Inflatable Pool Regulations in the European Union: An Overview

Inflatable pools imported or manufactured for sale in the European Union are subject to various safety standards, chemical restrictions, labelling, documentation, and testing requirements. Given the inherent risk with such products, ensuring compliance is crucial.

Further, the specific requirements that apply depend on various factors, such as the age group the pool is intended for.

In this guide, we take a closer look at the Toy Safety Directive, General Product Safety Regulation, REACH, and other EU compliance requirements relevant to inflatable pools. However, this guide does not cover requirements for pumps and other electrical components.

Toy Safety Directive

The Toy Safety Directive sets requirements for toys. According to the Guidance Document No. 8 on the Application of Directive 209/48/EC on the Safety of Toys – Pools, this includes “pools for play”, which are classified as:

a. Pools that have a maximum water depth of 400 mm, or

b. Pools that have a maximum water depth that exceeds 400 mm, but contain play elements, such as a volleyball net, or inflatable animal-shaped items.

The document also explains that the requirements are different according to the maximum water depth of the pool. Here are the key requirements for importers and manufacturers of pools that are covered by the Toy Safety Directive:

a. Ensure that the product:

• Complies with the requirements of the EN 71-8 standard (for pools with a maximum water depth of 400 mm), or
• Undergo an EC-type examination (for pools with a water depth exceeding 400 mm)

b. Ensure that the product complies with the requirements of other relevant harmonised standards. For example, EN 71-3 sets substance restrictions.

Note that harmonised standards allow you to comply with the technical requirements of the directive and should be applied whenever they are relevant to your product.

c. Ensure that the product passes the relevant lab testing

d. Prepare the required documentation (e.g. Declaration of Conformity)

e. Comply with the relevant labelling requirements

Water depth < 400 mm: EN 71-8 – Safety of toys – Part 8: Activity toys for domestic use

This standard sets requirements for domestic-use activity toys that are intended for one or more children. It covers pools that have a maximum water depth of 400 mm, when measured on their deepest point. Further, it sets requirements for accessories and components.

Water depth > 400 mm: EC Type Examination

The guidance document explains that pools that have a water depth exceeding 400 mm fall under the scope of the directive only if they have “play elements” (e.g. a volleyball net – you can find more examples in the document).

In this case, however, you cannot use the EN 71-8 standard, as it only covers pools with a water depth of up to 400 mm. Instead, you should submit your product for an EC-type examination.

Note that, in general, according to Article 19 of the directive you must submit your product for EC-type examination if there are not relevant harmonised standards, such as in this case. Furthermore, a notified body should carry out such an examination.

Documentation

Here we list the key documentation that you should provide with your product.

Title	Description
Declaration of Conformity	The directive requires manufacturers to provide a declaration of conformity that contains the items in Annex III, such as the manufacturer’s name and address, and references to harmonised standards used.
Technical documentation	The technical documentation should contain the items listed in Annex IV, such as test reports and a copy of the declaration of conformity.
User instructions	Importers and manufacturers should provide user instructions with their products. They should make sure, for instance, that they point out risks associated with the product and ways to mitigate said risks.
Test report	The directive mandates product testing and the provision of a test report with their technical documentation.

Labelling requirements

Here we list the key labelling requirements set by the directive.

Title	Description
CE marking	The directive requires the permanent affixation of the CE marking to toy products.
Product traceability	Importers and manufacturers should provide traceability information with their product, such as the toy’s batch or serial number.
Warning labels	The directive mandates the provision of relevant warnings (e.g. age limits, adult supervision, domestic use) with the product.

General Product Safety Regulation

The General Products Safety Regulation covers the safety of consumer products in general. This also includes pools that are not covered by the Toy Safety Directive, which are defined by the Toy Safety Directive’s guidance document on pools as “pools for leisure”.

Pools for leisure, always according to the Toy Safety Directive’s guidance document, are pools that have a water depth of more than 400 mm and, at the same time, do not have any play elements (such as an inflatable water cannon, for example).

The regulation generally requires you to:

a. Ensure that the product complies with harmonised standards or – in the absence of harmonised standards – non-harmonised EN standards, or national standards

b. Provide the required documentation (e.g. test reports and technical documentation)

b. Affix the required label information into your product and packaging (e.g. traceability information and appropriate warnings)

EN Standards

As also explained in the case of the Toy Safety Directive, harmonised standards should be used to comply with the safety requirements of the regulation when they exist. However, we could not find any harmonised standard for inflatable pools. In this case, you must still use other relevant standards to make sure that your product is safe.

We found the following non-harmonised standards that may be relevant to your product (the first three of which are also listed in the guidance document on pools):

We found four non-harmonised EN standards that may be relevant to your product (the first three of which are also listed in the guidance document on pools):

EN 16927 – Mini-pools – Specific requirements including safety and test methods for mini-pools

EN 16582-1 – Domestic swimming pools – Part 1: General requirements including safety and test methods

EN 16582-2 – Domestic swimming pools – Part 2: Specific requirements including safety and test methods for inground pools

EN 16582-3 – Domestic swimming pools – Part 3: Specific requirements including safety and test methods for aboveground pools.

Note that other standards may also exist.

Documentation

Here we list the regulation’s documentation requirements.

Title	Description
Technical documentation	The regulation requires manufacturers to provide technical documentation with their product containing the items specified in Article 9(2), such as risk analyses and relevant EN standards applied.
Instructions	Importers and manufacturers should ensure that their products come with clear instructions.
Test reports	The regulation mandates importers and manufacturers to get their products tested and provide the subsequent test report with their technical documentation.

Labelling

Here we list the regulation’s labelling requirements. Note that you should place the labelling information on the product itself, or its packaging or an accompanying document. The latter could potentially include user instructions.

Title	Description
Traceability information	Product type, batch, or serial number Manufacturer name or registered trade mark Manufacturer postal address Manufacturer electronic address
Warnings	Manufacturers should provide warnings regarding the product’s usage, disposal, and age-suitability for children (if applicable).

REACH Regulation

The REACH Regulation restricts substances in consumer products. This includes substances found in the materials used to manufacture inflatable pools, such as PVC, rubber, and silicone. In short, pools containing amounts of substances above the set limits are non-compliant.

Annex XVII

Annex XVII sets restrictions on substances that may exist in inflatable pools. We list here some examples of those substances:

a. Phthalates (e.g. DEHP) – restricted to 0.1% by weight

b. Lead – restricted to 0.1% by weight in PVC, and other materials

c. Cadmium – Should not be used in PVC, polyurethane and other materials

SVHC Candidate List

The Substances of Very High Concern (SVHCs) Candidate List contains substances harmful to human health and the environment. You need to inform ECHA via the SCIP database if your product contains more than 0.1% of an SVHC. Here we have some examples of substances that may be found in inflatable pools:

• Bumetrizole – can be found in coatings
• Melamine – can be found in plastic coverings

Persistent Organic Pollutants (POPs) Regulation

The Persistent Organic Pollutants (POPs) Regulation sets restrictions on POPs, including POPs used in consumer products. ECHA defines POPs as organic substances that:

• Remain, and accumulate, in the environment and living creatures
• Harm human health and the environment
• Can be transported around the world in a variety of ways

The materials used to manufacture inflatable pools, such as plastic, may contain restricted substances, such as:

• Alkanes (e.g. used as secondary plasticisers in PVC)
• PFOA

You should get your product tested to ensure it is safe and does not contain banned substances or restricted substances over the limits.

Lab Testing

Some regulations, such as the Toy Safety Directive, require product testing and the subsequent provision of test reports. Other regulations, such as the POPs Regulation, do not specifically mandate testing, but you should still get your product tested to ensure product safety and compliance. Either way, if your product passes the tests, the laboratory issues you a test report that indicates your product complies with the relevant requirements.

Regulation	Lab testing
Toy Safety Directive	Toys should generally undergo testing against the requirements set by the EN 71 standard series. This includes EN 71-8, which set requirements that are specific to swimming pools, EN 71-1, which sets physical requirements, and more.
General Product Safety Regulation	The required testing will vary according to the standards that apply to the product. For example, EN 16927 sets safety requirements for mini-pools.
REACH Regulation	This regulation sets substance restrictions that you need to ensure your product complies with. You achieve this goal by getting your product tested to ensure it does not contain restricted substances over the permitted limit.
Persistent Organic Pollutants (POPs) Regulation	The POPs regulation also sets substance restrictions. You should get your inflatable pool tested to ensure it does not contain any restricted substances above the allowed limit.

Inflatable pool testing companies

Here we list some companies that claim to test toys against the requirements of EN 71-8:

• Intertek
• SGS
• Eurofins
• QIMA