An average EU airline emits around 1kg of Halon per year. This is not really a suprise since halon is only used in real emergency cases.
Apart from safety and cost, there are also environmental arguments against most halon replacements. Most replacements are heavier... as we know even a few kilo's extra weight on an aircraft means 1000s of kg of extra fuel burn and co2 emissions per year.
The folks from DG-environment even do not want to understand that their plans on halon replacement are even countra productive for the EU climate change objectives....
It is a typical example of EU regulation for the sake of regulation. unfortunately with decreased aviation safety margins as a consequence...
All should ask their Member States and MEPs to protest and to block those ill-conceived proposals.
Regretably environment ministries are in charge and are only supposed to 'consult' their Ministries of Transport and CAAs...
As regard EASA, they have been rather silent on this issue apart from supporting the 'political' will to replace halon rather than identifying safety concerns with some of the (heavier) alternatives