What is BABA Compliance? A Guide for Lighting Projects

In 2021, the Build America, Buy America Act (BABA) was signed into law. BABA was created as a means to guarantee that federally funded infrastructure projects utilize domestically produced products, in turn boosting domestic manufacturing, keeping American jobs stateside, and building stable U.S. supply chains.

What is BABA Compliance?

From a manufacturing standpoint, there are four primary considerations when determining whether a light fixture or retrofit kit is BABA compliant:

• Is the product a manufactured product or an iron/steel construction material?

• Does final manufacturing occur in the United States?

• Can you trace the origin of every component used in this product?

• Are more than 55% of the costs of all components manufactured in the United States?

Why is it Important to Source from a Reputable BABA Manufacturer?

Falsely stating that a product is BABA compliant can lead to a number of consequences. If a product is mistakenly stated to be BABA compliant, sold, and installed, and is later found to be out of compliance, the product may need to be removed and replaced with a compliant product. This can also lead to the contractor or recipient of the BABA funding being held financially liable for the non-compliant product and its replacement, as well as the withholding of future BABA funds.

If a manufacturer knowingly misrepresents a product as BABA compliant, civil or criminal penalties may be pursued by the EPA Office of Inspector General. Since BABA compliance is a self-certified claim, you will want to be 100% certain that you are buying from a trusted manufacturer.

How Does ESI Handle BABA Projects?

With nearly 35 years of American manufacturing experience, ESI has been building BABA-compliant products since before it was cool. Now, with dozens of BABA projects under our belt, ESI has a tested process for ensuring our BABA claims are legitimate.

Identify the Project as BABA

Once ESI has been made aware of the BABA requirements, we add a "BABA" suffix to all applicable part numbers. This does not change the BOM, manufacturing process, or any attributes of the fixture. The suffix calls out the BABA requirement so that each ESI team member has a heads-up that all boxes need to be checked.

Determine Domestic Content

As the product is entered into the system, the BABA suffix calls for every single component to be checked for Country of Origin (COO) and cost. Each component is then loaded into our internal tool, with COO and cost calculated to determine the domestic content percentage. If the number is greater than 55%, it will continue on to the quoting process.

The ESI Guarantee

Once the opportunity turns into a project, ESI provides a signed BABA compliance letter stating that each product meets or exceeds BABA compliance requirements.

How Can ESI Help You?

With our battle-tested process, ESI can walk you through the grit and grind of your BABA project, even if you don't have any BABA experience. You can trust that anything coming out of our factory that is stated to be BABA compliant will pass any scrutiny with flying colors.

Don't believe us? Come visit our factory in West St. Paul, Minnesota. We would be more than happy to take you on a tour to see our process.