with the product whose performance was originally assessed.
That means controlling the variables that actually influence AAC performance: raw-material properties, slurry conditions, dosing accuracy, aluminum addition, mixing, rising, pre-curing, cutting, autoclaving and finished-product inspection.
EN 771-4 already addresses areas such as raw materials, production equipment, production processes, finished-product testing, statistical techniques, traceability and handling of nonconforming products.
For a modern AAC factory, I would concentrate on five groups of records:
- Raw materials: sand/fly ash, cement, lime, gypsum, aluminum and return slurry.
- Process parameters: slurry density, temperature, batching quantities, mixing and pre-curing conditions.
- Autoclaving: pressure, temperature, cycle duration and abnormal events.
- Finished products: density, strength, dimensions and other required performance checks.
- Traceability: production date, batch, mold, shift, testing records and disposition of nonconforming products.
Gathering as much data as possible is not the goal. It is to establish a traceable chain between raw material → process → batch → test result → shipped product.
That chain will become increasingly valuable as European construction-product information becomes more digital.
Environmental Performance Will Move Closer to Product Compliance
This is probably the area AAC manufacturers should pay the most attention to over the next several years.
The revised CPR introduces predetermined environmental characteristics based on Life Cycle Assessment (LCA), helping environmental performance information feed into calculations at the building level. The new framework also introduces AVS System 3+, specifically associated with verification of environmental essential characteristics.
For AAC, this deserves attention because environmental performance is influenced by much more than block density.
Consider the production chain:
Raw materials → grinding → batching → mixing → cutting → steam generation → autoclaving → handling → packaging → transport
Each stage creates inputs that may eventually matter to environmental calculations.
AAC manufacturers preparing early should begin organizing data such as:
| Data Category | Examples |
| Raw materials | Cement, lime, sand/fly ash, gypsum, aluminum |
| Electricity | kWh per production period or per output |
| Thermal energy | Boiler fuel and steam generation |
| Water | Process and make-up water |
| Waste | Cutting waste, rejects, disposal/recycling |
| Packaging | Film, straps, pallets |
| Transport | Raw-material and finished-product logistics |
| Production output | Saleable m³ or tonnes |
The biggest mistake would be waiting until a customer asks for environmental documentation and then trying to reconstruct a year’s production data from invoices.
Environmental reporting is much easier when the factory’s metering and ERP/MES structure have already been designed to capture useful information.
Prepare for the Digital Product Passport
The Digital Product Passport (DPP) is one of the most visible changes introduced by the new CPR. It is intended to make construction-product information available digitally and in machine-readable form throughout the product life cycle, eventually incorporating information such as the Declaration of Performance and Conformity.
But again, AAC manufacturers should distinguish between preparing for DPP and assuming DPP is already mandatory for every AAC block in 2026.
The Commission explains that mandatory DPP use applies 18 months after the relevant delegated act for the product family enters into force. The implementation roadmap is therefore progressive.
That gives manufacturers time, but it should not encourage delay.
The sensible preparation is to clean up product data now.
Imagine a pallet of AAC blocks leaving a factory. Its digital identity could eventually connect product identification with relevant regulatory and technical information.
To prepare, manufacturers should establish a consistent structure for:
Product code → product type → declared characteristics → manufacturing site → supporting documents → batch information
The technology is the easy part. Generating a QR code takes seconds.
Creating reliable data behind that QR code is much harder.
The Declaration and CE-Marking Records Need to Be Examined
A Declaration of Performance and Conformity (DoPC) is required under CPR 2024 for items put on the market under the new framework following the completion of the necessary evaluation and verification processes. CE marking follows the applicable harmonised rules.
The regulation also provides for electronic supply of the DoPC. Under specified conditions, manufacturers can make it available through a website in an unamendable format that is both human- and machine-readable, downloadable, continuously accessible and linked to the product type through its unique identification code.
For AAC exporters, 2026 is therefore a good time to audit the entire documentation chain rather than simply redesign the CE label.
Check whether:
- Product codes match across invoices, labels and declarations.
- Declared characteristics correspond to actual tested products.
- Factory and manufacturer information is consistent.
- Technical documents can be retrieved quickly.
- Test reports can be linked to the relevant product family.
- Product changes trigger a documented review.
- Required language versions are controlled.
- Older document revisions cannot accidentally be issued.
Document control sounds mundane until a customer or market-surveillance authority requests information about a particular shipment.
Then retrieval speed becomes part of compliance quality.
Non-EU AAC Manufacturers Need to Look Beyond the Factory Gate
For manufacturers in China, Turkey, India, the Middle East or other non-EU locations, production compliance is only one part of entering the European market.
Importers have their own obligations. Under the revised framework, importers are expected to verify areas including technical documentation, CE marking where applicable, identification information and required instructions or safety information.
That makes cooperation between manufacturer and importer increasingly important.
A strong European distribution arrangement should therefore establish clearly who manages product documentation, translations, regulatory updates, customer requests and communication with authorities.
From a commercial perspective, this is also useful.
An importer is much more comfortable representing an overseas AAC producer when documentation can be supplied within hours instead of being recreated every time a project requests it.
What AAC Producers Should Do During 2026
The transition does not justify rebuilding the entire compliance system overnight. A staged approach is more practical.
| Priority | Action | Purpose |
| High | Review applicable standards and product families | Establish regulatory baseline |
| High | Audit FPC and traceability | Improve consistency |
| High | Standardize product codes | Prepare digital records |
| High | Review test reports and declarations | Identify documentation gaps |
| Medium-High | Start collecting environmental input data | Prepare for LCA requirements |
| Medium-High | Improve energy and steam metering | Support environmental calculations |
| Medium | Digitize technical documents | Prepare for DPP |
| Medium | Review importer responsibilities | Reduce EU market risk |
| Ongoing | Track new harmonised specifications | Manage CPR transition |
One point deserves particular emphasis: do not redesign the factory solely around regulatory paperwork.
Good compliance data should largely come from good production control.
If an AAC plant already records raw-material consumption accurately, monitors autoclave cycles, maintains batch traceability, controls laboratory testing and measures energy consumption, much of the foundation already exists. The regulatory task becomes one of structuring and verifying that information.
If those systems do not exist, creating attractive certificates will not solve the underlying problem.
Equipment Decisions Will Also Affect Future Compliance
The new CPR is not an AAC machinery regulation, but equipment choices influence how easily an AAC producer can demonstrate stable production and collect reliable data.
When evaluating a new AAC production line or upgrading an existing plant, manufacturers should therefore look beyond nominal capacity.
Batching systems should record material quantities accurately. Autoclave controls should retain meaningful cycle information. Laboratory testing should connect results with production batches. Energy systems should make major consumption points measurable. Production software should allow records to be exported rather than trapped inside proprietary control interfaces.
This is especially relevant for new plants.
A factory designed in 2026 may operate for 20 or 30 years. Spending slightly more during plant design to provide useful metering, traceability and data interfaces is generally easier than rebuilding the information infrastructure five years later.
The Real Change Is From Product Certification to Product Information
EU construction-product regulation is moving toward broader, more structured and increasingly digital product information. The 2026–2029 CPR Working Plan begins this transition, with new harmonised standards and Digital Product Passport measures developing progressively.
For AAC producers, 2026 is a year to prepare rather than panic. Competitive plants will need to demonstrate consistent production, resource use, product performance and reliable supporting records—not simply production capacity.
Preparation should therefore begin with stronger process control, documentation and traceability.