Three signals from the middle of this year justify a segment-level look at the §4865 mandate gap rather than an aggregate one. HII's Lionfish option-year exercise on July 6 put a second UUV program into production without disclosing a cell supplier. S.4784 failed cloture on July 14, leaving the Section 847 battery language reported but inoperative. And the 6T line stayed where it has been: applied research, no production procurement. Small UAV cells, 6T vehicle batteries, and UUV modules each sit against a different binding constraint — cell availability, formal qualification, and certification opacity. This piece maps the current state of each. Temporal dynamics and waiver-quality assessment belong to the companion feature.
Small UAV and the cell-availability gap
The §4865 new-acquisition deadline is January 1, 2028 — seventeen months out. The requirement is that 95% of a battery's total costs originate outside foreign entities of concern, screened at the functional-component level.
The public record supports seven manufacturers with operating or evidenced 18650/21700 production in the United States or noncovered countries: Panasonic Energy (2170, Nevada and Kansas), American Lithium Energy (18650, Carlsbad), EnerSys/Quallion (18650, Sylmar), Murata (18650/21700, Japan), Samsung SDI (21700, Malaysia), LG Energy Solution (2170, Korea), and Molicel (18650/21700, Taiwan). Three carry defense-adjacent development routes: ALE holds a $6M Air Force Phase II for Space Force cell qualification, EnerSys is adapting 18650 designs under DIU's FAStBat program, and Molicel's line is producing the NanoGraf M38 cells now in qualification for the Army Leader Radio.
Neither Samsung SDI nor LG Energy Solution has disclosed a U.S. defense contract, qualification milestone, or program-specific volume for small UAV cells in 2026 filings or earnings materials. That is consistent with eighteen months of Korean-maker disclosure tracked in this publication: when committed volume exists, these companies report it.
Seven manufacturers is a count of production capability. It is not a count of qualified supply, and on the public record no cell from that list is paired to a cleared small-UAV platform under §4865 cost-origin screening. The reason: Blue UAS clears platforms without battery provenance. The public cleared list carries no cell-manufacturer, chemistry, component-origin, or §4865 field. A drone can hold Blue UAS certification and carry cells with full FEOC supply-chain exposure. No battery-qualification pathway exists inside the Blue UAS architecture, so there is no timeline to estimate for closing this gap. No publicly recorded waiver or waiver request for small-UAV battery sourcing was identified in checked records.
Two announced pathways are not yet operating. Forge Nano's Morrisville plant targets 3 GWh/year with Samsung SDI operational assistance and an expected 2028 start, which lands after the new-acquisition deadline. DIU describes planned NanoGraf 18650 production by 2027 but identifies the current qualification cells as Molicel-produced.
Pending legislative signal: S.4784 Section 847 would extend covered-UAS restrictions explicitly to batteries and battery management systems. The provision remains in the Senate-reported text. The Senate failed cloture 50–46 on July 14, and motions on July 23 and July 27 did not advance the bill. The House passed H.R.8800 on July 22. No conference exists. §847 is unchanged and has no effect.
6T vehicle batteries and the qualification gap
Which §4865 deadline applies to a 6T buy depends on the program's milestone status at enactment, not on the battery. A 6T purchase under a program that had not reached Milestone B faces January 1, 2028 — seventeen months. A purchase under an existing vehicle program such as JLTV or Stryker falls under January 30, 2031. The statute also sets a separate January 1, 2029 standard-battery deadline, twenty-nine months out, which is arguably the most directly relevant date for a mil-spec battery designed as a form-factor replacement. The distinction is currently academic. No production procurement has occurred under any of these timelines, so the qualification gap binds regardless of which date arrives first.
Two 2026 public records attach to lithium-ion 6T work. W5170126CA050, awarded March 30, is a $2M applied-research contract to Farad Power for biomass-derived anode 6T batteries, with no quantity or production rate disclosed. A254-P050, closed May 13, is a Phase I solicitation of up to $250K covering charging, fire mitigation, diagnostics, and maintenance for Gen 3 Li-ion 6T batteries. It references MIL-PRF-32565 but procures feasibility work. No awardee was public at research cutoff.
No 2026 production solicitation or award naming a MIL-PRF-32565 battery quantity, LRIP lot, or vehicle-program allocation appeared in checked SAM.gov, Army PEO, or DLA records. No publicly recorded waiver activity for 6T lithium-ion batteries was identified. This matches what I documented in issue #8: authority to buy and obligation to buy are distinct instruments, and 6T has not crossed from R&D into production procurement.
QPL-32565 remains at zero rows. DLA has reported manufacturing progress at key developers. Development milestones are not qualification rows. Until a product appears on the QPL, no contracting officer can order against the specification. MIL-PRF-32565 qualification has historically taken 18 to 36 months from first article submission through environmental, abuse, and life-cycle testing. Started today, that finishes no earlier than mid-2028.
UUV modules and the certification gap
The deadline mapping here is mixed and both dates are live at once. New UUV battery contracts, including the torpedo-tube launch-and-recovery awards, fall under January 1, 2028. The Lionfish option-year exercise continues an existing contract and falls under January 30, 2031.
The strongest 2026 production signal is Lionfish. On July 6, HII announced the Navy had exercised an option year, with 42 vehicles delivered through 2025 against a five-year ceiling above $347M for up to 200 vehicles. The announcement discloses no cell supplier, pack supplier, chemistry, or §4865 evidence.
DIU awarded L3Harris an OTA in March 2026 for the Iver4 900 torpedo-tube launch and recovery system. L3Harris describes the Iver4 900 as carrying the first Navy submarine- and aviation-approved AUV lithium-ion technology, but that certification completed in 2024 with Inventus Power named as pack producer. Cell supplier and chemistry remain undisclosed. HII's April 2026 contract for REMUS torpedo-tube launch and recovery identifies no battery supplier, certification milestone, or value.
As I assessed in issue #2: system-level specifications are public, pack-level producers are sometimes identifiable, cell-level supply chains are opaque across all programs. Nothing in 2026 has changed that. The Iver4 900/Inventus configuration is the only publicly certified UUV battery pairing, and it predates this year. Navy lithium-battery certification is configuration-specific, and a new cell or pack design triggers a fresh cycle that has historically run two to four years. No waiver activity for UUV battery sourcing was identified in checked Navy, NAVSEA, or SAM.gov records. Platform demand is not the problem here — vehicles are being contracted and built. The problem is that nobody outside the program offices can see what cells go into them, which makes the §4865 screening question unanswerable from public sources rather than answerable and negative.
Across the three segments
| Segment | Nearest Deadline | Months Out | Binding Constraint | Qualified Supply (public record) |
|---|---|---|---|---|
| Small UAV | Jan 1, 2028 (new acq.) | 17 | No battery-qual pathway in Blue UAS | 7 cell makers; 0 paired to cleared platform under §4865 |
| 6T | Jan 1, 2029 (std. battery) | 29 | QPL-32565: zero rows | 0 on QPL; 18–36 mo. qual timeline |
| UUV | Jan 1, 2028 (new acq.) / Jan 30, 2031 (existing) | 17 / 53 | Cell-level supply chain opacity | 1 certified pairing (Iver4 900/Inventus, pre-2026) |
In issue #7 I assessed four candidate defense battery suppliers against the §4865 cost-origin proof requirement and found it blank across all four. That holds at segment level, and no waiver or waiver request has surfaced publicly in any of the three segments to relieve it. What differs by segment is the constraint sitting in front of the proof requirement. Small UAV lacks a battery-qualification pathway inside the platform certification it already has. 6T lacks a qualified product to procure. UUV lacks visibility into cells already in contracted platforms. Each would require a different instrument to close, and on the public record none is underway.
- DIBC BES-26-01 awards: Quad-chart submissions closed July 17 with no public award listed yet, making this the clearest near-term test of whether expressed small-cell demand converts into a volume-backed selection.
- DLA standards project 6140-2026-008: DLA's standards catalog lists this new project number under MIL-PRF-32565 without publishing scope, status, or schedule — a potential signal of specification revision or qualification-pathway change.
- SK On UUV negotiation: Yonhap reported in February that SK On was discussing battery supply for an AI-enabled UUV with an unnamed U.S. defense company, but no named contract or qualification record has surfaced in six months of monitoring.
- DFARS Case 2024-D011 NPRM: The Unified Agenda projected a July 2026 proposed rule, the third projected date after December 2024 and February 2026 — Federal Register searches still return nothing.