Differences Between BABA, BAA, and Made in America Lighting

Understanding BABA, BAA, and "Made in America": What Lighting Professionals Need to Know

For lighting professionals, the terms BABA, BAA, and Made in America are appearing more frequently in specifications and bid documents. As federal and state projects ramp up requirements for domestic sourcing, understanding these distinctions has become essential. Misinterpreting them can lead to compliance issues, costly project delays, or even being disqualified from a government contract. Here’s what you need to know, along with a closer look at the sometimes-misleading use of “Assembled in America.”

Buy America, Build America (BABA)

BABA is the newest standard, created as part of the Infrastructure Investment and Jobs Act (IIJA) of 2021 [1]. It is one of the strictest sourcing rules, requiring that construction materials, iron and steel, and manufactured products used in federally funded infrastructure projects be produced in the United States.

For manufactured products such as luminaires:

All manufacturing processes must take place in the U.S.
At least 55% of the cost of components must come from U.S.-sourced materials. [2]

This presents challenges for lighting manufacturers, since many drivers, LEDs, and electronic components originate overseas. Manufacturers like LA Lighting ensure BABA compliance by not only building their products in America, but by practicing careful supply chain management and maintaining thorough documentation.

Buy American Act (BAA)

The Buy American Act, originally passed in 1933, applies to goods purchased directly by the federal government:

The product must be manufactured in the U.S.
At least 65% of the cost of components must be domestic, with that threshold set to increase to 75% in 2029. [3]

Because BAA focuses on direct federal procurement, it applies in a narrower set of circumstances than BABA. Still, many government contracts specify BAA compliance, so it’s important for lighting specifiers and distributors to understand the distinction.

Made in America

The phrase “Made in America” is regulated by the Federal Trade Commission (FTC). To use this label, a product must be “all or virtually all” made in the United States, including its components and processing. This standard can be stricter than BAA, since it looks beyond percentages and considers whether significant foreign content exists.

While “Made in America” can be a powerful marketing tool in the lighting industry, misuse of the label can bring serious consequences, including FTC investigations and fines.

The Not-So-Gray Area: "Assembled in America"

Some manufacturers import nearly complete fixtures and perform minimal work in the U.S. They may perform minor assembly, change packaging, or add a small component, then label those products as “Assembled in America.” While the FTC allows this label if the assembly is substantial and occurs domestically, simply tightening a few screws or attaching a label does not qualify. [4]

In the lighting industry, this can be particularly misleading. A fixture that looks American-made may, in reality, rely heavily on imported components. Specifiers and contractors should be wary of products that carry “Assembled in America” or “Made in America” labels while being sold at import-level prices. Requesting documentation to confirm whether a product genuinely meets BABA, BAA, or FTC standards can help identify bad actors.

Why It Matters for Lighting Professionals

For anyone involved in specifying, sourcing, or installing lighting on government projects, clarity on these terms is critical:

BABA: Strictest requirements, tied to federally funded projects.
BAA: Federal procurement, with a 65% domestic content threshold (increasing to 75% in 2029).
Made in America: FTC-regulated, requires “all or virtually all” U.S. origin.
Assembled in America: A marketing term with looser standards, often used to suggest U.S. origin without full compliance.

As more infrastructure and government projects emphasize domestic sourcing, lighting professionals who understand these nuances will be better equipped to avoid missteps and deliver compliant solutions. Knowing the difference between BABA, BAA, and “Made in America” ensures your projects run smoothly and your products meet the right standards.