Tony PopeBusiness
Broker

Sector guide · Toy, gift & hobby retail

Inventory, and what it is genuinely worth

This is where toy businesses come unstuck. Slow moving and dead stock carried at cost is not worth cost, and every experienced buyer knows.

Nothing on this page is legal, financial or taxation advice. Free confidential appraisal, no cost and no obligation. Last updated 15 September 2026.

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This is where toy businesses come unstuck. Slow moving and dead stock carried at cost is not worth cost, and every experienced buyer knows it. Discontinued lines, damaged packaging, ranges that did not land, seasonal stock from two Christmases ago.

Go in with ageing analysis by line, sell through rates, and an honest write down position already taken. It feels like handing money back. It is the opposite. A buyer who finds your inventory position is realistic starts trusting every other number you have given them. A buyer who finds a hundred thousand dollars of unsaleable stock valued at cost starts questioning the whole set of accounts.

The button and coin battery regime: four instruments, one commencement date

Instrument and register IDWhat it requires
Consumer Goods (Products Containing Button/Coin Batteries) Safety Standard 2020
F2020L01656
Battery compartments in consumer goods must be secure and child-resistant. Batteries must not release during reasonably foreseeable use or misuse. Screw-secured compartments must use captive fasteners. Suppliers must hold compliance testing against the applicable standards.
Consumer Goods (Products Containing Button/Coin Batteries) Information Standard 2020
F2020L01657
Warnings on packaging and in instructions for goods containing the batteries. Alert words, safety symbols, chemistry-specific hazard statements, and instructions to seek immediate medical advice.
Consumer Goods (Button/Coin Batteries) Safety Standard 2020
F2020L01658
Child-resistant packaging for lithium button batteries of all sizes, and for non-lithium button batteries 16 mm in diameter or larger. Blister packs must release one battery at a time. Compliance testing required.
Consumer Goods (Button/Coin Batteries) Information Standard 2020
F2020L01659
Packaging warnings with alert words, safety symbols and chemistry-specific hazard language. Lithium batteries 20 mm in diameter or larger must carry a keep out of reach of children symbol at least 6 mm in size.
WHY THIS ONE MATTERS MOST

The $14 million case was against a retailer, not an importer

On 22 December 2025 the Federal Court ordered City Beach, trading through Fewstone Pty Ltd, to pay $14 million in penalties for supplying non-compliant button battery products. The products included toys, digital notepads, keyrings, lights and light-up Jibbitz accessories for Crocs. The Court found more than 54,000 occasions of breaching the button battery safety standard and more than 56,000 occasions of breaching the information standard, and referred to pervasive failures to inform itself of its obligations.

Read that finding carefully, because it is the reason this section exists. The penalty was not imposed on the overseas maker or the wholesaler. It was imposed on the business at the till. Supplier under the Australian Consumer Law covers manufacturers, importers, wholesalers and retailers, and a retailer cannot discharge the obligation by relying on assurances from the party who sold it the stock.

Smaller failures are enforced too. On 6 May 2025 Hungry Jack’s paid $150,240 across eight infringement notices for allegedly breaching the button battery information standard. A Garfield toy supplied with children’s meals between 20 and 30 May 2024, 27,850 units nationally, met the safety standard but did not tell consumers it contained button batteries or carry the required warnings. The product was safe. The packaging was not compliant. That distinction is worth understanding before a buyer’s lawyer explains it to you.

Current maximum pecuniary penalties per contravention, as listed by the ACCC for conduct on or after 28 March 2026, are for a corporation the greater of $100,000,000, three times the value of the reasonably attributable benefit, or 30 per cent of adjusted turnover during the breach turnover period. The ACCC lists $2,500,000 for an individual. The increase came through the Treasury Laws Amendment (Doubling Penalties for ACCC Enforcement) Act 2026, No. 19 of 2026, assented 27 March 2026. For earlier conduct, the maximum that applied at the time governs. Infringement notice amounts are $218,400 for a listed corporation, $21,840 for another corporation and $4,368 for an individual, reflecting the penalty unit value of $364 from 1 July 2026.

WHAT TO BUILD

The compliance folder that turns an exposure into an asset

Start with a list of every SKU in the range that contains a button or coin battery, and every SKU that is a loose button or coin battery. In a business carrying thousands of lines this is genuinely hard work, and it is exactly the work a buyer will not do on trust. Light-up accessories, sound cards, novelty keyrings, craft kits and remote controls all belong on that list alongside the obvious electronic toys.

Against each SKU, hold two documents. A compliance test certificate against the applicable safety standard, obtained from the supplier or from your own testing. And an artwork proof showing the required warnings, alert words and safety symbols exactly as they appear on the packaging and in the instructions that ship with the product.

Then add the process evidence. How new lines are assessed before a first order is placed. Who signs off artwork. What happens when a supplier changes a component mid-production. What your incident and complaints log looks like, and how it connects to the 2 day reporting obligation under section 131 of the Australian Consumer Law.

The commercial argument for doing this is simple. A buyer pricing a stock-heavy business decides what to pay for the stock, and unverified compliance is priced as risk. A folder that answers the question in an afternoon moves the negotiation onto margin and turn, where you want it.

Ask what it is worth

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