NDAA Battery Compliance: Which Battery Cells Will Still Be Procurable in 2028

Defence spending is being pulled towards electrification faster than most supply chains can adapt. Drones, 6T vehicle batteries, BB-2590 packs and more all draw from the same pool of lithium-ion cells, and that pool is dominated by Chinese manufacturers or by companies with material and process exposure to China. Drones are the clearest case, with platforms routinely built around cells from Grepow, Racepow and similar suppliers. The military segment already accounts for the largest share of the drone battery market, and forecasts put drone battery growth well ahead of the wider military battery market.

That is the problem the regulation is aimed at. Section 842 exists to cut geopolitical reliance on China for critical systems and to push investment into a domestic and allied battery ecosystem, rather than to penalise any individual supplier.

Compliance is hard because defence battery volume is not one large programme. It is thousands of small packs across air, sea, ground and space platforms, plus a long tail of standardised formats that have been in service for decades. Compliance has to be proven for each product line, not signed off once at fleet level.

What NDAA battery compliance means

Section 842 of the FY2026 National Defense Authorization Act restricts Department of War procurement of advanced batteries linked to a foreign entity of concern (FEOC), meaning an entity located in or controlled by China, Russia, Iran or North Korea.

The specifics:

• What is banned - The prohibition covers advanced batteries and advanced battery cells that are owned by, sourced from, refined in, or produced by a foreign entity of concern.

• How deep it goes - It reaches component level, including cathode materials, anode materials, separators, anode foils, solvents, additives, electrolyte salts and internal safety devices.

• What it applies to - Batteries procured directly and batteries embedded within warfighting and support systems, so any platform where a battery is a substantial or critical component falls in scope.

• The exemption test - A cell qualifies only if final assembly is carried out by a non-FEOC, the product is produced without technology licensed from a FEOC, and more than 95% of costs come from non-FEOC sources.

• The carve-outs - Narrow exceptions exist for RDT&E, certain non-defence uses, and COTS acquired only for equipment maintenance, plus a one-year non-availability waiver.

A cell can be assembled outside China, by a Western-headquartered company, and still fail if the process technology behind it is licensed from a FEOC.

Who does NDAA compliance impacts

Directly, it impacts Department of War acquisition programmes. Indirectly, it impacts everyone selling into them: pack designers, propulsion integrators, and OEMs building UAVs, ground vehicles and soldier power systems.

The harder position is dual use. A company building drones for both commercial and defence customers cannot economically maintain two parallel cell qualification tracks, two sets of test data, two BMS calibrations and two supply agreements. The rational move is to minimise suppliers and standardise on one cell, which means the commercial platform inherits the defence compliance bar years before any defence contract is signed. Delay the audit and the risk lands late in development, when switching cost is highest and requalification eats the programme schedule.

When does NDAA battery compliance come in

New acquisition programmes: 1 January 2028. Standard batteries: 1 January 2029. Existing acquisition programmes: 30 January 2031.

Who is in scope to supply under NDAA battery compliance

We have been mapping the battery manufacturers that, to the best of our knowledge from direct communication with them or from public statements, are actively working towards NDAA-compliant supply chains. The map spans North America, Europe, the Middle East and Asia, which reflects the rule as written: the requirement is non-FEOC, not US-only, so allied manufacturing qualifies.

Broadly, they split by format.

• Cylindrical: the format most ground, marine and portable power platforms design around. Amprius, Rincell, ALE, Forge Nano, StoreDot, Trydan Tech, Volklec.

• Pouch: more common in new UAV systems due to higher energy density. Amprius, BEI, Enovix, Enpower, ALE, EGI Battery, CustomCells, InoBat, AdvantElec, SES, Basquevolt.

  
  

Prismatic is a gap. Defence has traditionally had little use for the format, so the compliant supply base reflects that, but as ground platforms electrify and hybrid drive systems scale, prismatic will matter. Teams working on larger ground vehicle packs should expect fewer compliant options than their aviation and UAV counterparts, at least for now.

Why cell selection becomes the bottleneck

Once the pool narrows, cell selection stops being a search for the best cell and becomes a search for the best cell that clears the bar. Physical sampling and testing across a shortlist take months per cell and burns test capacity that most teams do not have. Modelling-driven selection, using validated battery models built on real lab data, lets a design team screen the compliant pool against their actual duty cycle before committing to hardware.

That is what the Voltt does, reducing cell evaluation test cycle duration by 70%. Fully characterised, simulation-ready models across 50+ cells, with direct filters for NDAA certification at the product-level, so you can compare accessible energy, power performance and degradation behaviour under your own mission profile rather than a datasheet's.

FAQs (Frequently Asked Questions)

What is Section 842 of the NDAA?

Section 842 of the FY2026 National Defense Authorization Act restricts Department of War procurement of advanced batteries and battery cells connected to a foreign entity of concern, covering ownership, sourcing, refining, production and licensed technology.

When does NDAA battery compliance take effect?

New acquisition programmes must comply from 1 January 2028, standard batteries from 1 January 2029, and existing acquisition programmes from 30 January 2031.

What is a foreign entity of concern?

An entity located in, owned by, or subject to the control of China, Russia, Iran or North Korea.

Does the 95% rule apply to materials or costs?

Costs. A battery qualifies for the exemption where final assembly is by a non-FEOC, no FEOC-licensed technology is used, and more than 95% of costs come from non-FEOC sources.

Does NDAA compliance mean the cell has to be made in the USA?

No. The requirement is non-FEOC, so manufacturers in the UK, EU, Japan, South Korea, India and Israel can qualify provided the material and licensing conditions are met.

Does Section 842 apply to commercial drones?

Not directly, but it applies to any defence system where a battery is a substantial or critical component. Dual-use manufacturers selling into both markets are usually better off qualifying a single compliant cell than maintaining two supply chains.

Is manufacturer-level compliance enough?

No. A manufacturer can be non-FEOC while its cathode active material, graphite, electrolyte salts or process licensing sit inside scope. The audit must reach material and IP level.