Qualification Statement on BEGA-US "Made in America" & "ARRA"

The question has been asked if BEGA-US Lighting Products meet the requirements for “Made in America” and the U.S. Federal requirements for “Buy American” under the specifications for purchases of equipment utilizing federal tax credit stimulus funds provided by the American Recovery and Revitalization Act of 2009 (ARRA 2009).

The answer to that question is that all BEGA-US Lighting Products fabricated, assembled, produced and shipped from our Carpinteria, California manufacturing facility do meet the required criteria to be qualified as “Made in America”; designated under the FTC “Made in America” standard, and that the provisions of the “Buy America” clause of the ARRA 2009 section and other federal procurement program provisions have been met.

1. American Recovery and Revitalization Act of 2009: Section 1605 – Buy American Section 1605 (a) of the ARRA of 2009 states that none of the funds appropriated or otherwise made available by this Act may be used for a project for the construction, alteration, maintenance, or repair of a public building or public work unless the iron, steel, and manufactured goods used in the project meet the criteria for “Made in the United States”.

2. Federal Trade Commission Country of Origin Documents: The FTC provides a complete set of documents that explain the topic of complying with the “Made in the USA” standard, as it applies to manufactured equipment. While US content must be disclosed on automobiles, textiles, wool, and fur products, there is no law that requires disclosure on most other products. A qualified “Made in the U.S.” statement evaluates and analyzes the material content of said manufactured equipment and includes statements as to the material content and country of origin.

3. The “Buy American Act” requires that a product being manufactured in the United States be more than 50 percent U.S. fabricated, assembled, materials, components and parts in order to be considered “Made in the U.S.” for government procurement purposes. More information on this topic may be found by reviewing the “Buy American Act” at 41 U.S.C. §§ 10a-10c, and the Federal Acquisition Regulations at 48 C.F.R. Part 25, and the Trade Agreements Act at 19 U.S.C. §§ 2501-2582.

4. The required material review and analysis has been completed for the totality of BEGA-US Lighting Products. We are classified as qualified “Made in America” with a minimum 51% total US content with specific products of up to 90% US content. These models meet the required 50% minimum content and can be stated as “Made in America” for government procurement purposes. Synopses of these analyses can be provided if requested.

In summary, BEGA-US Lighting Products meet the definition of “Made in the U.S.” per the FTC criteria, which therefore meets the specifications of the ARRA of 2009 requirements or with other federal procurement programs requiring “Made in the U.S.” or “Buy American” designation.