The Vision Council (TVC) announced it has submitted formal comments to the U.S. Department of Commerce in response to two ongoing Section 232 national security investigations that could result in new tariffs on products used throughout the optical industry.
The investigations—covering personal protective equipment, medical consumables and equipment (Docket No. BIS-2025-0258), and robotics and industrial machinery (Docket No. BIS-2025-0257)—include broad product categories that may encompass spectacle lenses, frames, diagnostic instruments, and manufacturing machinery essential to the vision care industry.
In its submissions, TVC cautioned that imposing additional tariffs on these items could raise costs across the optical supply chain, ultimately reducing access to affordable vision care. The organization urged the department to exclude optical devices and related manufacturing equipment from any new trade measures, citing their critical role in public health.
“Affordable access to corrective eyewear is a public health necessity,” says TVC CEO Ashley Mills. “Additional duties on optical devices or equipment will make it harder for Americans to access the care they need.”
The comments emphasized that optical medical devices—including eyeglasses, contact lenses, and low vision aids—are among the most commonly used medical devices in the U.S., with more than 61% of Americans relying on prescription eyewear. TVC noted that further tariff increases could disproportionately impact children, veterans, and underserved populations.
The organization also highlighted existing trade pressures from Section 301 tariffs and other duties, which have already led to increased costs and supply chain disruptions for optical companies. TVC argued that the industry’s supply chains—which rely on trusted partners such as Italy, Germany, Japan, and Mexico—serve consumer health needs and pose no national security risks.
As part of its recommendations, TVC submitted detailed Harmonized Tariff Schedule code lists identifying optical devices and manufacturing equipment that should be exempt from any Section 232 actions and called for a transparent product exclusion process.
“Our mission is to ensure policymakers understand that optical products are health tools, not security threats,” says Omar Elkhatib, senior manager of government relations. “Tariff relief is essential to maintaining affordable, high-quality vision care for millions of Americans.”
TVC’s government and regulatory affairs team continues to advocate on Capitol Hill for tariff relief and trade policies that support affordable, high-quality vision care.