Born in the USA?

When it comes to LEDs, distributors wrestle with the many definitions of “Made in the USA.”

Long before the Boss ever recorded “Born in the U.S.A.” and Paul Simon sang “American Tune,” the lighting industry was trying to get a fix on exactly what constituted a product that was “Made in the USA.” And the debate rages on.

Following, several veteran distributors discuss their understanding of and experience with the term “Made in the USA” as it relates to lighting products and how this term can come back to haunt unsuspecting channel members and end users if they don’t read the fine print.

A Confusing Term

“The term ‘Made in the USA’ is difficult to explain and easy to confuse,” confirmed Charles Dix, lighting segment manager at Cottage Grove, MN-based Werner Electric.  “There are three definitions of Made in America — ‘qualified,’ ‘unqualified,’ and ‘assembled in the USA’ — and each of these terms carry a variety of meanings that only a few really understand.  Also, many internet lighting companies advertise Made in the USA but really their products are just assembled here.”  According to Dix, “there’s enough ambiguity to allow some manufacturers to take great liberties in their advertising.”

Stephen Shepps, LC, construction solutions manager at Harrisburg, Pennsylvania-based Schaedler Yesco Distribution, agreed that the Made in the USA moniker can be perplexing.  “Manufacturers aren’t legally required to state the percentage of U.S.-made content in their product and if we ask for that percentage, many times they can’t tell us,” he said. “Only a few manufacturers seem to really be trying to use domestic content and truly be ‘Made in the USA’; those are the brands that can provide you with the necessary information to ensure that you meet job requirements.” Unfortunately, Shepps noted, “some manufacturers will take an imported product and modify it state-side to rationalize a Made in the USA designation.”

Robert “Bud” Belviso, lighting designer at the Tinton Falls, New Jersey-based Lighting Design Center at Warshauer Electric, couldn’t agree more. “Some manufacturers use the term Made in the USA, but in reality, they’re just ‘Assembled in the USA,’” he said. “I’ve seen a box labeled ‘Made in NY’ on the front side of the carton and ‘Made in China’ on the bottom of the carton.”

According to Dix, “I define ‘Made in the USA’ as a product that was substantially assembled here with a large amount of U.S.-made product included in the final product but which could still have some or a sizeable number of the components sourced from overseas. If I can visit the factory here in the U.S. and physically see American workers assembling the lighting fixture and using U.S.-made parts in that assembly, then I define that as ‘Made in the USA,’” Dix said.

Belviso concurred. “Made in the USA should mean that the majority of the lighting product material is manufactured and assembled in the USA,” he said.

At Schaedler Yesco, Shepps said that his team looks for the Made in the USA designation on manufacturers’ spec sheets and, when they can, uses actual American manufacturers with brick-and-mortar factories in the U.S. that they’ve been to. “Some of the manufacturers we use regularly are H.E. Williams, Lumax, and LSI,” Shepps said. “We’ve visited these factories, have seen them making fixtures, and know that their products are truly Made in the USA.”

A Blurry Bill of Materials

When it comes to divulging where different parts of suppliers’ lighting products are made, our experts suggest that a fair share of confusion persists throughout the industry.

“It’s not an easy question for many of our suppliers to answer,” Dix confirmed. “While our major lighting manufacturers have excellent quality control and parts sourcing, it’s the second and third-tier suppliers who simply buy end product from China that may or may not know where all of the components come from,” he said. “When pushed for information, it’s difficult to get accurate LED chip and driver information, let alone testing data.”

For Shepps, the “innocent until proven guilty” rule applies. “Unless we have first-hand experience at a plant, the honor system is in effect,” he said. “If a manufacturer labels a product as Made in the USA, we have to trust them until proven otherwise.”

“Most experienced lighting people are aware that in our world of LEDs, the majority of diodes are manufactured in China; Samsung and Cree are prime examples,” Belviso contended. “So if the rest of the product is manufactured here, I’d have to say that it’s as close to fitting the definition of Made in the USA as you can get. Most of our suppliers are up-front about where the lighting products come from.  Most decorative lighting sold in the U.S. originates from China.”

Don’t Shoot the Middleman

As it turns out, our experts confirm that only a small slice of their projects require Made in the USA products in the first place. In the upper Midwest, for instance, Dix estimates that less than 15% of public jobs require Made in the USA product and nearly all of those involve Federal or state projects. Shepps agreed that while many customers would like to use products that are “Made in the USA,” only a very small percentage of his firm’s projects – perhaps 2-3% — actually require it. “These are typically Federal projects, such as a military installation or another federally-owned building,” Shepps said, “though it’s interesting to note that not every Federal installation requires U.S.-made products.”

Still, while a ‘Made in the USA’ requirement may only affect a small number of projects, blurred lines can land distributors in big trouble.

“It’s happened to me on several government projects when the bidding documents allowed enough wiggle room for an ‘Assembled in the USA’ designation to qualify over product that was actually ‘Made in the USA,’ which resulted in losing the bid,” Dix shared. “The law should be redrafted to create a clear and understandable definition of what ‘Made in the USA’ means. It’s also the responsibility of distributors to help educate customers as best they can on the many variations of the definition and how each does or doesn’t reconcile with the wishes of a customer who wants a ‘Made in the USA’ product.”

Shepps concurred that distributors (and end-users) can get caught in the middle with respect to manufacturers’ ‘Made in the USA’ claims. “As the seller, we’re responsible for providing product that meets customer guidelines, and if a manufacturer deceives us and falsely labels product as ‘Made in the USA,’ we’re liable,” said Shepps, who believes that responsibility should lie with the source of the inaccuracy. “If the seller can prove that they were provided data stating that the product was Made in the USA,” he argued, “their liability should be removed from the equation.”

Or, as Belviso suggested, the industry could go old-school and physically spell things out to avoid confusion. “The only way to resolve issues of ‘Made in the USA,’” he confirmed, “is to have an industry standard that designates the exact criteria for a lighting product to be called ‘Made In the USA.’”