On December 31, 2025, the aviation community will reach its first major milestone in legislation for the protection of the ozone layer, which requires aircraft to be equipped with halon-free portable fire extinguishers. EASA is continuously providing technical support and guidance needed to implement this requirement.
One of EASA’s strategic priorities is the adoption of measures to improve the sustainability of European aviation. To comply with its obligations under the Montreal Protocol with regard to protection of the Ozone Layer, the EU adopted legislation that has phased out the consumption of ozone depleting substances. This provided the long-term framework for legislative and practical action to protect the ozone layer. and established the EU as a world leader on ozone layer protection policy. This legislation is laid out in Regulation (EU) 2024/590.
According to Article 9 and Annex V to Regulation (EU) 2024/590 any in-service aircraft registered in the EU or operated by an operator registered in the EU must be equipped with halon-free portable fire extinguishers. Halons can no longer be used in portable fire extinguishers for the protection of aircraft cabins and crew compartments.
EASA has developed ETSO-2C515 A1 (Aircraft Halocarbon Clean Agent Handheld Fire Extinguisher dated 25.07.2020) that provides the requirements which an aircraft halocarbon clean agent handheld fire extinguisher must meet to be identified with the applicable ETSO marking. The Agency has also recently published certification memorandum CM-CS-013 Issue 01 to provide guidance on the certification of the installation of Halon-free handheld fire extinguishers on CS-23, CS-25, CS-27, and CS-29 aircraft and to support in complying with the end-date of the Ozone Regulation.
Regulation (EU) 2024/590 is not airworthiness-related legislation. An infringement of Regulation (EU) 2024/590 with regard to halon fire extinguishers on aircraft beyond the envisaged end-date would not have an impact on the aircraft’s airworthiness. There are also no grounds under Regulation (EU) 2018/1139 that would oblige Member States to ground an aircraft for non-compliance with the end-date referred to in Regulation (EU) 2024/590. Please note in this respect, that in accordance with Part-26 of Annex I to Regulation (EU) 2015/640, operators of large helicopters and large aeroplanes shall ensure that portable fire extinguishers do not use halon as an extinguishing agent where the individual certificate of airworthiness is first issued on or after May 18, 2019.
Note: Under Article 9(4) of Regulation (EU) 2024/590, derogations from cut-off and end dates may be granted in specific cases where it is demonstrated that no technically and economically feasible alternative is available. Such derogations can be granted only by the European Commission at the request of the competent authority of a Member State (individual companies may not submit derogation requests directly to the Commission). EASA is not the competent authority for granting such derogations.
