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IES Asks For Tariff Reconsideration

IES Asks For Tariff Reconsideration

In a letter to U.S. Trade Representative Robert Lighthizer, the Illuminating Engineering Society is asking that proposed tariffs on lighting components made in China be reconsidered.  The IES believes the tariffs will increase LED costs while also cutting into jobs in the United States.

Here is the full letter sent to the U.S. Trade Representative late last week:

11 May 2018

The Honorable Robert Lighthizer
United States Trade Representative
Office of the United States Trade Representative 600 17th Street NW
Washington, DC 20508

RE: Notice of Determination and Request for Public Comment Concerning Proposed Determination of Action Pursuant to Section 301: China’s Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation [Docket No. USTR‐2018‐0005]

Dear Ambassador Lighthizer,

Established in 1906, the Illuminating Engineering Society (IES) is the recognized technical and educational authority on illumination. For over one hundred years its objective has been to communicate information on all aspects of good lighting practice to its members, to the lighting community, and to consumers through a variety of programs, publications, and services. With nearly 8,000 members, the strength of the IES is its diversified membership: engineers, architects, designers, educators, students, contractors, distributors, utility personnel, manufacturers, and scientists, all contributing to the mission of the Society: to improve the lighted environment by bringing together those with lighting knowledge and by translating that knowledge into actions that benefit the public.

For the last ten years, IES members and the companies who employ them have worked tirelessly to accelerate market adoption of LED lighting solutions (i.e. designs and installations utilizing light‐emitting diode‐based lamps and luminaires). Solid‐state lighting is a true American R&D success story, having first been invented in the U.S. in the 1950s, and optimized for general illumination over the past decade. Recognizing the enormous potential of these technologies to massively reduce U.S. power consumption associated with both residential and commercial lighting, the IES and its members have coordinated with the Department of Energy’s Office of Energy Efficiency and Renewable Energy to leverage federal R&D funding that has enabled rapid improvements to the technology. Lighting experts broadly agree that the global lighting market will shift almost entirely to solid‐state lighting as a means of reducing energy consumption and meeting greenhouse gas emission reduction targets, and that this transformation is well

underway. As an ANSI accredited standards development organization, our Society has been integral to supporting this transformation through the development and implementation of standardized test procedures and technical memoranda which ensure that LED product performance information is trustworthy, comparable, and supports a competitive marketplace.

Of primary concern for the IES with regard to the proposed tariffs is the inclusion of certain electronic components that are vital to the production of solid‐state lighting goods. Specifically, these components include capacitors, resistors, controllers, light‐emitting diodes (LEDs) and other electronic and semiconductor devices commonly used in LED lighting products.

Should the proposed tariffs on the above components be enacted, the costs of solid‐state lighting goods will likely increase for consumers. In addition, our members are concerned that the proposed tariffs on components can be circumvented by simply increasing imports of processed or finished LED lighting goods not subject to these tariffs. This is in direct opposition to the intent of the Section 301 goals, and would result in further harm to our members as trade deficits increase further and threaten U.S. jobs. This would negatively impact the U.S. lighting industry, and the IES members whose work supports it. Related industries like commercial and residential construction would also be negatively impacted, and the energy efficiency sector, which currently employs more than 2 million Americans, could take a hit as energy‐efficient lighting products will become more expensive and less available for use. This will harm the ability of these related industries to expand their economic impacts. It will also negatively affect the long‐term environmental benefits and monetary savings for businesses that result from construction of more energy‐efficient buildings.

Moreover, beyond the potential direct impacts on IES members and their employers, the proposed tariffs also threaten to harm the United States’ global status as an innovation leader in emerging areas such as energy efficiency and smart technologies. For all of these reasons, the Illuminating Engineering Society respectfully requests that USTR avoid targeting goods related to energy efficient lighting products. The IES urges the Administration to evaluate the proposed 301 tariffs, consider the full scope of the potential economic harm that could impact a variety of industries across the country, and tailor the tariffs accordingly.

We thank you for the opportunity to provide these comments. If you have any questions or we can be of further assistance, please contact Alex Baker, IES Manager of Government Affairs and Public Policy, at abaker@ies.org or (202) 374 ‐ 4348. We appreciate your attention to this matter.

Sincerely,

Timothy Licitra
Executive Director
Illuminating Engineering Society tlicitra@ies.org

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