From 1 January 2026, all remaining exemptions for Halon fire extinguishers in European aviation will end, and the EU Commission has confirmed that no further extensions will be granted. This puts many aircraft owners in a difficult situation since the only approved alternative "Halotron" is not available on the market in sufficient quantities. Further, airlines are competing for the few extinguishers available in the market driving up the prices to disproportionate levels somewhere between €2.000 and €4.000 for a single extinguisher.

If you are not able to source a halotron extinguisher before the end of december there is no really good solution in sight. We have however tried to outline some useful facts which can help the individual aircraft owner decide for himself the best course of action.

Aircraft below 1.200kg MTOW:

If you are flying an ELA1 aircraft (MTOW below 1.200 kg) you have more options, since a fire extinguisher is not mandatory according to EU regulation NCO.IDE.160.

This means you can legally remove the halon extinguisher from the aircraft provided it is not part of the certification of the aircraft which is the case for the majority of GA aircraft in operation. In practice you can check in the AFM if the aircraft has the fire extinguisher listed as an optional or a mandatory item. This would mean you would be flying without a fire extinguisher. You would be legal, but it is certainly not an ideal solution. To compensate for the missing installed halon extinguisher you could consider to bring a typical car fire extinguisher in your handbag. You would still be legal and a little bit better off against a fire, but certainly not ideal. All common extinguisher types have severe drawbacks when used in the confined space of an aircraft cockpit.

A CO₂ extinguisher takes away the oxygen and creates a severe risk that occupants will pass out. A powder extinguisher is severely corrosive so if used inside an aircraft the aircraft is almost certainly a total write-off. A water or foam extinguisher is far from ideal for electrical fires and could destroy your avionics.

Not even the new halotron extinguishers are advisable or healthy to use inside a small cockpit, and when deciding on the best course of action it is also worth noting that actually using an extinguisher in a cockpit is an exremely rare occurance. EASA has reviewed all inflight fire and smoke incidents involving ELA 2 aircraft in the past decade. Only three cases were recorded, two of them in hot-air balloons, and none resulted in serious injury. Cockpit fires in conventional light aircraft are extremely rare; when fires do occur, they tend to originate in the engine compartment or the brakes, where standard EN3 household extinguishers are sufficient. For lithium-battery problems, a fire-containment bag is a more appropriate safeguard than a cabin extinguisher.

Aircraft above 1.200kg MTOW:

If you are flying an aircraft over 1.200kg there is no legal way to keep operating in the new year without a fire extinguisher installed. Interestingly however, it is worth noting that keeping your Halon fire-extinguisher does not mean that your aircraft is grounded or not airworthy according to European aviation regulation. EASA has made this clear in a communication published November 6'th: "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."

How authorites would handle such a scenario could vary from country to country. As mentioned, if you are flying an ELA1 aircraft you will in most cases have the option to simply remove the fire extinguisher and be perfectly legal (but less safe).

How to equip

Should you be able to actually obtain an approved extinguisher for your aircraft it can in many cases be installed using CS-STAN in accordance with CS-SC108a or CS-SC109a for either existing or new installations. Note however, that according to these instructions the new extinguisher must satisfy ETSO-2C515 or equivalent standards which limits the options and makes it very hard to find a suitable extinguisher before the deadline. The alternative to using CS-STAN would be an STC or an approved minor modification. 

IAOPA Europe is working with EASA and the European Commission to ensure that fire extinguishers used in non-commercial Part-NCO operations can be considered non-installed equipment, which would remove the need for aviation-specific certification. Given the extremely low incidence of cockpit fires, we believe the use of Halotron-2 extinguishers should remain voluntary. IAOPA Europe will inform members immediately when new developments occur.

For more info please see these google translated links to AOPA germany:

November article

December article

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For older editions of the UK AOPA Magazine please visit the archive

With a growing list of member benefits we have now compiled a list of member benefits available to members of affiliates of IAOPA Europe.

The lists has been constantly growing with partners such as Jeppesen, TopMeteo & Safesky.

The latest addition is Foreflight where a 15 percent discount is now available.

Please check the list at www.iaopa.eu/memberbenefits

We will update the list regularly as new benefits are added

Recent developments in several European countries highlight the growing focus on cost-sharing flights — and the need for clarity in how rules are applied.

In Finland, a case is developing where the national CAA claims a pilot operating cost-sharing flights is effectively running a commercial operation because the aircraft is privately owned.

The UK has recently tightened its approach following the high-profile Sala accident, which involved an illegal charter flight. Starting in October, UK pilots conducting cost-sharing flights must ensure passengers pay an equal share of the cost. Passengers are also required to fill out a participation form, which the pilot must keep for six months — allowing investigators to confirm compliance if necessary. According to AOPA UK’s Martin Robinson, these changes are intended to make enforcement easier but will likely have limited impact on illegal charter flights due to limited oversight resources.

In Denmark, a case was previously taken to court by the CAA seeking to convict a pilot for not paying an equal share of the costs on a cost-sharing flight. The court dismissed the case, ruling correctly that EU regulations only require the pilot to pay a share, not necessarily an equal one. This ruling reinforces the principle that cost-sharing flights remain a legal way for private pilots to defray operating costs, provided they do not turn into disguised commercial operations.

One of the open questions that still causes confusion and uncertainty is what can be considered ‘direct costs’ eligible for sharing and here the discussion centers on costs for items like insurance, maintanance and hangar. If a pilot rents an aircraft the entire rent is obviously a direct cost even if part of the rent is set obviously covering these elements. If the pilot owns the aircraft himself it does not seem logical that the same elements could not be taken into account when calculating 'direct costs'. This question remains open and could have wide-reaching implications for GA pilots across Europe.

IAOPA Europe is monitoring these developments closely, as several CAAs may look to replicate the UK model or even pressure EASA to revise its rules. ‘This is another example of regulators trying to solve a problem that may not really exist — while creating new burdens for legitimate GA activity,’ Martin Robinson noted.

What is a cost-sharing flight?

Under EU Regulation (EU) No 965/2012 (Part-NCO), private pilots may share the direct costs of a flight with up to five passengers, provided the pilot also contributes to those costs. Direct costs typically include fuel, oil, landing fees, and — if applicable — aircraft rental fees. The flight must be genuinely non-commercial: the pilot cannot make a profit and cannot be ‘holding out’ by offering air transport as a service.
Cost-sharing is a vital way for private pilots to reduce flying expenses, maintain currency, and keep GA accessible. However, interpretation of what counts as ‘direct costs’ and how flights are advertised remains a point of discussion with regulators.