The Buy American Act (BAA) requires that government-funded projects use products manufactured in the U.S. with a minimum percentage of domestic components.

The Build America, Buy America (BABA) Act, established under the Infrastructure Investment and Jobs Act (IIJA), strengthens domestic manufacturing requirements by mandating that materials and components used in federally funded infrastructure projects be produced primarily in the U.S.

To comply with BAA or BABA requirements, LED linear lighting products must meet specific manufacturing and material sourcing standards. These include:

• Manufacturing Location: The final assembly must take place in the U.S.
• Component Sourcing: A significant portion (65% for BAA and 55% for BABA) of the component costs must be of USA origin and do not include labor.

Manufacturers should provide documentation or product specifications indicating compliance. When sourcing lighting products for government or infrastructure projects, always request documentation from the supplier to ensure they meet the required standards.

• Work with manufacturers that specifically label products as BAA or BABA compliant.
• Request documentation to verify compliance before purchasing.
• Coordinate with project managers to ensure all materials and components align with compliance mandates.

BAA/BABA-compliant products are available from select U.S.-based lighting manufacturers and distributors. Be sure to check with reputable brands that specialize in commercial-grade linear lighting solutions for government and infrastructure projects. Look for indicators of certification in product documentation. 

The Build America, Buy America provisions apply to all new Federal and State-funded financial assistance awards or ongoing awards that receive additional funding after May 14, 2022, that involve the construction, alteration, maintenance or repair of infrastructure in the United States.

The provisions require that all manufactured products used in an infrastructure project are manufactured in the United States. The cost of a product’s components that were mined, produced, or manufactured in the United States must also be greater than 55% of the total cost of the product’s components unless another standard for determining the minimum amount of domestic content of the manufactured product has been established under applicable law or regulation. 

For example, the concrete on a construction site would be considered a manufactured product covered by the Build America, Buy America provisions because it is incorporated into the building or public work. Similarly, a “smart” thermostat that is brought to the site for incorporation into a building would be covered by the Build America, Buy America provisions. The individual parts that go into the thermostat, however, would be considered components or subcomponents and would not be subject to the Build America, Buy America provisions. By contrast, an energy-efficient desktop computer monitor does not become a permanent fixture of the building, and therefore is not “incorporated into” the building. As a result, the monitor does not fit the definition of a “manufactured product” and is not covered by the Build America, Buy America provisions.

No. The iron, steel or manufactured goods must be produced or manufactured in the United States. A simple repackaging or a basic assembly does not pass the test of substantial transformation and satisfy the definition of “manufacturing.”

The recipient is responsible. To assist in making these determinations, the Office of Management and Budget has issued Memorandum M-22-11: Initial Implementation Guidance on Application of Buy America Preference in Federal Financial Assistance Programs for Infrastructure.

No, the Federal Trade Commission's guidelines for product marking are independent and separate from the requirements of BAA and BABA. Goods must be individually evaluated against the regulations and certified by the manufacturer that they are compliant with these programs.