The Toy Association™ recently submitted three formal comments to the Office of the U.S. Trade Representative (USTR) on several trade policy proposals and investigations. The comments were developed with member input and reinforce The Toy Association’s ongoing advocacy for tariff-free treatment of toys and trade policies that support resilient supply chains and U.S. toy businesses.

Across the filings, the Association emphasized that toys are non-sensitive consumer goods that should not be subject to broad tariff measures, and highlighted the industry's longstanding commitment to ethical sourcing, intellectual property protection, and supply chain diversification. The Toy Association is urging USTR to pursue targeted, rules-based trade solutions that avoid unnecessary costs for American families and small businesses.

US-China Board of Trade — Accommodations for Non-Sensitive Goods
On July 10, the Association submitted comments supporting USTR’s proposed “Board of Trade” mechanism designed to promote reciprocal managed trade between the U.S. and China, requesting that toys and related products be designated as non-sensitive goods eligible for duty-free treatment, noting that toys do not pose national security, critical infrastructure, or supply chain resilience concerns. Toys have historically been excluded from tariffs under the reciprocal “zero-for-zero” framework established through the 1994 Uruguay Round of the General Agreement on Tariffs and Trade (GATT), and China’s low trade barriers for imported toys under its WTO commitments further support continued tariff-free treatment. The filing also emphasized that zero tariffs on toys would lower costs for American families, strengthen U.S.-based toy companies, and support the industry's design, innovation, and compliance workforce.

Section 301 Investigation on Forced Labor
On July 6, the Association submitted comments in response to USTR's Section 301 investigation examining whether various economies have failed to prohibit the importation of goods produced with forced labor. The Association requested USTR to exempt toys and related products from any additional duties, explaining that the toy industry has already implemented extensive ethical sourcing safeguards, third-party audits, and supply chain oversight programs to address forced labor risks. The filing also encouraged USTR to continue pursuing targeted engagement with trading partners rather than broad tariff measures.

Section 301 Investigation on Vietnam Intellectual Property
On July 2, the Association submitted comments regarding USTR's Section 301 investigation into Vietnam's intellectual property practices. While reaffirming its strong support for robust global intellectual property enforcement, the Association stated that members have not identified Vietnam as a significant source of intellectual property concerns affecting the U.S. toy industry. Instead, the filing described Vietnam as an increasingly important manufacturing partner as companies continue to diversify sourcing beyond China.

The Toy Association will continue to keep members informed as the investigations move forward. Members may contact The Toy Association’s Kathrin Belliveau, chief policy officer, with any questions.