There are new developments in the ongoing global tariff situation—and the potential impact on the optical industry is, once again, concerningly high.
Specifically: The Vision Council (TVC) has submitted formal comments to the U.S. Department of Commerce Bureau of Industry and Security (BIS) in response to the possibility of expanded tariffs that could impact key products used by the optical industry.
Wow. Okay, so where did we last leave off with these tariffs?
Going in chronological order:
- See here for a recap of how this trade war began.
- And check out our follow-up coverage from April 2025 (which introduced reciprocal tariffs).
- Finally, click here for our most recent coverage from August 2025, when reciprocal tariffs were supposed to take effect.
Now to the latest update.
Let’s first discuss the context behind TVC’s recent comments to BIS.
These were submitted to address ongoing investigations (referred to as Section 232 national security investigations) that BIS is carrying out. Those include looking into:
- Personal protective equipment (PPE), medical consumables, and medical equipment
- Robotics and industrial machinery
Wait … remind me what Section 232 is.
Section 232 falls under the U.S. Trade Expansion Act of 1962.
What this does: Allows the U.S. president to restrict imports deemed to threaten national security.
- How: Via an investigation (such as the two aforementioned ones) conducted by BIS, with the findings and recommendations then sent to the president to decide whether or not to implement a plan that involves tariffs, quotas, or other restrictions.
Got it. So what do these investigations have to do with the optical industry?
As TVC noted, both investigations’ focuses are “broad product definitions” that could include those used by the optical industry.
For example: Spectacle lenses, frames, diagnostic instruments, and the machinery utilized to manufacture each product (just to name a few of the extensive list of products TVC noted in its submitted comments).
Speaking of those comments …
For each investigation, interested stakeholders (such as TVC) were invited to submit public comments by Oct. 17.
The significance of these comments:
- They may be taken into consideration (and possibly responded to) as an investigation is conducted
- They can help to shape an investigation’s outcome and offer clarity on specific issues
- They may be of particular interest if directly addressing criteria for determining potential national security impacts
Let’s look more closely at what TVC had to say.
For both investigations, TVC offered several reasons as to why any additional duties brought on by BIS’s findings for medical devices are “unnecessary”—particularly for those in the eyewear and optical medical device fields.
- From a public health perspective, it noted that new tariffs would raise costs for vision care devices such as eyeglasses and contact lenses—leading to limited access for essential care.
- Economically, TVC referenced existing Section 301 tariffs already in place that have added higher costs, reduced profit margins, and delayed business expansions for optical companies.
- And from a global standpoint, TVC argued that the industry’s supply chain poses no national security risks with its trade relationships involving ally countries (Italy, Germany, Mexico, and Japan included).
And TVC wasn’t the only organization to weigh in on these, right?
Definitely not. In fact, the PPE investigation saw a total of 401 submitted comments, while the robotics investigation had 256.
- Click here and here to read TVC’s full comments for both investigations.
So what was the organization’s request?
Quite simply: To exclude optical products (and other related equipment) from any potential future duties or quota resulting from the investigations.
- “Optical medical devices are not the type of importation that should trigger national security concerns,” TVC wrote.
“Eyecare is an essential element of a healthy and successful society, and any additional Section 232 duties assessed against optical medical devices or diagnostic instruments will only create an additional barrier to Americans receiving that care,” the organization added in its letter.
And when will these investigations conclude?
Good question. That’s currently up in the air.
A typical Section 232 investigation has been known to take up to 270 days to complete (after which the findings report is then sent to the president).
- See here for a look at and breakdown of all current Section 232 tariffs (and investigations) in place and ongoing.
However, as some reports noted, the current U.S. administration has indicated a potentially faster timeframe.
Lastly, what should industry and eyecare professionals keep in mind moving forward?
First and foremost: Stay informed on the latest developments in this ever-changing political landscape to better understand the exact impact these tariffs could have—including on patients and consumers.
To help with this, TVC is offering access to three resources:
- Real-time updates on tariff developments
- Industry resources and guidance (including archived webinars and country-specific tariff info)
Tariff Dashboard (exclusive to TVC members)