China is the default source. China supplied 66.5% of US HS 9503 toy imports in 2025 and 65.5% of world toy exports in 2023, though its US share fell from 84.9% in 2018.
Is China still the default source for toys?
Yes, though it is losing share quickly. Toy manufacturing in China is the production of dolls, puzzles, models, plush, ride-on and electronic toys and similar playthings, most of them classified under HS heading 9503, and China supplied 66.5% of US imports of that heading in 2025 (US$9.77 billion of US$14.68 billion), according to UN Comtrade, the United Nations database of national customs trade statistics. That was down from 84.9% in 2018 and 76.3% in 2024.
China's world position is similar. It made 65.5% of reported world HS 9503 exports in 2023 (US$40.55 billion of US$61.9 billion). The Czech Republic was second at 5.4%, likely reflecting EU distribution hubs. That share is a sum across reporting countries, computed from the data rather than published by Comtrade, and the 2025 US data may be revised.
| China's share of US imports (Comtrade) | 2018 | 2023 | 2024 | 2025 |
|---|---|---|---|---|
| HS 9503 toys | 84.9% | 77.3% | 76.3% | 66.5% |
| HS 9505 festive, carnival and Christmas articles | 92.7% | 90.0% | 89.2% | 77.2% |
| Chapter 95 as a whole | 81.2% | 75.1% | 73.8% | 54.5% |
An HS chapter is the two-digit level of the Harmonized System; Chapter 95 covers toys, games, sports equipment and video-game consoles (9504), so its steeper fall overstates the shift for toys proper. The 2025 drop in 9503 was the largest one-year decline in the series. US toy imports from all sources also fell that year, from US$18.91 billion to US$14.68 billion, so part of the decline reflects lower total imports rather than relocation alone.
Where toys are made in China: Chenghai and Guangdong
Chenghai, a district of Shantou in eastern Guangdong, is China's best-documented toy cluster.
- Shantou has more than 50,000 toy-sector entities and is "China's most comprehensive and largest plastic toy production and trading base," according to China Daily (5 November 2024).
- Chenghai exported toys worth RMB 10.24 billion in 2024, according to China Media Group as reported by Global Times and republished by CCPIT (July 2025). The same report says Chenghai produces more than 50% of China's plastic toy output and about one-third of global supply; that claim is undated.
- From January to July 2021, toys were 56.64% of Chenghai's exports (RMB 2.738 billion), and toy enterprises above designated size had output of RMB 9.296 billion in the first three quarters of 2021, according to the Shantou government.
Dongguan is widely cited as the second major Guangdong toy cluster, associated with licensed and higher-end toys made by foreign-invested firms. No official figure for it was found.
How toy production is organized
Plastic injection molding and assembly dominates Chenghai. Other factory types include plush and stuffed toys, which are sewing-intensive; die-cast toys; wooden toys; and electronic and radio-controlled toys, which combine circuit-board assembly with molding. Licensed-character work requires factory audits by the licensor.
The minimum order quantity (MOQ, the smallest order a factory will accept) is driven by mold cost and ownership, color and pigment batches, and printed packaging runs. Plush minimums are usually set per fabric and color. No authoritative benchmark exists, so none is given here.
Lead time follows a fixed sequence: tooling, samples, third-party testing to ASTM F963 and CPSIA requirements, mass production, pre-shipment inspection and transit. Seasonality is strong, because Christmas goods in HS 9505 must ship well before the fourth quarter. One Chenghai manufacturer described lead times falling from about three months to two during the 2025 order surge; that is a single anecdote, not a benchmark.
US toy safety rules
The US Consumer Product Safety Commission (CPSC) regulates toy safety, and its rules place the legal duty on the importer. For imported goods, the importer is the "manufacturer" under the Consumer Product Safety Act.
- ASTM F963-23 became the mandatory US toy standard on 20 April 2024 by direct final rule (89 FR 3344), codified at 16 CFR part 1250. It applies by date of manufacture.
- Third-party testing and the CPC. Toys designed or intended primarily for children 12 and under must be tested by a CPSC-accepted laboratory, and the importer must issue a Children's Product Certificate (CPC) based on that testing (CPSC).
- Tracking labels are required on the product and its packaging under 15 U.S.C. 2063(a)(5).
- Lead and phthalates. CPSIA limits cover lead in paint and surface coatings (16 CFR part 1303), lead in accessible substrate (15 U.S.C. 1278a) and phthalates in children's toys and child care articles (16 CFR part 1307). The numeric limits commonly cited for these were not re-checked against the CFR for this page.
- Newer rules. CPSC issued final rules on water beads (90 FR 57820, 12 December 2025) and neck floats (90 FR 58096, 15 December 2025). A rule on toys with button or coin cell batteries was proposed on 13 August 2024 (89 FR 65791); its final status was not confirmed.
Toys for ages 13 and up are not children's products, but they still need a General Certificate of Conformity where a CPSC rule applies.
CPSC certificate eFiling from July 2026
Since 8 July 2026, certificate data for CPSC-regulated products that require certification must be filed electronically with CBP at the time of entry, under the Certificates of Compliance final rule (90 FR 1800, 8 January 2025; 16 CFR part 1110). Goods entered from a foreign trade zone follow on 8 January 2027. A technical correction (90 FR 45917, 24 September 2025) did not change those dates.
In practice this moves the CPC from a document produced on request to data that must exist before the goods are entered. A toy importer that relied on a factory's test report, or that has no CPC, now meets the problem at the border.
Tariffs on Chinese toys as of October 2026
The MFN (normal trade relations) duty on HTS 9503.00.00 is Free. As of October 2026, the main additional layer is the forced-labor Section 301 duty of 12.5% on Chinese goods, in effect since 24 July 2026. The notice's annexes contain product exceptions, and whether any toy lines are exempt was not confirmed.
The 2018 Section 301 list coverage of toys was not confirmed for this page. Many 9503 lines are commonly said to have been placed on List 4B, which was suspended in December 2019 and never imposed, but that should be checked in USTR's list search or HTSUS Chapter 99 notes before relying on it.
Two layers have ended. The Supreme Court struck down the IEEPA tariffs on 20 February 2026 in Learning Resources, Inc. v. Trump, a case whose lead plaintiff is an educational-toy company. A 10% Section 122 surcharge then ran from 24 February to 24 July 2026. IEEPA refunds are being processed: CBP had accepted about US$136.6 billion in potential and certified refunds and refunded about US$126 billion, with interest, as of 2 October 2026, according to CBP figures cited by the Court of International Trade; those totals change weekly.
Where toy production is shifting
Vietnam is growing fastest, from 3.6% of US HS 9503 imports in 2018 to 13.3% in 2025. Mexico supplied 8.5% and Indonesia 3.5% in 2025. In festive goods (9505), Cambodia reached 8.3%. China is still five times Vietnam's size in US toy imports.
Moving production changes the tariff only if origin changes. A toy substantially transformed in Vietnam is Vietnamese origin; parts molded in China and only packed in Vietnam are not. CBP decides origin, and it can issue rulings. No toy-specific AD/CVD order was found. The forced-labor Section 301 duty applies 12.5% to Vietnam as well as China, which narrows the tariff gap between them.
Common mistakes and how to evaluate a toy factory
- Relying on the factory's test report. The importer issues the CPC and is legally responsible for it, and the test must come from a CPSC-accepted lab.
- Labeling a toy "14+" or "collectible" to avoid children's-product testing. CPSC looks at design, marketing and packaging, not just the age label.
- Testing to an old F963 edition. F963-23 applies to toys manufactured since 20 April 2024.
- Forgetting tracking labels on both the product and its packaging.
- Ignoring other markets. The EU and UK run separate toy safety regimes; their 2025–2026 status was not verified here.
In evaluating a toy factory, confirm who owns the molds, which CPSC-accepted lab will test production samples, whether the factory can apply tracking labels to both product and carton, and whether it has passed the licensor audits that licensed products require.
Frequently asked questions
What percentage of toys are made in China?
About two-thirds by both main measures. China made 65.5% of reported world toy exports (HS 9503) in 2023 and supplied 66.5% of US toy imports in 2025, according to UN Comtrade. Its US share has fallen from 84.9% in 2018, and Vietnam rose to 13.3% over the same period.
Where is China's toy capital?
Chenghai district in Shantou, Guangdong, is the most cited. China Daily reported in November 2024 that Shantou has more than 50,000 toy-sector entities, and Chenghai exported toys worth RMB 10.24 billion in 2024, according to a July 2025 report republished by CCPIT. Dongguan is the other major Guangdong cluster, though no official figure was found.
Which ASTM F963 version applies to toys sold in the US?
ASTM F963-23 applies. CPSC made it the mandatory US toy safety standard by direct final rule, effective 20 April 2024 (89 FR 3344), codified at 16 CFR part 1250. It applies by date of manufacture, so toys manufactured on or after that date must meet the 2023 edition rather than an older one.
Do I need third-party testing for toys from China?
Yes, for toys designed or intended primarily for children 12 and under. Testing must be done by a CPSC-accepted laboratory, and the importer must issue a Children's Product Certificate based on it. For imported goods the importer counts as the manufacturer, so a factory's own report does not transfer the obligation.
What is CPSC eFiling and when does it start?
CPSC eFiling is the electronic filing of certificate data with CBP at the time of entry. It became mandatory on 8 July 2026 for most imports of CPSC-regulated products that require certification, and applies from 8 January 2027 to goods entered from a foreign trade zone, under the Certificates of Compliance rule (90 FR 1800).
What tariff is on Chinese toys now?
As of October 2026, the MFN duty on HTS 9503.00.00 is Free, and a 12.5% forced-labor Section 301 duty applies to Chinese goods from 24 July 2026, subject to annex exceptions. IEEPA tariffs ended in February 2026. Whether 2018 Section 301 list duties apply to specific toy lines was not confirmed, so check each line.
Sources
- United Nations Statistics Division (UN Comtrade) — UN Comtrade database, HS 9503, US imports 2018-2025 and all-reporter exports 2023
- U.S. Consumer Product Safety Commission — Safety Standard Mandating ASTM F963 for Toys, Direct Final Rule, 89 FR 3344 (16 CFR part 1250)
- U.S. Consumer Product Safety Commission — Certificates of Compliance, Final Rule, 90 FR 1800 (16 CFR part 1110); correction 90 FR 45917
- U.S. Court of International Trade — Freestyle World, Inc. v. CBP, Slip Op. 26-123 (CIT Oct. 8, 2026)
- comtradeapi.un.org/public/v1/preview/C/A/HS?period=2023&partnerCode=0&cmdCod…
- epaper.chinadaily.com.cn/a/202411/05/WS67296697a3105c25b38ed7df.html
- english.shantou.gov.cn/english/news/content/post_2002486.html
- cpsc.gov/Business--Manufacturing/Business-Education/Toy-Safety