Second, each club will be permitted to sign a maximum of two Practice Squad players who have earned no more than two accrued seasons of free agency credit. Absent this exception, a player who has earned one or more accrued seasons would not be eligible for a Practice Squad unless the player spent fewer than nine games on a club’s 46-player active list in each of his accrued seasons.
It's a tad unclear as I'm reading it but while this is Tolzien's fourth year he was on the Packers active roster the final 8 games, which are the only games he's ever been active. On the one hand he seems to have too many accrued seasons but on the other he has never been active more than 8 games in any season...

It does read like he'd be PS-eligible but that article summation/interpretation from ESPN may not be worded quite properly...