The Toy Association™ Addresses Industry Priorities for CPSC Regulatory Reform Efforts
August 12, 2025 | The Toy Association™ submitted comments on August 11 in response to the U.S. Consumer Product Safety Commission (CPSC) Request for Information on Reducing Regulatory Burdens, outlining ways to reduce unnecessary costs and administrative hurdles while maintaining strong safety protections.
The Toy Association emphasized that toy safety remains the industry’s top priority and highlighted ASTM F963 as a globally recognized, science-based toy safety standard that has been effective for decades. The comments also identified opportunities for the CPSC to reduce regulatory burdens posed specifically by the agency’s current and proposed regulations, as well as recent changes in agency practice — without compromising safety — in three key areas:
- Improving Current Rules
- Simplify the eFiling rule by using a single product identifier, strengthening data privacy protections, and implementing a phased rollout with a disaster recovery plan.
- Narrow the scope of the Infant Support Cushions rule to exclude unrelated toys, such as playmats, and revise overly prescriptive warning label requirements.
- Expand exemptions from phthalates testing to include additional materials not likely to present phthalates, to avoid redundant testing.
- Reassessing Proposed Rules
- Withdraw unnecessary button and coin cell battery requirements imposed on toys, which already meet effective ASTM F963 protections and are expressly exempt under Reese’s Law.
- Reevaluate proposed water bead restrictions that, in effect, ban the products, and re-engage with the ASTM consensus process as the means to revise the toy standard for water beads, led by relevant data.
- Remove infant neck floats from “toy” regulation, as they are not toys by definition.
- Addressing Recent Changes in Regulatory & Enforcement Practices
- Return to a collaborative, data-driven, consensus-based standards process.
- Ensure incident data is accurate, cost-benefit analyses reflect realistic impacts, and labeling requirements are concise, factual, and scalable.
- Return to recognizing that similar but different standards can provide equivalent protection.
- Set realistic timelines for compliance to avoid supply chain disruptions.
- Follow due process in enforcement prior to issuing unilateral notices.
Click here to read the full comments.
The Toy Association will continue to keep its members updated on developments. Questions from members may be directed to The Toy Association’s Jos Huxley, senior vice president of technical affairs.