Halons in foreign aircraft fire extinguishers: what changes in the EU in 2026

Key data

Third-country airlines flying to Europe faced a first-order technical and regulatory problem: the Regulation (EU) 2024/590 on substances that deplete the ozone layer generally prohibits the use of halons, but replacing them in aviation is not as simple as changing an office fire extinguisher. It requires complex technical certifications that cannot be completed overnight.

The Commission Implementing Regulation (EU) 2026/2489, published on 11 November 2026 and in force from 10 November, resolves this situation with a temporary exception to Article 9.4 of Regulation (EU) 2024/590. The Commission recognizes that requiring foreign operators to adapt their fleet immediately is practically unfeasible, and acts accordingly.

What does this regulation establish?

Regulation 2026/2489 grants a temporary critical use of two specific substances in a very specific context:

Halon is generally prohibited in the EU due to its negative impact on the ozone layer. However, in aviation, its replacement cannot be done unilaterally or immediately: each change in on-board safety systems requires certification processes with the relevant aeronautical authorities, both in the country of registration and in the countries where the aircraft operates.

The exception is not a blank check: it implies coordination with aeronautical authorities and monitoring of compliance by EU Member States.

Economic and operational impact

For third-country airlines affected, this exception has a direct operational impact and avoids significant costs and disruptions:

• Prevents operational paralysis: Without the exception, third-country aircraft with halon extinguishers would not have been able to legally operate in European airspace from 10 November 2026.
• Eliminates pressure for urgent certification: The process of replacing halons in aviation requires complex technical certifications. The extension provides time to complete them without immediate regulatory urgency.
• Involves active monitoring: EU Member States are responsible for verifying compliance. Affected airlines must be prepared to demonstrate that their equipment falls within the exception.
• Does not affect European airlines: Companies registered in the EU do not benefit from this exception and must fully comply with Regulation (EU) 2024/590.

Who is affected?

• Airlines from non-EU countries operating routes to European airports (intercontinental flights, charter, cargo, etc.).
• Operators of aircraft registered in third countries that operate within EU airspace.
• Aeronautical authorities of Member States, which must coordinate and supervise compliance with the exception.
• Compliance officers and operations directors of non-European airlines with routes to Europe.
• Legal advisors and aviation consultants advising third-country operators on their obligations in European airspace.

European airlines, operators of aircraft registered in the EU, and companies outside the aviation sector are not affected by this regulation.

Practical example

An airline based in Turkey operates regular flights between Istanbul and several European airports. Its aircraft are registered in Turkey and equipped with portable halon-1211 fire extinguishers in the passenger and flight decks, as required by its national aeronautical authority.

Without Regulation 2026/2489, from 10 November 2026 that airline would have breached European regulations on ozone-depleting substances every time its planes landed at an EU airport. Replacing the extinguishers with halon-free models would require obtaining certification from Turkish and European authorities, a process that cannot be completed immediately.

Thanks to the temporary exception, the Turkish airline can maintain its current extinguishers during the exception period, provided that its operations in the EU are monitored by Member States. Its compliance department must document that its aircraft fall within the scope of Regulation 2026/2489 and be prepared to demonstrate this to the competent authorities.

What should companies do now?

1. Verify if the exception applies to your fleet: Confirm that your aircraft are registered in a non-EU country and operate in European airspace. Only in that case does the exception in Regulation 2026/2489 apply.
2. Document compliance: Prepare documentation proving that fire extinguishers with halon-1211 or halon-2402 are installed in passenger or flight decks, as required by the exception. Member States will conduct active monitoring.
3. Initiate the certification process for replacement: The exception is temporary. Contact your national aeronautical authority to initiate the certification process for alternative halon-free extinguishers, so that the transition is completed within the exception period.
4. Coordinate with European aeronautical authorities: If you operate in several EU countries, ensure that your situation is known to the aeronautical authorities of the Member States where you land, as they are responsible for monitoring compliance.
5. Review Regulation (EU) 2024/590: Familiarize yourself with the general framework on ozone-depleting substances, as the exception is a temporary measure linked to that base regulation and any changes to it may affect your situation.

Official source

Consult full 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_202602489