PA Stuffed Toy Law Takes Effect August 27: What Companies Need to Know

stock image of stuffed animalsAugust 26, 2024 | The new, Toy Association-sponsored Pennsylvania Stuffed Toy Manufacturing Act will officially go into effect August 27, 2024, marking a significant change for manufacturers of stuffed and plush toys. The Toy Association™ has been working closely with the Pennsylvania Department of Labor and Industry (PA L&I) to ensure a smooth transition and compliance for the toy industry.

The Pennsylvania Stuffed Toy Manufacturing Act lifts a decades-old ban on using recycled materials in stuffed toys manufactured and sold in Pennsylvania. This legislative victory was two years in the making, with The Toy Association team playing a crucial role throughout the lawmaking process. From gathering industry feedback to drafting legislative language that was ultimately included in the law, ongoing engagement and advocacy efforts were essential in driving the bill's passage and facilitating its implementation. Without the Association’s efforts, the outdated law would have remained in place, restricting the use of recycled materials in the state's stuffed toy market.

Here’s what companies need to know as the law is implemented:

  1. Registration Framework Updates: PA L&I has not yet completed the necessary updates to its registration framework to fully implement the new law. This delay means that while the law will technically take effect tomorrow, the mechanisms required for manufacturers to comply may not be in place immediately. Companies should stay alert for updates from PA L&I and The Toy Association and be prepared to adapt as the framework is finalized.

  2. Labeling Requirements: One of the key aspects of the new law involves updated labeling on stuffed toys, particularly the inclusion of specific language on sewn-in labels indicating the type of material used as filling. While PA L&I has prioritized finalizing this language, it has not yet been confirmed.

  3. Sample Submission: The law mandates that all manufacturers submit a retrofitted sample of their product to PA L&I for approval, similar to the existing registration process. This requirement applies to all manufacturers, emphasizing the importance of early preparation and compliance.

  4. Lab Testing Limitations: PA L&I is considering imposing limitations on the labs that can be used for testing filling materials and products. The Toy Association has strongly recommended the use of labs accredited by the Consumer Product Safety Commission (CPSC) to ensure consistency and reliability in testing.

  5. New Electronic Registration Form: To streamline the process, PA L&I will introduce a new electronic form for filing registrations. This form is designed to be more efficient and user-friendly, helping manufacturers navigate the new requirements.

The Toy Association is actively engaged with PA L&I to advocate on behalf of the industry and will continue to provide updates as more information becomes available. For further questions, contact Charlotte Hickcox, director of state government affairs at The Toy Association.