If you fly or maintain aircraft, you have probably heard that Halon fire extinguishers were banned. You may have heard it from a fellow pilot at the hangar, seen it in an online forum, or read it in a maintenance bulletin. And like most things that get repeated often enough, it has started to feel like settled fact.
It is not.
Halon 1211 — the agent used in portable aircraft fire extinguishers — was not banned. The production of new Halon ended on January 1, 1994, under the Montreal Protocol on Substances that Deplete the Ozone Layer. Its use, however, was not prohibited. Recycled Halon 1211 has been legally sold and used in aircraft extinguishers ever since. The FAA not only permits it — the FAA continues to actively accept and recommend UL-listed Halon 1211 extinguishers for aviation use. In November 2024, UL Solutions issued a Certification Bulletin confirming the continuation of its UL Mark listing for Halon 1211 fire extinguishers — and notably removed any specific future termination date for the program. As long as reclaimed Halon supply supports it, UL-listed Halon extinguishers will remain available.
So the short answer to "can I still use a Halon fire extinguisher?" is: probably yes — but it depends on where your aircraft is registered, whether your country has enacted the ICAO Halon replacement standard into domestic law, and if so, the date your aircraft's individual certificate of airworthiness was first issued. In at least one country, the type certificate date matters instead.
That is the honest complexity of the situation. Aviation Halon regulations are not uniform. What is fully legal in the United States is prohibited in the European Union. What is permitted on an older aircraft may not be permitted on a newer one. And in many parts of the world, the rules have simply not been settled.
This article gives you a clear, current picture of where things stand — and a practical decision tool you can use for your specific aircraft.
"The question is not whether Halon has been banned. It hasn't — not everywhere. The question is whether it has been banned where you operate."
Why the Confusion Exists
Most of the confusion about Halon traces back to a misreading of two separate regulatory events that happened at different times and had very different scopes.
The first was the 1994 Montreal Protocol production ban. This was global and absolute — no new Halon would be manufactured after January 1, 1994. But the Protocol did not ban the use of existing Halon. It created a recycling and recovery system specifically to allow existing stockpiles to continue serving applications where Halon remained necessary. Aviation was one of those applications.
The second was a more recent development: ICAO's Annex 6 revision in 2016, which established that any portable fire extinguisher on an aircraft whose individual certificate of airworthiness was first issued after December 31, 2018, should use a Halon replacement agent. This is a forward-fit standard — it applies to newly entering aircraft, not to the existing fleet. And crucially, it only has legal force in countries that have enacted it into their own domestic regulations. ICAO sets standards; it does not enforce them. Individual countries must pass their own regulations.
Add to this the European Union's December 31, 2025 retrofit deadline — which applied to EU-registered aircraft regardless of age — and you have three overlapping regulatory events that affected different groups of operators in different ways, at different times. It is little wonder the picture looks blurry.
Where Things Stand Today
As of early 2026, the global regulatory landscape for portable aviation Halon extinguishers looks like this:
- United States and Canada: Halon 1211 remains fully permitted. No retrofit requirement exists. The FAA and Transport Canada continue to accept Halon extinguishers without restriction.
- European Union and United Kingdom: Cabin and crew compartment Halon 1211 extinguishers were required to be retrofitted with approved replacement extinguishers by December 31, 2025. The only EASA-approved replacement is Halotron BrX. Halotron 1 is also not permitted.
- Australia: Halon is permitted on aircraft whose individual certificate of airworthiness was first issued before December 31, 2018. Aircraft certified on or after that date must use an alternative. Australia has enacted the ICAO forward-fit standard into domestic law through CASR 90.150.
- China: Similar to Australia — Halon is permitted on aircraft whose airworthiness certificate was first issued before December 31, 2018. China implemented the ICAO standard through a CAAC airworthiness directive that took effect November 25, 2021.
- Brazil: Halon is permitted on aircraft with a type certificate issued before May 18, 2019. Confirm with ANAC for newer aircraft.
- Other ICAO member states: Halon may or may not be restricted depending on whether the country has enacted the ICAO forward-fit standard into domestic law. For aircraft whose individual airworthiness certificate was first issued before December 31, 2018, the ICAO standard does not apply regardless.
Those are the regions that come up most often. For a fuller picture, the country and region reference table covers 15 countries plus ICAO catch-all cases, comparing Halon 1211, Halotron 1, and Halotron BrX with the governing regulation for each.
Is the Supply of Halon Running Out?
Another common concern is that Halon must be disappearing because new production stopped more than 30 years ago. The data says otherwise.
When Halon extinguishers are retired or replaced, the agent is recovered and recycled as required by law. That recovery infrastructure has kept Halon available long after manufacturing ended. According to the most recent published data, the UNEP Halons Technical Options Committee 2022 Assessment Report, the global bank of Halon 1211 was estimated at approximately 20,000 metric tons in 2022, with projections of around 11,000 metric tons remaining by 2035. Major U.S. recycler AGAS reports that supply continues to meet demand without significant price pressure.
Somewhat counterintuitively, the EU's December 2025 retrofit mandate — which required EU operators to remove and replace Halon extinguishers — has actually added to the global Halon supply. All of that recovered Halon flows back into the recycling market, where it is available to operators in regions where Halon remains legal.
Choosing the Right Extinguisher
If your situation allows Halon 1211, it remains the best available option for most aircraft — lighter, more compact and less expensive. The recycled Halon supply is healthy.
If you operate in the EU or UK, Halotron BrX is the only compliant replacement. It is the closest alternative to Halon 1211 in performance, size, and weight, and it carries approvals from FAA, EASA, ICAO, UL, ISO, and EN. It is more expensive — roughly four to five times the cost of an equivalent Halon extinguisher — and it is disposable rather than rechargeable.
If you fly in both the U.S. and Europe, Halotron BrX is the practical choice: a single extinguisher that satisfies both FAA and EASA requirements, with no servicing risk when you land in Europe.
Not sure which extinguisher is right for your aircraft?
H3R Aviation has been helping operators navigate fire extinguisher regulations for decades. Contact us and we will give you a straight answer.
