ZLEDLighting & the Buy American Act/Build America Buy America Act
At ZLEDLighting, we are committed to providing high-quality, energy-efficient LED lighting solutions that comply with U.S. government procurement requirements. Our Build Your Own line of LED lighting products meet the standards of the Buy American Act (BAA), ensuring eligibility for federal and state-funded projects.

What is the Buy American Act?
The Buy American Act (BAA) of 1933 (BAA) (41 U.S.C. §§ 8301-8305), requires federal agencies to purchase “domestic end products” and use “domestic construction materials” on covered above certain monetary thresholds (typically $10,000) performed in the United States To be considered BAA-compliant, products must be manufactured in the United States with a significant portion of components sourced domestically.

Manufactured Products: To be considered ""domestic"", manufactured products must be manufactured in the United States,and either the cost of the components, produced, or manufactured in the U.S. must be 50% of the total cost of all components, or the product is a Commercial Off-The-Shelf (COTS) item.

A COTS item is defined as:
A commercially available product (or supply) sold in substantial quantities to the general public.
Offered without significant modification for governmental use.
Examples of COTS items can include mass-produced light fixtures, wiring, and other electrical components that are regularly sold in commercial markets.

When Can You Use the COTS Exception?
Standard Commercial Products: If the light fixtures are widely sold in commercial markets without specialized government modification, they may qualify.
Manufacturing Location: The final assembly must still occur in the United States under BAA rules.
Iron & Steel Items: If the product is primarily made of iron or steel, the COTS exception may not apply.
Waivers for BABA: Specific federal agencies may provide waivers for BABA compliance if the product meets COTS conditions and other criteria.
Two conditions must be present for the Buy American Act to apply:
The procurement must be intended for public use within the United States.
The items to be procured or the materials from which they are manufactured must be present in the United States in sufficient and reasonably available commercial quantities of a satisfactory quality.

Build America Buy America Act (BABA):
Enacted as part of the Infrastructure Investment and Jobs Act (IIJA) in November 2021, BABA establishes stricter domestic content requirements for federally funded infrastructure projects. Under BABA, products used in these projects must be ""100% manufactured in the United States."" This includes categories such as iron and steel, manufactured products, and construction materials. For manufactured products like light fixtures, BABA introduces escalating domestic content thresholds:​
65% for items delivered in 2024-2028​
75% for items delivered starting in 2028 ​
These thresholds are based on the ratio of the cost of domestically sourced components to the total cost of all components, excluding the final assembly costs. Given that many LED components are produced overseas, achieving compliance with BABA's escalating thresholds can be challenging for lighting manufacturers.​

COTS Exception under the Build America, Buy America Act (BABA) BABA enforces stricter domestic manufacturing standards, requiring up to 75% domestic content by 2028. COTS Exemption Applicability: BABA does not automatically adopt the same COTS exception as BAA. However, agencies may issue specific waivers for COTS products if:

Public Interest: The exemption is in the public interest.
Non-availability: The item is not produced in sufficient quantities domestically.
Cost Concerns: Inclusion of a U.S.-made product would increase overall project costs by 25% or more.
Why Choose ZLEDLighting for BAA/BABA-Compliant Projects?
✔ BAA-Compliant LED Lighting – Our eligible products meet federal purchasing requirements.
✔ Superior Quality & Efficiency – Designed for long-lasting performance, energy savings, and sustainability.
✔ Wide Range of Applications – Ideal for government facilities, military bases, schools, and public infrastructure projects.
✔ Supports American Jobs – Purchasing BAA-compliant products contributes to U.S. manufacturing and economic growth.