Westminster Policy News & Legislative Analysis

UK extends halon 1211 use on Defence, Loganair aircraft

Ministers have approved a narrow, time‑limited relaxation of the halon 1211 phase‑out for specified aircraft operating in Great Britain. The Ozone‑Depleting Substances (Grant of Halon Derogations) Regulations 2025 were made on 4 December, laid on 8 December and come into force on 30 December 2025. The instrument applies to England, Wales and Scotland only.

The measure grants derogations from the Annex VI row 4.2 end date for portable extinguishers used to protect cabins and crew: to 30 June 2027 for Defence aircraft listed in Schedule 1 Table 1; to 31 December 2040 for the Globemaster III (C‑17) in Schedule 1 Table 2; and to 31 December 2026 for the named Loganair aircraft in Schedule 2.

Defence platforms in scope include A400M Atlas, Chinook HC5/6/6A, Dakota Mk3F, Merlin HM2/HC4/HC4A, P‑8A Poseidon MRA1, Shadow R1 and Wildcat AH1/HMA2, with the C‑17 carrying the longest extension. For commercial operations, the derogation applies to specified Loganair ATR 72‑212A and ATR 42‑500 airframes identified by registration in the Schedule.

Under the Ozone Regulation, the general end date for halon 1211 in handheld extinguishers protecting cabins and crew is 31 December 2025. The UK instrument recognises short‑term technical and economic constraints and grants limited additional time to complete conversions on the listed fleets.

Article 13(4) of Regulation (EC) No 1005/2009 permits case‑specific derogations where no technically and economically feasible alternative is available. The Secretary of State records that this test is met and confirms consultation under Article 25D(9) in the instrument.

Because the regulation has Great Britain extent, Scottish and Welsh ministerial consent was required and obtained under Articles 25A(1) and 25B(1) of the assimilated Regulation, inserted by the 2019 EU Exit amendments.

Operators using the derogations remain bound by the Ozone‑Depleting Substances Regulations 2015. Competency, record‑keeping and enforcement provisions continue to apply; breaches can trigger enforcement notices and offences. Maintenance organisations should plan decommissioning and ensure any halon handling is undertaken by qualified personnel under that regime.

For Loganair, the 12‑month extension beyond the general 2025 end date creates a defined window to procure, certify and install halon‑free portable extinguishers across the listed ATR airframes and to arrange controlled recovery and disposal. Defence platforms largely have an 18‑month extension, while C‑17s have a long‑tail date to 31 December 2040 reflecting persistent integration constraints.

Internationally, the EU replaced Regulation 1005/2009 with Regulation (EU) 2024/590 in February 2024, restating the 31 December 2025 end date for handheld cabin extinguishers. Great Britain continues to operate the assimilated 2009 Regulation, as confirmed in the instrument’s explanatory note.

Defra indicates that no full impact assessment has been produced and that an Explanatory Memorandum accompanies the instrument on legislation.gov.uk. Operators should treat the new dates as firm operational deadlines and align procurement and certification plans accordingly.