The Vision Council (TVC) testified before the Office of the US Trade Representative (USTR) on May 5 during a public hearing examining Section 301 investigations into structural excess capacity across 16 economies. The hearings took place May 5 to 8 at the US International Trade Commission in Washington.
“We appreciated the opportunity to speak on behalf of our members about the real impact of tariffs on businesses and patients,” said TVC CEO Ashley Mills. “Additional duties would raise manufacturing costs, weaken US competitiveness, and make vision care less affordable for the workers and families who need it most.”
Representing TVC, Omar Elkhatib, the association’s director of government relations, urged USTR to exclude eyewear and optical products from potential tariff actions stemming from the investigation.
During the testimony, Elkhatib outlined several concerns regarding additional tariffs on optical products and components. According to TVC, tariffs on imported materials such as specialty polymers, acetate sheet, titanium alloys, and optical blanks could increase domestic manufacturing costs. The association also argued that the eyewear industry’s demand-driven supply chain differs from the overcapacity conditions the investigation is intended to address.
Additional duties, the organization said, could also place pressure on margins, affect domestic investment in innovation, and increase costs for consumers. TVC noted that eyewear products are already subject to existing Section 301 tariffs related to prior trade actions involving China.
The association further stated that prescription eyewear is classified by the US Food and Drug Administration as a Class I medical device, but does not receive the same tariff exemptions applied to some other low-risk medical products.
“The optical industry's story is distinct from the sectors at the center of this investigation,” said Elkhatib. “Prescription eyewear is a demand-driven, medically necessary product, not a commodity subject to structural overproduction. We believe we presented a compelling case for why our industry and products fall outside the scope of the excess capacity concerns.”
According to TVC, more than 70% of Americans rely on prescription eyewear. The organization said higher out-of-pocket costs could contribute to delayed vision care and potentially impact the detection and management of conditions such as glaucoma and diabetes-related eye disease.
In addition to its testimony, TVC said it continues to provide members with trade-related resources, including tariff policy updates, a tariff impact dashboard, and country-specific guidance related to duties and imports.
TVC offers resources to keep members updated on the impacts of trade and tariff policy. Learn more here.