---
title: "Defense"
canonical: "https://anchor.is/the-hysteresis/issue/3/defense"
publication: "The Hysteresis"
publisher: "The Hysteresis"
language: "en-US"
guide: "https://anchor.is/the-hysteresis/llms.txt"
permalink: "https://anchor.is/the-hysteresis/issue/3/defense"
issue: 3
section: "defense"
description: "Drone, UAV, UUV, and 6T battery intelligence"
authors: ["Elise Huan-Cartwright","Ronan Adike"]
published: 2026-06-29
updated: 2026-06-27
articles: 13
---

# The Hysteresis

> The Hysteresis exists to give a small cross-functional team — strategy, investment, and procurement — a shared weekly instrument for reading the battery supply chain earlier than consensus. Success means the team consistently identifies inflection points in cell pricing, supplier health, and policy enforcement weeks or months before they surface in earnings calls, annual surveys, or trade press. The commercial mechanism is internal-first: the publication proves itself as a decision tool inside the organization, then extends to paid subscribers and a practitioner community as upside. Revenue follows utility — if the team makes better-timed procurement calls and competitive assessments because of what they read here, the publication earned its place.

[Read on the website](<https://anchor.is/the-hysteresis/issue/3/defense>)

## Issue 3 — Defense

Drone, UAV, UUV, and 6T battery intelligence

### Bilateral Pressure

- [Two Lists, One Supply Chain](<https://anchor.is/the-hysteresis/issue/3/defense/article/26797/markdown>) — By [Elise Huan-Cartwright](<https://anchor.is/the-hysteresis/team/53/markdown>) · Published 2026-06-26

Two parallel enforcement actions in June made the supply chain environment around defense batteries and drones explicitly bilateral. DoD's [June 8 expansion](https://www.aljazeera.com/economy/2026/6/9/us-lists-chinas-byd-alibaba-baidu-as-chinese-military-companies) of the 1260H Chinese military companies list to 188 entities added three battery producers: BYD, CALB Group, and EVE Energy. Direct DoD contracting with all three is barred as of June 30. Indirect procurement of products containing their components is barred starting June 2027. Any defense-adjacent BOM with CALB or EVE cells now carries a compliance clock.

### Implementation Gap

- [Two Section 842 Implementation Checkpoints Have Passed. The Public Record Shows Nothing.](<https://anchor.is/the-hysteresis/issue/3/defense/article/26794/markdown>) — By [Ronan Adike](<https://anchor.is/the-hysteresis/team/74/markdown>) · Published 2026-06-26 · Format: The Mandate Gap

The DFARS revision required by June 16 and the congressional compliance-repository briefing due May 1 produced no visible public artifacts. Eighteen months remain before the January 2028 new-acquisition prohibition takes effect. Zero domestic or allied-nation suppliers are in qualification against the 95% non-FEOC cost-origin test. No contracting officer has clause language to enforce it. The statute created the prohibition. The implementing rules that would tell manufacturers, primes, and program offices what compliance actually looks like have not appeared. The qualification clock cannot start until they do.

### Blue List Evolution

- [Blue UAS Certification Does Not Reach the Battery](<https://anchor.is/the-hysteresis/issue/3/defense/article/26795/markdown>) — By [Ronan Adike](<https://anchor.is/the-hysteresis/team/74/markdown>) · Published 2026-06-26 · Format: Blue List Evolution

The DCMA Blue UAS portal lists 67 cleared platforms and 197 Framework component records. Zero of those records cover batteries, cells, or energy storage in any form. That absence traces directly to §848 of the FY2020 NDAA, which scoped its China-origin prohibition around data-handling components and left batteries outside the compliance perimeter. A platform can carry Chinese-origin cells and remain Blue UAS-cleared, because the certification never asks the question. This piece maps the gap between what EO 14307 directed, what the portal actually exposes, and what to ask when someone cites platform clearance as battery compliance evidence.

### 842 Status Board

Congress wrote three compliance clocks into Section 842. The first reads January 1, 2028. As of this week, none of the implementation machinery those clocks depend on has produced a visible public artifact.

The 180-day DFARS revision deadline passed ten days ago with nothing in the Federal Register. A congressional briefing on the §836 compliance repository was due May 1. Silent. And the repository itself, due January 2027, turns out to cover older sourcing regimes rather than the §4865 battery-specific cost-origin test. A structural gap, not a timing gap.

The operative threshold: 95% of functional cell component costs from non-FEOC sources. Suppliers publicly documented as clearing it: zero. The mandate is statute. The supply base to meet it does not yet exist in public view.

- **New acquisition battery ban: eighteen months out** — [Source](<https://uscode.house.gov/view.xhtml?edition=prelim&req=granuleid%3AUSC-prelim-title10-chapter385-subchapter2>) — Published 2026-06-26

Tag: New Acquisitions

§4865 bars FEOC-sourced functional cell components in programs that had not passed Milestone B before December 18, 2025. Scope covers cathode materials, anode materials, separators, electrolyte salts, and foils. Applies to contracts entered after enactment only. Clock reads January 1, 2028.

- **Standard battery ban including 6T: thirty months** — [Source](<https://uscode.house.gov/view.xhtml?edition=prelim&req=granuleid%3AUSC-prelim-title10-chapter385-subchapter2>) — Published 2026-06-26

Tag: Standard Batteries

§4865(e)(5) defines standard batteries as those used across multiple weapons systems without a single portfolio acquisition executive. The 6T lithium-ion battery under MIL-PRF-32565 is squarely in scope. January 1, 2029.

- **Existing programs deadline: January 30, not January 1** — [Source](<https://uscode.house.gov/view.xhtml?edition=prelim&req=granuleid%3AUSC-prelim-title10-chapter385-subchapter2>) — Published 2026-06-26

Tag: Existing Programs

§4865(b) sets January 30, 2031 for programs past Milestone B before enactment. Several law firm summaries misquote this as January 1. Pillsbury reads the statute correctly; Crowell & Moring does not. Use the statute. Fifty-five months out.

- **DFARS revision deadline passed ten days ago silently** — [Source](<https://www.federalregister.gov/api/v1/documents.json>) — Published 2026-06-26

Tag: DFARS Revision

§842(c) required DFARS revision within 180 days of enactment, putting the deadline at approximately June 16, 2026. Federal Register searches for §4865 implementation and DoD battery-FEOC rulemaking return nothing as of June 26. Internal clearance status unknown.

- **Section 836 repository briefing: no public evidence** — [Source](<https://www.pillsburylaw.com/en/news-and-insights/fy2026-ndaa-sourcing-restrictions-critical-minerals-advanced-batteries.html>) — Published 2026-06-26

Tag: Compliance Repository

§836 of P.L. 119-60 required a congressional briefing by May 1, 2026 and a public repository by January 1, 2027. No public record of the briefing. Worth noting: §836 covers §4862/4863/4864 sourcing regimes, not the §4865 battery-specific cost-origin test. That gap matters.

- **Suppliers meeting the FEOC cost threshold: zero** — [Source](<https://uscode.house.gov/view.xhtml?edition=prelim&req=granuleid%3AUSC-prelim-title10-chapter385-subchapter2>) — Published 2026-06-26

Tag: Supplier Count

§4865(c)(1) requires more than 95% of functional cell component costs from non-FEOC sources. No supplier has publicly claimed compliance. China controls 80%+ of global battery output (IEA, 2026). The waiver architecture Congress wrote into §4865 tells you what Congress already knew.

### External Sources

- **China Blocks Dual-Use Exports to Red Cat, MP Materials, and Eight Other U.S. Defense Firms** — [Source](<https://apnews.com/article/1aebe98718e127365859b0fb0b63d07b>) — Published 2026-06-26

Entity-level Chinese export controls on U.S. drone makers and rare-earth suppliers; supply-chain enforcement now bilateral.

- **Pentagon Adds BYD, CALB, and EVE Energy to 1260H List, Now at 188 Entities** — [Source](<https://apnews.com/article/4d664a6f164538b451263eafcceddaa5>) — Published 2026-06-26

DoD flags Chinese battery makers as military-linked; direct contracting ban June 30, third-party restrictions from June 2027.

- **BYD and Alibaba Push Back on Pentagon Military Designation as Procurement Bans Near** — [Source](<https://www.theguardian.com/world/2026/jun/09/china-military-tech-companies-byd-alibaba-baidu-pentagon-claims>) — Published 2026-06-26

Company denials on record; 1260H triggers procurement bans, not sanctions, but feeds OFAC and NS-CMIC pipelines.

- **IEA Global EV Outlook 2026: China Holds 80%+ of Battery Output, U.S. Costs Run 50% Higher** — [Source](<https://www.iea.org/reports/global-ev-outlook-2026/electric-vehicle-batteries>) — Published 2026-06-26

Anchors the Section 842 reality gap: LFP cathode supply nearly all China-sourced, Korean cost competitiveness tied to 45X.

## Other sections in Issue 3

- [Signal](<https://anchor.is/the-hysteresis/issue/3/signal/markdown>)
- [China](<https://anchor.is/the-hysteresis/issue/3/china/markdown>)
- [Korea](<https://anchor.is/the-hysteresis/issue/3/korea/markdown>)
- [The Log](<https://anchor.is/the-hysteresis/issue/3/the-log/markdown>)
- [Qualification](<https://anchor.is/the-hysteresis/issue/3/qualification/markdown>)

## More

- [Publication guide](<https://anchor.is/the-hysteresis/llms.txt>)
- [Issue archive](<https://anchor.is/the-hysteresis/issues/markdown>)
