The EU commission has revised two guidance documents that provide clarification to the scope of the EU toy safety directive.

SAFEGUARDS | Toys and Juvenile Products NO. 042/19


The EU Commission has published two revised guidance documents:


Guidance Document on Musical instruments

The guidance document clarifies the grey area between toy musical instruments and actual musical instruments. The guidance document provides additional justification clarifying why and how certain toys can be classified. Another major change in the guidance document concerns maracas.


Different types of maracas-like products are discussed and clarified:

  • Toy rattles that may have a maracas shape

  • Toy maracas that are intended to be used as toy musical instruments

  • Real musical instruments

More details can be found in the guidance document [1]. 

Guidance Document on Pools

The guidance clarifies the grey area between toy pools and pools intended for leisure. Toy pools should have additional play value and it is clarified which additional features would be considered as adding play value. This could be additional animal shaped inflatables, slides, inflatable castles or similar.

The previous guidance discussed two categories of pool:

  • Toy paddling pools, covered by the harmonized toy standard EN 71-8, with a water depth ≤ 400mm

  • Leisure pools (not toys) with a water depth of > 400 mm

Now a new category has been introduced:

  • Toy pools with a water depth of > 400 mm

As these pools have play value they are within the scope of the toy safety directive 2008/49/EC but as EN71-8 is not applicable to these products and EC Type examination may be required.

Pools for leisure that do not have play elements and have a water depth of more than 400 mm are not toys. They are covered by the General Product Safety Directive (GPSD) 2001/95/EC.

The EU guidance refers to the following standards for reference (although they are not harmonized under the GPSD):

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

  • EN 16582 Domestic swimming pools:

    • Part 1: General requirements including safety and test methods
    • Part 2: Specific requirements including safety and test methods for inground pools

More details can be found in the guidance document [2]. 

SGS offers a wide range of services to ensure that your products comply with the EU Toy Safety Directive. We offer training, safety/risk assessment, technical documentation check, labelling review, testing according to harmonized standards, SVHC screening, inspections and audits. With the largest global network of toy experts and testing facilities around the world - around 20 toy labs worldwide including 3 EU Notified Bodies (France, Germany and Netherlands), SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Sanda Stefanovic
Toy expert
t: +31 6 51542190

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