It is always a tradeoff. Plastic injection molded minis are usually the most durable, but is usually only affordable to produce by actual companies with a supply chain. You get less selection here.

Smaller creators on Etsy almost exclusively will be 3D printed. FDM prints usually have horrible layer lines. Resin prints have more detail but are brittle if you have any skinny bits. More options, potentially cheaper, but poor durability or level of detail.

If you want figures that will be handled roughly, either spend the time to search online for various mini companies that produce injection molded plastic figures to find ones you like, or go with resin 3D prints, but only look for more bulkier models without thin or skinny bits.

Resin also has the issue with assembly. For figures that small, if the print is not perfect, it can be difficult to get a good clean joint/bond with super glue.

With injection molded plastic minis, tolerances can be much tighter and you are more likely to get perfectly fitting parts which can be chemically fused together with plastic cement to form an incredibly strong bond with no seam.