The Vision Council Urges Commerce Department to Exclude Optical Products from Potential Tariffs

The Vision Council has submitted formal comments to the US Department of Commerce opposing potential new tariffs that could affect essential optical products and equipment.

The comments respond to two ongoing Section 232 national security investigations concerning (1) personal protective equipment (PPE), medical consumables, and medical equipment (Docket No. BIS-2025-0258) and (2) robotics and industrial machinery (Docket No. BIS-2025-0257). The broad scope of these investigations could encompass spectacle lenses, frames, diagnostic instruments, and the machinery used in optical manufacturing.

In its submissions, The Vision Council cautioned that imposing additional tariffs on optical products would harm public health by increasing costs for patients and providers. The organization urged the Department to exclude optical devices and related manufacturing equipment from any new tariff actions, emphasizing that these goods support, rather than threaten, US health and economic security.

“Affordable access to corrective eyewear is a public health necessity,” said Ashley Mills, CEO of The Vision Council. “Additional duties on optical devices or equipment will make it harder for Americans to access the care they need.”

The Vision Council noted that optical medical devices—such as eyeglasses, contact lenses, and low vision aids—are among the most commonly used medical products in the country. Roughly 61% of Americans wear prescription eyeglasses, with more than 81 million pairs of lenses dispensed annually. New tariffs, the group warned, would drive up costs throughout the supply chain, limiting access to essential vision care—particularly for children, veterans, and vulnerable populations.

The organization’s filings also pointed to the negative economic impact of existing trade measures, including Section 301 tariffs and duties imposed under the International Emergency Economic Powers Act. Many optical companies, The Vision Council reported, already face higher operating costs, reduced margins, and delayed growth as a result of these policies. Furthermore, the optical industry’s supply chains—linking trusted partners in Italy, Germany, Japan, and Mexico—pose no threat to US national security, the Council said. Instead, they are dedicated to supporting consumer health and advancing vision care technologies.

The Vision Council’s comments call for a broad and transparent exclusion process for optical products and related manufacturing equipment. The submissions include detailed lists of Harmonized Tariff Schedule (HTS) codes identifying the optical devices, diagnostic tools, and machinery that should be exempt from Section 232 measures.

In addition to its Commerce Department filings, The Vision Council’s Government and Regulatory Affairs team continues to work closely with members of Congress and federal agencies to advocate for tariff relief and to underscore the impact of existing duties on the vision care industry.

“Our mission is to ensure policymakers understand that optical products are health tools, not security threats,” said Omar Elkhatib, Senior Manager of Government Relations. “Tariff relief is essential to maintaining affordable, high-quality vision care for millions of Americans.”