Russia Presidential Decree 1011 places Rockwool's two Russian insulation subsidiaries under temporary administration

Mechanism

Decree No. 302 (25 April 2023), "On temporary management of certain property," is Russia's standing legal instrument for placing Russian-based property of companies from "unfriendly" jurisdictions under state administration. It operates by an ever-growing schedule/annex: the President periodically signs a short amending decree that adds specific named companies' shares or assets to the list. Decree No. 1011 is one such amendment — signed 31 December 2025 but not officially published (and therefore not in force) until 13 January 2026 — adding 100 percent of the authorized-capital shares of Rockwool LLC and 68 percent of the shares of Rockwool-Volga LLC (both belonging to Denmark's ROCKWOOL A/S) to the Decree 302 schedule, and naming Construction Assets Development JSC as the temporary administrator.

Like the same-day Canpack/StalElement decree (2026-01-13-russia-decree-1012-canpack-stalelement-temporary-administration), this routes control through a specially constituted private administrator rather than the state property agency Rosimushchestvo directly — a pattern that distinguishes this batch from the earlier Fortum, Air Liquide and Silgan seizures.

Downstream implications

• Removes ROCKWOOL A/S's operational control of its four Russian

insulation plants (Moscow, Leningrad and Chelyabinsk regions, and Tatarstan) — ROCKWOOL's own 13 January 2026 disclosure states the company has determined control is lost, not merely restricted.

• Same-day companion decree (No. 1012) placed Polish/French packaging

maker CANPACK Group's Russian subsidiaries under a parallel administrator (StalElement LLC), indicating a bundled year-end batch of Decree 302 amendments rather than a company-specific trigger.

• Extends the same two-stage risk pattern flagged in the Silgan/Vonorus

and Canpack/StalElement filings: temporary administration typically precedes potential fast-track disposal to a state-directed buyer under Decree No. 693 of 30 September 2025 (2025-09-30-russia-decree-693-federal-property-fast-track-sale).

Open questions

• Whether Construction Assets Development JSC (RSA) is linked to other

Decree-302 administrator entities or ultimate beneficiaries, and whether the Rockwool assets are eventually routed through the Decree 693 fast-track sale mechanism.

• Whether ROCKWOOL A/S records an impairment on the Russian units in its

next financial statements, and what portion of group insulation-segment revenue the four plants represented pre-seizure.