Blue UAS Platform Certification Is Outrunning the Battery Compliance Infrastructure Behind It

The Blue UAS Cleared Listnow exceeds 50 platforms. The DCMA transitioncompleted December 2025, on schedule. The FCC Covered List exemption, secured January 7, 2026, removed a genuine procurement friction. The Green UAS fast-track pathway is formalized, giving qualifying platforms an accelerated route onto the cleared list. By any reasonable measure, platform-level certification for non-Chinese UAS procurement is scaling.

Section 842 of the FY 2026 NDAA imposes phased restrictions on DoD procurement of batteries containing critical minerals mined, refined, or processed by foreign entities of concern (FEOC, currently defined to include China, Russia, North Korea, and Iran). Compliance requires that no more than 5% of a battery's total cost derive from FEOC sources. The first enforcement date is January 1, 2028 for new contracts. The Voluntary Compliance Repository mandated by Section 836, due January 1, 2027, shows no publicly visible implementation groundwork: no Federal Register notice, no systems development solicitation, no designated office of primary responsibility. The interagency working group mandated by Section 837, due approximately June 16, 2026, has no published charter, no named membership, no meeting schedule. The DFARS open cases list as of May 15, 2026 shows no rulemaking case for Section 842 battery FEOC restrictions.

Platform certification has velocity. Battery compliance implementation has none that is publicly visible. A contracting officer selecting a Blue UAS-cleared platform today has a validated answer to the Section 848 question (no Chinese critical components as enumerated in FY 2020 NDAA) and no government-designated mechanism to answer the Section 842 question. Different statutes, different component scopes, different enforcement timelines, different institutional structures. The distance between these two tracks continues to grow.

What Blue UAS Certification Actually Covers

The scope boundary is worth stating precisely because it is persistently misread. DIU's own policy page is titled "FY20 NDAA Sec 848 Component Definition Guidance." Section 848 enumerates critical components as flight controllers, radios, data transmission devices, cameras, gimbals, ground control systems, and operating software. Batteries are not on that list. They have never been on that list.

Blue UAS certification assesses a platform against Section 848's component restrictions and cybersecurity criteria. The FCC's January 2026 determination confirms this scope, validating cleared platforms as compliant with "current U.S. law and regulations." As of that determination date, Section 842 battery FEOC restrictions were not yet operative. They will not be operative until January 1, 2028 at the earliest.

No DCMA policy document, Defense Acquisition University resource, or defense trade press reporting identified in a comprehensive search describes a Section 842 battery FEOC assessment as part of Blue UAS certification criteria. The same applies to the Green UAS fast-track pathway, which accelerates the platform certification process but operates within the same Section 848 and cybersecurity assessment framework. Green UAS makes it faster to get onto the cleared list. It does not expand what the cleared list certifies.

Blue UAS was designed to answer a specific question and it answers that question well. The concern is that procurement convenience is allowing platform clearance to absorb confidence that should be directed at a separate compliance regime with no operational infrastructure behind it. In the drone industry, "NDAA compliance" is shorthand for Section 848 supply chain security. That shorthand is becoming dangerous as Section 842 creates a second, distinct compliance obligation that the same shorthand does not cover.

Mandated Infrastructure, No Visible Implementation

Congress anticipated the component-level problem. The FY 2026 NDAA legislated three pieces of connective infrastructure. I have searched the Federal Register, SAM.gov, DoD acquisition announcements, GAO and CRS reporting, and defense trade press through May 19, 2026. The findings below reflect that search. If implementation is proceeding internally without public-facing output, that itself is a data point about the supply base's ability to prepare.

Section 836: Voluntary Compliance Repository. This provision directs DoD to establish by January 1, 2027 a public online repository through which vendors may voluntarily register and attest that covered products comply with specified domestic and allied sourcing requirements, including restrictions under 10 U.S.C. §§ 4863 and 4872. The repository is intended to house ownership structure, country of ownership, CAGE/DUNS numbers, and key compliance certifications, functioning as a visibility tool into subcontractors and lower-tier suppliers.

The deadline is 7.5 months away. No notice of proposed rulemaking, no systems development solicitation, no implementation guidance referencing Section 836 has surfaced. The repository was designed to give the supply base a 12-month runway before the January 2028 new-contract deadline. Without it, battery cell suppliers and critical mineral processors have no government-designated channel to register compliant sourcing against the 95% non-FEOC cost threshold that Section 842 imposes. The runway requires a runway.

Section 837: Interagency Working Group. This provision directs DoD, within 180 days of enactment (signed December 18, 2025), to establish a working group charged with developing recommendations to enhance information exchange between DoD and defense industrial base contractors regarding compliant materials, and to accelerate qualification of compliant sources.

The 180-day deadline falls approximately June 16, 2026. Twenty-eight days from today. No Federal Register charter notice has been published. No DoD press release names membership or leadership. No congressional oversight activity specifically inquiring into Sections 836–838 implementation has been identified.

The deadline has not passed. Internal constitution without a Federal Register charter notice is plausible. But the absence of a charter notice is notable for a DoD interagency body of this type, and even if the working group is constituted on deadline, the arithmetic is compressed: 19.5 months to produce recommendations, have those recommendations acted upon, and influence supplier qualification before the first Section 842 enforcement date.

DFARS Implementing Rule for Section 842. Section 842's battery FEOC restrictions require translation into contract-level obligations through updates to the DFARS, particularly 10 U.S.C. § 4872. The open DFARS cases list shows one FY 2026 NDAA provision under rulemaking: Section 1555, requiring a DARS Regulatory Control Officer. No case for Section 842. No case for Section 836. No case for Section 837.

Without a DFARS rule, no contract clause exists through which a contracting officer can flow down Section 842 obligations to a prime contractor, let alone to a battery cell subcontractor two tiers down. DFARS rulemaking cycles typically run 12–18 months from proposed rule to final rule. The January 2028 deadline is 19.5 months away. If a proposed rule appeared tomorrow, the timeline would be tight. No proposed rule has appeared.

The Skydio Illustration

Skydio is useful here because its supply chain exposure became publicly visible in a way that most Blue UAS-cleared platforms' supply chains have not. Most platforms have battery sourcing that is opaque by default. Skydio's became visible by force.

The X10D has maintained its position on the Blue UAS Cleared List for consecutive years. In March 2026, the U.S. Army ordered more than 2,500 X10D units for over $52 million, the largest single-vendor tactical small UAS order in Army history. The platform is Section 848 compliant, cybersecurity vetted, Blue UAS cleared. It is exactly the kind of procurement success the program was designed to enable.

Skydio has also publicly acknowledged the structural dependency:

In October 2024, China sanctioned Skydio in retaliation for Taiwan sales, and Dongguan Poweramp, a TDK subsidiary and Skydio's primary battery source, ceased shipments. The company rationed batteries to existing customers. As of January 2025, Skydio was working with Taiwanese suppliers through government-backed initiatives but had not settled on a new source. In April 2026, Skydio announced SkyForge, a $3.5 billion domestic manufacturing expansion that will "in some cases initiate" domestic manufacturing of crucial parts and components.

That phrasing warrants a close read. "In some cases initiate" means some critical component manufacturing does not yet exist domestically at announcement. No Skydio press release or trade press article identifies a specific non-FEOC battery cell supplier for the X10D or asserts Section 842 compliance for the platform's battery supply chain.

Trade press reporting places China's share of drone battery cell production at approximately 99%. Non-FEOC cell production at the form factors and volumes UAS platforms require is simply not available at scale. Skydio is the most visible case, and likely among the least exposed. The platforms whose battery sourcing has never been forced into public view by sanctions or supply disruptions are the ones where the gap between Blue UAS clearance and Section 842 readiness is largest and least visible.

The Decision Sequence

Map the workflow a contracting officer actually faces today, and the structural problem becomes procedural.

Step 1: Platform clearance. The officer selects from the Blue UAS Cleared List. This step functions well. The list is public, maintained by DCMA, updated regularly, and confers the FCC Covered List exemption through January 1, 2027. (Whether that exemption will be renewed, extended, or allowed to lapse is an open question with no public guidance; its expiration introduces a separate procurement friction that compounds the Section 842 gap.) The officer has confidence the platform is Section 848 compliant and cybersecurity vetted. No ambiguity here.

Step 2: Component compliance. The officer must now determine whether the platform's battery supply chain satisfies Section 842's requirement that no more than 5% of total battery cost derive from FEOC-sourced critical minerals or cell manufacturing. No government repository exists to check. No DFARS clause exists to require the prime to attest. No interagency working group has published qualification criteria or compliant-source lists. The officer is reliant on the manufacturer's voluntary disclosure, if any exists, in no standardized format, with no verification mechanism, under no legal compulsion until the enforcement date.

Step 3: Procurement authority. Even if the officer is personally satisfied on both counts, the contract itself cannot incorporate Section 842 as a binding requirement with defined compliance terms, because the implementing clause does not exist.

Timeline Convergence

Milestone	Date	Status (May 19, 2026)
Blue UAS → DCMA transition	Dec 3, 2025	Complete
Section 837 working group	~June 16, 2026	No public evidence of formation
Section 836 repository	Jan 1, 2027	No groundwork identified
FCC Blue UAS exemption expiration	Jan 1, 2027	Active; renewal status unknown
Section 842: new contracts	Jan 1, 2028	No DFARS case opened
Section 842: standard batteries	Jan 1, 2029	No DFARS case opened
Section 842: existing programs	Jan 31, 2031	No DFARS case opened

The legislative design assumed the repository would be operational 12 months before the first hard deadline. The working group would be constituted 19.5 months before enforcement. The DFARS rule would translate statutory language into contract-level obligations before contracting officers needed to apply them. Each assumption requires execution against a deadline. Blue UAS has hit every milestone on its track. The Section 842 implementation track shows no publicly visible progress on any milestone.

What This Produces

Two outcomes are plausible, and both are bad.

If the deadlines hold without implementing infrastructure, contracting officers face a procurement cliff where platforms they can clear under Blue UAS cannot be bought because the battery compliance pathway does not exist. Programs that have successfully onboarded non-Chinese drone platforms discover that those platforms are legally procurable under one statute and legally restricted under another, with no mechanism to resolve the conflict at the contract level.

If the deadlines slip through waiver authority or enforcement discretion, the restrictions become aspirational. The signal to domestic and allied battery manufacturers weakens. Investment decisions that depend on a credible enforcement timeline lose their anchor. At least one independent supply chain analyst has stated directly that no producer can currently meet the 95% non-FEOC cost requirement. That assessment describes a structural gap, one the supply base cannot close on the timeline Congress set without capital deployment at scale. And capital deploys against credible demand signals. Statutory text without implementing rules does not generate those signals.

The legislative architecture was designed to avoid both outcomes. The repository, the working group, and the DFARS rule were the connective infrastructure between platform certification and component compliance. They were the bridge between two regimes operating on different clocks, governed by different institutions, assessing different layers of the same procurement.

That bridge was designed on paper. As of today, it has not been built, staffed, qualified, or shipped. The procurement risk sits in the space where the bridge was supposed to be.