In continued advocacy efforts on behalf of the toy industry to #KeepToysTariffFree, The Toy Association™ urged federal agencies to exclude toys and games from new or expanded trade measures under multiple ongoing investigations. In separate comments, the Association also raised concerns about recent changes impacting toy drones and flying toys.
Last week, the Association submitted formal comments to the U.S. International Trade Commission (USITC) and Office of the United States Trade Representative (USTR), outlining the potential economic impacts of proposed actions and calling for remedies that do not impose tariffs on toys and games. The Toy Association also provided follow-up information to the Department of Homeland Security (DHS) after an April 7 meeting on policy changes impacting children’s flying toys. Below is a summary of each filing:
Investigation into Revoking China’s Permanent Normal Trade Relations Status
On April 13, the Association submitted comments to the USITC in response to the agency’s investigation into the potential effects of revoking China’s Permanent Normal Trade Relations (PNTR) status. The Toy Association stated that revoking China’s PNTR or imposing higher tariffs would have lasting negative consequences for the U.S. toy industry, citing prior trade tensions as evidence that restrictive policies disrupt supply chains and increase costs. The Association noted that the industry’s reliance on global sourcing and large-scale production means higher tariffs would raise the cost of imported toys and components, forcing companies to increase prices, reduce investment in new products, and potentially cut jobs. The comments further state that higher prices would reduce consumer spending on toys, weakening demand and slowing growth and innovation across the industry.
Section 301 Investigation on Excess Capacity
On April 15, the Association submitted comments to USTR regarding the agency’s Section 301 investigation into structural excess capacity and production in manufacturing sectors. The Toy Association requested that toys and games be excluded from any tariff or non-tariff measures adopted under the investigation. The comments state that, even if concerns are identified in other industries, remedies should be narrowly targeted rather than broadly applied. The Association emphasized that toys and games classified under Harmonized Tariff Schedule (HTS) Chapters 95 and 34 (which sets out the tariff rates and statistical categories for all merchandise imported into the U.S.) do not present issues related to structural excess capacity, are non-strategic in nature, and would face disproportionate consumer impacts if subject to tariffs.
Section 301 Investigation on Forced Labor
Also on April 15, the Association submitted comments to USTR in response to a separate Section 301 investigation examining the failure of certain economies to prohibit the importation of goods produced with forced labor. The Association requested tariff-free treatment for toys and games, stating that any identified concerns in other industries should be addressed through targeted remedies rather than broad tariff measures. The filing notes the absence of forced labor risks in the toy industry, as well as the potential for disproportionate impacts on consumers and child safety if tariffs were applied. The Association again called for explicit accommodations for products classified under HTS Chapters 95 and 34.
Toy Drones & R/C Flying Products
In a follow-up to The Toy Association’s April 7 meeting in Washington, D.C. with DHS, the Association raised concerns about a recent rule change related to uncrewed air systems (UAS) that has unintentionally impacted children’s flying toys, including toy drones and remote-control airplanes. The Association noted that these products are simple, short-range recreational items that lack advanced features associated with national security risks, such as cameras, GPS, connectivity, or autonomous flight capabilities, and are often designed for indoor or limited-use environments. While federal agencies have historically distinguished toy drones from higher-risk UAS, the updated rule has resulted in third-party labs declining to certify these products for U.S. import, creating a bottleneck that is disrupting production timelines and seasonal sales cycles. The Association emphasized that all toys are already subject to rigorous federal safety standards and warned that continued certification delays could have significant economic consequences, particularly for small and mid-sized companies, some of which face potential closure without timely resolution.
The Toy Association will continue to keep members informed as the investigations move forward. Members may contact The Toy Association’s Maria Sierra, vice president of government affairs, with questions on the Section 301 and PNTR investigations, or Joan Lawrence, senior vice president of standards & regulatory affairs, with questions on recent rule changes for children’s flying toys.