Pool and spa chemicals

• Regulation (EU) No 528/2012 — Biocidal Products
• Regulation (EC) No 1272/2008 — CLP
• Regulation (EC) No 1907/2006 — REACH

Who has to appoint one

Anyone placing pool sanitisers and disinfectants on the EU market. These are biocidal products in product-type 2, requiring a national or Union authorisation and an active substance sourced from a supplier listed under Article 95.

Thresholds and exemptions

None. A single sanitising claim brings the product into the biocidal regime, and consumer pack sizes are not exempt.

What must appear on the label

The authorisation number, the active substance and its concentration, the product type, use instructions with dosage, first aid, CLP pictograms with signal word and hazard and precautionary statements, the UFI code, and the supplier's EU details.

Marketplace fields

Marketplaces suppress pool chemicals without a national authorisation number, and this category was among the first targeted after the biocidal rules were enforced online.

Documentation you must hold

Product authorisation per member state or a Union authorisation, evidence that the active substance supplier is Article 95 listed, efficacy data, safety data sheet, and poison centre notification with the UFI.

Standards and testing

Efficacy testing under the applicable EN standards for the claimed organisms and conditions, stability testing, and CLP classification of the mixture.

Language requirements

The full label including hazard and precautionary statements in the official language of each member state of sale.

When it applies

Authorisation before the first sale in each member state. Authorisation timelines run to years and cannot be shortened.

How long records are kept

Ten years for the documentation.

What happens if you do not comply

Immediate withdrawal, seizure and fines. Selling unauthorised biocides is treated as a serious environmental and health infringement, with criminal exposure in several member states.

Who enforces it

National biocides authorities and ECHA, plus poison centres and customs.

Where the boundary lies

No representative arrangement can substitute for a product authorisation. A pH adjuster without a biocidal claim is a chemical mixture under CLP rather than a biocide, which is a lighter route, so the claim determines the regime.

Questions we are asked

Can we sell chlorine tablets bought legally in the US?

No. The product itself must hold an EU authorisation and the active substance must come from an Article 95 listed supplier.

Is a pH minus product a biocide?

Not if it makes no disinfectant claim. It remains a CLP-classified mixture with labelling and poison centre notification duties.