Mere commoditization

October 6, 2021
Contact lens “gray markets,” deregulation pose real concerns for our patients’ health.
Letter from AOA President Robert C. Layman, O.D.

Commoditization, in essence, is the process of taking a particular good and stripping its distinctive characteristics for the sake of making it interchangeable. As a standardized commodity, it’s a race to the lowest price point that drives competition—not product quality.

I bring up this point about market economics because it is an issue of concern that must be reckoned with in the contact lens marketplace: the risk that individual patient health and safety considerations, and the medical decision-making of doctors, are replaced by a deregulated market that prioritizes cheapest cost over healthiest choice. And when it comes to medical devices, such as contact lenses, we know that is a dicey tradeoff that our patients stand to lose.

Contact lenses are not “one-size-fits-all,” regardless of what online sellers say in flashy ads or trendy articles that target the roughly 45 million American contact-lens wearers. But even as the AOA and our proponents made this very point in over 300 Capitol Hill meetings this past May, advocating to close loopholes that online sellers commonly exploit, our opponents could not sit idly by.

Days before Virtual AOA on Capitol Hill, The Federalist published an opinion piece openly criticizing the American marketplace and asking why we couldn’t be more like Europe. In 25 of 28 European countries, the author argued, contact lenses can be procured without prescriptions from vending machines “in the same way Americans can purchase a Snickers.” Can you imagine our patients selecting “B12” for a blister pack of contact lenses and a candy bar?

These differing policies have allowed for a “gray market” whereby contact lenses move from Europe to the U.S., in turn leading to countless lawsuits and legal scrutiny. For years, the AOA has raised an alarm over these kinds of transactions, including working with Amazon.com Inc. to ensure sales do not sidestep these protections and direct outreach to these overseas companies. But it is a constant battle that requires vigilance on the part of our membership and association.

Although the AOA is not a regulatory enforcement entity, we continue to apprise companies and federal authorities of situations that put our patients in harm’s way. Because, above all, we are advocates for our patients’ health and safety. Toward that end, I ask for your continued support of the AOA and our advocates given that the topic of contact lens market deregulation is not going away any time soon.

The fight is just getting started: Deregulation only stands to bring about greater commoditization of contact lenses, ultimately deprioritizing our patients’ health and safety.



Advocate for optometry

Use the AOA Action Center to ask for your lawmaker’s support of S. 1784, the Contact Lens Prescription Verification Modernization Act.
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