Toy Association Advocates on Foreign Issues Impacting Toys

November 2, 2021 | The Toy Association, in collaboration with its newly formed International Committee, is continuing to make headway on global regulations, threats, and opportunities affecting the toy and play community.

Last week, the Association submitted comments to the Office of the U.S. Trade Representative (USTR) regarding foreign trade barriers impacting the U.S. toy industry’s ability to export safe toys to international markets. The feedback was provided in response to the USTR’s solicitation of public comments for the agency’s preparation of its annual National Trade Estimate Report on Foreign Trade Barriers, which is used to identify significant barriers to U.S. trade and USTR priorities for 2022. (View the 2021 report.)

The Toy Association described the U.S. toy industry’s significant economic impact and commitment to producing safe toys, and the unprecedented economic strain the pandemic and ongoing supply chain disruptions have placed on the industry.

The Toy Association summarized actions by some international governments that pose significant concern to the U.S. toy industry as technical barriers to trade. These measures are described as being inconsistent with the commitments and obligations of each country under the World Trade Organization (WTO) Agreement on Technical Barriers to Trade because they create “unnecessary obstacles to international trade” and are “more strict than necessary” while providing little or no added health or safety benefit. One trade barrier of note is India’s strict Quality Control Order for toys and 200-percent increase in tariffs on imported toys. The Association’s Comments also address additional and emerging trade barriers in the European Union, Indonesia, Mexico, Russia, Saudi Arabia, and other regions.

“Despite operating within an extremely volatile business environment, the U.S. toy industry has remained committed to ensuring the maintenance and application of strict product safety standards and regulations around the globe,” said Steve Pasierb, president & CEO, in The Toy Association’s comments to the USTR. “By reducing these barriers to trade and achieving the international alignment and harmonization of risk-based standards, we can best ensure confidence that toys sold in any market can be trusted as safe for use by children.”

The Toy Association has also developed and submitted comments regarding Brazil Ordinance 302 and made recommendations for clarifications on small parts, projectiles, toys with lasers, cords and elastics, and other sections of the ordinance. The ordinance was designed to consolidate technical regulation and conformity assessment requirements for toys, combining multiple Brazilian ordinances from recent years, and is set to take effect January 1, 2022. The Toy Association’s comments, were also shared with the U.S. Department of Commerce.

The Toy Association works year-round with the U.S. Department of Commerce and the U.S. Trade Representative’s office on trade issues that impact the toy industry. The submitted comments also forecast issues where continuing U.S. government intervention and support may be needed in the coming year.

Members with questions on this topic are invited to contact The Toy Association’s Joan Lawrence or Alan Kaufman. Members of the International Committee meet monthly, and more frequently as needed, as well as convene annually to agree on overall strategy and budgeting for international advocacy activity. Questions about The Toy Association’s international advocacy efforts and the International Committee may be directed to Ed Desmond, executive vice president of external affairs.