INTERNATIONAL TRADE LAW

How to Export Toys: Safety, Licensing & Labeling

Schuyler 'Rocky' Reidel 5 min read

Exporting toys from the United States almost never requires an export license — most toys ship as EAR99 — but the shipment still has to satisfy U.S. product-safety rules and the destination country’s own toy regulations. The license question is usually the easy part; the safety, testing, and labeling requirements are where exporters get caught. This guide walks the three things that actually govern a toy export: export controls, U.S. safety law, and the rules of the country you are shipping to.

Most toys export without a license (EAR99)

Toys fall under the Export Administration Regulations (EAR), administered by the Bureau of Industry and Security (BIS), but ordinary toys are not listed on the Commerce Control List. Items that are subject to the EAR but not listed are designated EAR99, and EAR99 goods usually ship without a license to most destinations.

“Usually” is not “always.” An EAR99 toy still needs a license — or cannot ship at all — if it is going to an embargoed country (such as Cuba, Iran, North Korea, or Syria), to a restricted end user, or for a prohibited end use. Before any export, screen the buyer, consignee, and end user against the BIS Entity List and Denied Persons List and the Treasury Department’s Specially Designated Nationals (SDN) list maintained by the Office of Foreign Assets Control. Screening is the step most small exporters skip, and it is the one with the highest penalties.

U.S. safety law still follows the product

If your toys are also sold in the United States — or are imported, then re-exported — the Consumer Product Safety Improvement Act (CPSIA) sets the baseline. The CPSIA, enforced by the Consumer Product Safety Commission (CPSC), makes the ASTM F963 toy safety standard mandatory and layers on several requirements:

  • Third-party testing at a CPSC-accepted laboratory, supporting a Children’s Product Certificate that travels with the shipment.
  • A total lead content limit of 100 ppm in accessible parts of children’s products, plus restrictions on specified phthalates.
  • Tracking labels on the product and packaging so a unit can be traced to its manufacturer and production batch.
  • Small-parts and choking-hazard rules for toys intended for younger chil