Work through each step in order. Stop when you reach a definitive answer.
Three terms worth understanding before you use this checklist
Type Certificate (TC)
Issued once to an aircraft manufacturer, covering the design of a particular model. Does not change when individual aircraft are built or sold. Brazil uses the TC date as its regulatory trigger.
Individual Certificate of Airworthiness
Issued to your specific aircraft by tail number when it first enters service. ICAO, Australia, and China use this date as their regulatory trigger, not the TC date. The most important date for most operators using this checklist.
Aircraft Registration
The administrative record of which country your aircraft belongs to, reflected in its registration marks (N- for the U.S., G- for the UK, etc.). Determines which country's regulations govern your aircraft. This is what Steps 1 and 2 are asking about.
Step 1
Is your aircraft registered in the U.S. or Canada?
Yes
You may use Halon 1211. The FAA and Transport Canada accept UL/ULC-listed Halon 1211 extinguishers with no restrictions. UL reaffirmed its listing in November 2024.
No
Go to Step 2.
Step 2
Is your aircraft registered in the EU or UK?
Yes
Halon 1211 is not permitted. Under EU Regulation 2024/590, portable Halon extinguishers were required to be removed from cabin and crew compartments by December 31, 2025. The only approved replacement is 2-BTP (Halotron BrX). HCFC Blend B (Halotron 1) is also prohibited. Contact H3R Aviation for replacement options.
No
Go to Step 3.
Flying a non-EU registered aircraft into Europe? You are not required to carry a Halon-free extinguisher. Your aircraft registration, not your route, determines which country's regulations apply. However, if your extinguisher needs servicing while in Europe, it will likely not be possible, which could leave you without a compliant extinguisher for the return flight. Operators making regular transatlantic trips should consider Halotron BrX, which satisfies both FAA and EASA requirements.
Step 3
Is your aircraft registered in Australia, China, or Brazil?
Australia
Halon is permitted if your aircraft's individual certificate of airworthiness was first issued before December 31, 2018. Prohibited on aircraft first certificated on or after that date. Australia has enacted the ICAO forward-fit standard through CASR 90.150 and AWB 26-002.
China
Halon is permitted if your aircraft's individual certificate of airworthiness was first issued before December 31, 2018. Replacement required for aircraft first certificated after November 25, 2021. China implemented the ICAO standard through a CAAC airworthiness directive.
Brazil
Halon is permitted on aircraft with a type certificate issued before May 18, 2019. Almost every major transport category aircraft type in service today, including the Boeing 737 family, Airbus A320 family, Embraer E-jets, ATR turboprops, and Cessna, Piper, and Beechcraft piston aircraft, received their original type certificates well before 2019. Confirm with ANAC for aircraft certified after that date.
Other
Go to Step 4.
Step 4
Has your country adopted the ICAO Halon replacement standard into domestic law?
The ICAO Annex 6 standard requires Halon alternatives on aircraft whose airworthiness certificate was first issued on or after December 31, 2018, but only in countries that have enacted this standard into domestic regulation. ICAO membership alone does not make it law. To find out, contact your national civil aviation authority or check whether your country has filed a difference with ICAO on Annex 6.
No
You may use Halon 1211 regardless of when your aircraft was produced. Confirm with your national civil aviation authority that no domestic restriction applies.
Yes
If your aircraft's certificate of airworthiness was first issued before December 31, 2018, you may use Halon 1211. If first issued on or after that date, a Halon replacement is required. Confirm the applicable regulation with your national civil aviation authority.
?
Not sure? Contact your national civil aviation authority directly, or contact H3R Aviation and we can help point you in the right direction.
This checklist is provided for general guidance only. Regulations vary by jurisdiction and are subject to change. Always verify current requirements with your national civil aviation authority before purchasing or installing a fire extinguisher. H3R Aviation, Inc. makes no representation as to the completeness or current accuracy of information regarding regulatory requirements outside the United States. For the full country-by-country breakdown, see the country and region reference table.
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.
