INTERNATIONAL TRADE LAW
How to Export Toys: Safety, Licensing & Labeling
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 children.
Exporting does not let you offload product the U.S. has pulled from the market. Federal law restricts exporting consumer products that have been recalled or that fail to meet an applicable mandatory safety standard; the CPSC requires advance notice before such goods leave the country and notifies the importing country’s government. Treating an overseas buyer as a dumping ground for non-compliant inventory is both a CPSC violation and a reputational risk.
The destination country sets its own rules
Clearing U.S. requirements does not clear the border on the other end. Each market enforces its own toy-safety regime, and the testing you did for the U.S. may not be accepted abroad. The common destinations break down like this:
| Market | Core toy-safety regime | Conformity marking |
|---|---|---|
| United States | ASTM F963 (mandatory under CPSIA) | Children’s Product Certificate |
| European Union | EN 71 series + Toy Safety Directive; REACH chemical limits | CE marking |
| United Kingdom | UK toy-safety rules mirroring EN 71 | UKCA marking |
| Canada | Canada Consumer Product Safety Act toy regulations | No CE/UKCA equivalent; meet CCPSA |
Build the destination’s requirements into the order before you ship. That means confirming which standard applies, whether local testing or a local representative is required, and what language and safety warnings the labeling must carry.
The export paperwork
A typical toy export needs a commercial invoice, a packing list, the correct Schedule B / HTS classification, and — for shipments over $2,500 per Schedule B number, or any shipment that requires a license — an Electronic Export Information (EEI) filing in the Automated Export System. Many buyers also ask for a certificate of origin and the product’s conformity documentation. Keep the testing records and certificates organized; they are what a foreign customs authority or distributor will ask to see.
Frequently asked questions
Do I need an export license to ship toys overseas? Usually not. Ordinary toys are EAR99 and ship without a license to most destinations. You still must screen the parties and check that the destination is not embargoed.
Does CPSIA apply if I only sell abroad? CPSIA’s mandatory standards apply to children’s products in U.S. commerce, and federal law restricts exporting recalled or non-compliant products even when they are export-only. If your toys also sell domestically, full CPSIA compliance is the baseline.
Will my U.S. safety testing be accepted in other countries? Not automatically. The EU’s EN 71 and CE marking, the UK’s UKCA, and Canada’s CCPSA are separate regimes. Confirm the destination’s requirements and arrange any additional testing before shipping.
When do I have to file EEI in AES? For exports valued over $2,500 per Schedule B number, or for any shipment that requires an export license, regardless of value.
For related export-compliance guides, see how to export medical devices and machinery export compliance, or our international trade law practice page.
Exporting a regulated product and want the rules mapped before you ship? Reidel Law Firm delivers a flat-fee Import/Export Compliance Memo covering your classification, licensing, and documentation obligations — with direct attorney access. Get a flat-fee compliance memo →
