ALA's Response to the Request for Comments on the USMCA Implementation and Operation

OFFICE OF THE UNITED STATES TRADE REPRESENTATIVE 

Request for Public Comments and Notice of Public Hearing Relating to the Operation of the Agreement 
Between the United States of America, the United Mexican States, and Canada

Review of the USMCA Implementation and Operation

Comments Submitted by Jon Melchi, President & CEO, American Lighting Association

The lighting industry in North America is intimately integrated across the U.S., Canada and Mexico. The 
USMCA has created meaningful benefits for our sector through duty-free access for qualifying goods, 
streamlined supply-chain flows, and better alignment of regulations across borders. 
 

Many lighting components (LED modules, drivers, power supplies, optics, housings, controls) are 
manufactured or assembled in multiple locations in North America, Mexico and Canada. Cross-border 
trade is essential for cost-efficient manufacturing: sourcing, assembly, and final distribution. Recent tariff 
and trade-compliance uncertainties highlight the importance of the USMCA framework. For our industry, 
ensuring that goods legitimately qualify as “originating” under USMCA rules is critical to preserve dutyfree access and avoid cost disadvantages relative to non-USMCA sources. The USMCA review should 
consider mechanisms to simplify or harmonize certification for manufacturing-intensive sectors like 
lighting, to lower the compliance burden while preserving the integrity of origin rules.
 

The lighting industry has been significantly affected by new tariff measures imposed by the United States 
on imports from Canada and Mexico this year. These developments have increased uncertainty and 
disrupted business operations across the lighting supply chain. The whiplash caused by increased tariffs, 
followed by pauses with multiple suggestions from the administration for additional tariffs on Canada 
and Mexico make it difficult for our members to properly plan and set prices. For lighting manufacturers, 
revising prices is a complex task. Instead of applying a uniform percentage change, tariff-driven cost 
updates demand an in-depth reconfiguration of ERP systems like SAP and Oracle. These modifications 
influence production expenses, distribution networks, and pricing structures, turning what might seem 
like a simple adjustment into a time-consuming operational challenge. Currently, the lighting sector 
remains in a state of uncertainty, awaiting clearer signals on U.S. trade policy. The current “pause” offers 
short-term breathing room but does not provide price predictability nor does it remove the possibility of
additional supply chain interruptions. Predictability in trade policy is essential for our members. 
 

From the perspective of our association, we also have Canadian manufacturers and Canadian-based 
members who are directly impacted by these tariffs. Some Canadian lighting firms supply finished 
luminaires and fixtures into the U.S. market and now face higher duties or disruption when U.S. buyers 
adjust sourcing or delay purchases. These Canadian-member companies supply to other member-firms 
(including U.S. showrooms and U.S. lighting manufacturers) and the ripple effects of tariff cost increases, 
logistic complications, and pricing resets are being felt across the membership. The unpredictability of tariffs has caused both U.S. and Canadian firms to delay new capital investments, facility expansions, and 
cross-border development plans.
 

Given this context, it is critical that the USMCA review process take into account how tariff roll-backs, 
clarification of qualifying goods under USMCA, and predictable trade policy are essential for the lighting 
industry, particularly because of our integrated Canada-U.S.-Mexico supply chains and Canadian member 
participation in our association.
 

To further streamline trade in the region, ALA believes it is critical that Mexico continue efforts to align 
its residential ceiling fan test procedure and energy efficiency standard with those of the United States 
and Canada. Harmonization in testing methods across North America provides significant value by 
ensuring consistency in product performance, reducing regulatory barriers, and promoting fair 
competition. Over the past several years, industry representatives have collaborated to encourage 
CONUEE to adopt the U.S. Department of Energy (DOE) test procedure and efficiency standard, which 
Canada has already implemented. To further strengthen North American cooperation, we support 
mechanisms that provide prior notice of proposed variations in testing or standards, allowing these 
issues to be reviewed through a joint USMCA government-to-government reconciliation process. ALA 
also recommends establishing common standards for the certification of testing laboratories so that 
results from regionally accredited labs are recognized across all three countries. These steps will help 
avoid unnecessary or duplicative testing and fees, reduce costs for manufacturers, and enhance the 
overall efficiency and competitiveness of the North American market. In the present USMCA Appendix 2, 
Chapter 28 contains important "good regulatory practice" provisions that allow for early identification of 
potential regulatory non-tariff trade barriers and create mechanisms and processes for early government 
to government notification, engagement and resolution of these issues. This chapter of the existing 
agreement should be preserved and actively used by the parties.
 

The lighting industry is undergoing rapid technological change including smart lighting, connected 
controls, and increased energy efficiency standards. Cross-border regulatory divergences can raise costs 
and reduce North American competitiveness. The USMCA review presents the opportunity to promote 
regulatory alignment, mutual recognition of standards, and cooperation on innovation in the 
lighting/controls domain. 
 

Our sector supports manufacturing, showroom, and distribution jobs in North America. Predictable trade 
rules under USMCA help firms justify investment in North American production rather than relocating 
elsewhere. Uncertainty caused by tariff threats or origin qualification ambiguity undermines investment 
decisions. Maintaining the USMCA preference structure and rules of origin certainty is central to 
investment and job retention in North America.
 

Finally, ALA strongly advises against the “stacking” or simultaneous application of IEEPA, Section 301, 
and Section 232 tariffs. Such overlapping measures undermine the intent of the USMCA by introducing 
excessive and redundant trade barriers while increasing costs for manufacturers and consumers alike. A coordinated, transparent, and harmonized approach to trade and testing standards will enhance North 
American competitiveness and support a stronger regional market.
 

The lighting industry is committed to strengthening North American manufacturing, innovation and 
trade. The USMCA has played a constructive role in enabling this, but as technologies evolve and global 
competition intensifies, the trade framework must evolve as well. We respectfully urge the review 
authorities to adopt the recommendations outlined in these comments so that our members can 
continue to thrive under the USMCA in the years ahead.

The American Lighting Association (ALA) is a trade association representing the lighting, ceiling fan, and 
controls industries. It serves the largest network of residential lighting manufacturers, retail showrooms, 
manufacturers’ representative, designers, and industry affiliates located throughout the United States 
and Canada, with a growing international membership presence. The residential lighting industry 
supports tens of thousands of American jobs and contributes significantly to the U.S. economy through 
design, manufacturing, distribution, and retail