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 defines toys as products meant for children under 14 years old to play with. According to the Guidance Document No. 8 on the Application of Directive 209/48/EC on the Safety of Toys – Pools, the directive also covers “pools for play”.

The guidance document provides examples of pools for play – for instance, pools meant for young children that have sliders or other types of toys and play elements. The document also explains that there are separate requirements for pools that have a maximum water depth of 400 mm, and pools that have a water depth that exceeds 400 mm.

Here are the main requirements for pools for play:

a. Comply with the EN 71-8 standard requirements (for pools with a maximum water depth of 400 mm)

b. Undergo an EC-type examination (for pools with water depths exceeding 400 mm)

c. Undergo relevant testing to ensure it does not pose undue risks to children

d. Come with appropriate documentation and labelling

Note that, besides EN 71-8, other parts of the EN 71 standard series may apply. For example, EN 71-1 sets mechanical and physical requirements for toys.

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

This standard sets requirements and methods to test domestic-use activity toys that are meant to carry at least one child aged under 14 years. It only covers pools with a maximum water depth of 400 mm.

It also sets requirements for accessories, components, and separately sold swing elements that can be used on or with the activity toys.

Water depth > 400 mm: EC Type Examination

The guidance document states that pools that have play elements and a water depth exceeding 400 mm are also considered toys. However, always according to the document, EN 71-8 does not cover such pools, and you should submit your product for EC-type examination.

More in general, according to Article 19 of the directive, you should submit toys for EC-type examination if relevant harmonised safety standards for the toy do not exist. Such examination must be carried out in accordance to the requirements listed in Module B of Annex II to Decision No 768/2008/EC, and together with the requirements set by Module C of Annex II to Decision No 768/2008/EC.

In this case, you need to get a notified body to carry out the 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 Product Safety Regulation applies to consumer products, which include inflatable pools that do not have “play value”. For example, according to the Toy Safety Directive Guidance Document on Pools, “pools for play” may include play elements such as animal-shaped objects.

The regulation generally requires:

a. Compliance with harmonised standards (or – in the absence of harmonised standards – non-harmonised EN standards, or national standards)

b. Proper labelling (e.g. traceability information and appropriate warnings)

c. The provision of documentation (e.g. test reports and technical documentation)

EN Standards

In general, standards that are harmonised under the regulation should be used to comply with the safety requirements set by the regulation, when they exist. We could not find any harmonised standards relevant to inflatable pools. When harmonised standards do not exist for the product in question, you should use other relevant standards to ensure that your product is safe.

We found four non-harmonised EN standards that may be relevant:

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