Toy Association Submits Comments to USTR on Foreign Trade Barriers Impacting Toys

November 2, 2020 | The Toy Association, on behalf of its members, last week 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. (View the 2020 report.)

In summary, The Toy Association described the U.S. toy industry’s significant economic impact and commitment to producing safe toys, and the significance of aligning international toy safety standards and conformity assessment requirements in order to: promote toy safety and ensure compliance across all markets; reduce compliance costs, as well as costs associated with manufacturing, administration, and testing; and ultimately reduce product prices for consumers while offering them greater product availability and choice.

“Unfortunately, technical trade barriers have been used as a means of restricting imports by many governments. In some cases, these requirements have only a tenuous connection to safety, while in other cases, well-intentioned measures are unduly onerous without a corresponding safety benefit,” noted Steve Pasierb, president & CEO, in The Toy Association’s comments.

“The toy industry is committed to working with legislators and regulators in the U.S. and globally to reduce barriers to trade and to achieve the international alignment and harmonization of risk-based standards that will provide a high level of confidence that toys from any source can be trusted as safe for use by children.”

The Toy Association’s comments included a summary of some actions by international governments, which 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. The comments also note certain tariff barriers to trade facing the toy industry, including India’s recent tripling of its duty on toys to 60 percent, as well as ongoing efforts to reduce Brazil’s long-standing 35 percent tariff on toys.  

The Toy Association works year-round with contacts at 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 forecasted 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 Alan Kaufman.