Toy Association Advocates for Harmonized Regulatory Framework to Address Growing Number of Inconsistent State Laws
September 22, 2025 | The Toy Association™ submitted comments on September 15 in response to the U.S. Department of Justice’s Request for Information (RFI) on “State Laws Having Significant Adverse Effects on the National Economy or Significant Adverse Effects on Interstate Commerce.” The Association’s submission highlights how a patchwork of state regulations, particularly around packaging, chemical reporting, and outdated product restrictions, creates unnecessary burdens for toy companies while doing little to improve consumer safety.
Although toys are already among the most strictly regulated consumer products at the federal level, states continue to enact their own requirements. The Toy Association’s comments emphasized how these laws frequently conflict with one another, leading to higher compliance costs, reduced efficiency, and barriers to innovation for companies. Key examples include:
- Extended Producer Responsibility (EPR): Several states have enacted packaging and battery EPR laws with different definitions, reporting categories, and fee structures.
- Chemical regulations: State-by-state chemical reporting, labeling, and bans ignore existing federal standards and often require duplicative or contradictory compliance steps.
- Outdated restrictions: Ohio’s outdated stuffed toy law (Ohio Revised Code Chapter 3713), which currently prohibits the use of recycled materials in any stuffed toys manufactured or sold within the state, blocks sustainable practices and creates needless costs, despite modern safety standards that already apply nationwide.
The Toy Association emphasized that a uniform national framework would preserve strong safety protections while removing duplicative state requirements that inflate costs and cause confusion.
“Toys are already tested and certified to some of the world’s toughest safety standards under U.S. federal product safety laws and regulations,” said Kathrin Belliveau, chief policy officer at The Toy Association. “When states layer on conflicting requirements beyond federal standards, they don’t make toys safer or more sustainable and instead make them more expensive and harder to get into families’ hands. We consistently advocate for uniform standards that protect kids, support small businesses, and keep the U.S. toy market strong.”
The Toy Association will continue to work closely with federal and state policymakers to modernize outdated laws, harmonize regulatory frameworks, and advocate for policies that prioritize safety.
Members may reach out to Joan Lawrence, senior vice president of standards & regulatory affairs at The Toy Association, about questions on this topic.