Battery Sourcing & Compliance

U.S. pack assembly, global components

Upgrade Energy designs and assembles battery packs in the United States using components that may be internationally sourced. U.S. pack assembly does not mean that the cells or all other components are made in the United States. Cell manufacturing origin is separate from pack assembly location.

Does NDAA compliance require U.S.-made battery cells?

There is no universal NDAA requirement that all battery cells be U.S.-made. The National Defense Authorization Act (NDAA) includes different provisions with different scopes. Applicable sourcing restrictions depend on the provision, supplier, program and procurement date. Cell manufacturing country alone does not establish eligibility.

A Chinese-made cell does not automatically make a battery ineligible under every NDAA provision, and a cell made outside China does not automatically establish compliance. U.S. pack assembly, cell origin and procurement eligibility are separate considerations.

Which requirements may apply?

• Drone restrictions — FY2020 NDAA Section 848, as amended: Battery cells are not among the enumerated restricted components, which include flight controllers, radios, data transmission devices, cameras and gimbals. This does not establish eligibility under other laws, agency policies or contract requirements. DoD implementing clause.
• Specified battery manufacturers — FY2024 NDAA Section 154: Beginning October 1, 2027, this provision restricts DoD procurement of batteries produced by six named manufacturers and their successors. It is not a blanket restriction on every Chinese cell. Its definition of production also reaches certain component sourcing, so U.S. pack assembly alone does not resolve it. Enacted law, Section 154.
• Broader battery sourcing — FY2026 NDAA Section 842: This provision addresses foreign entities of concern, including functional cell components and technology. Applicability begins January 1, 2028 for new acquisition programs, January 1, 2029 for standard batteries and January 30, 2031 for existing acquisition programs, using the law's definitions. It applies to contracts or agreements entered into after enactment and includes exceptions and waiver provisions. Enacted law, Section 842.

Start with the applicable requirement. Before limiting your supplier options, identify the contract clause or program sourcing requirement and the procurement timeframe. Agency policies, contracts and customer preferences may impose additional restrictions; a customer preference should be distinguished from a mandatory requirement. Send us those details so we can assess the selected configuration and provide supporting documentation where available.

Summary reviewed October 26, 2026. Product eligibility requires assessment against the requirements applicable to the specific procurement.

Clear answers on each battery product page

Each battery listing identifies its cell options and answers specific purchasing criteria. A “meets” answer applies only to that named criterion; it is not universal NDAA certification or complete aircraft approval.

Drone Dominance: pack assembly and cell origin are different requirements

Under the July 23, 2026 framework, Phase II and Phase III minimum battery requirements call for non-covered-country pack assembly. Chinese-made cells alone do not fail that assembly criterion. Listed-entity restrictions and applicable BMS/electronics requirements remain separate.

Phase III preferred requirements (February 2027), which become Phase IV minimum requirements (August 2027), require non-covered-country cells that also meet FY2026 NDAA §842. RED V4’s China-made cells do not meet this cell-country criterion. RED V3’s Taiwan-made Molicel cells meet the cell-country criterion, but country alone does not establish §842 eligibility. Phase IV preferred requirements call for U.S.-manufactured cells; neither of those cell supplies meets that criterion.

GOLD and GREEN packs using Amprius SA08, SA10 and SA03 cells use China-manufactured cells. These listings do not meet requirements for cells manufactured outside China or in the United States, including the Drone Dominance cell-country criteria described above. U.S. pack assembly remains a separate criterion. A supplier’s compliant production pathway does not automatically cover every cell sold under its brand.

Official Drone Dominance framework, July 23, 2026: battery row on page 4. These are program-specific requirements and may change.

Buying for a restricted program

“Not currently offered as compliant with this requirement” means you should not order that listing for a purchase requiring it. Contact sales@upgradeenergytech.com before ordering to discuss a documented configuration. Include the product, quantity, exact requirement or program phase, and delivery date. A qualifying configuration is not guaranteed; availability and supporting documentation must be confirmed in writing.

This is our current sales position for the stated requirement, not a finding that the battery is legally noncompliant. Confirmed cell-country and pack-assembly answers remain separate from full procurement eligibility. GOLD/GREEN listings with Amprius SA03, SA08 and SA10 cells are not suitable for orders requiring cells manufactured outside China or in the United States.

Product-specific sourcing and NDAA requirements

If your program has NDAA-related or other sourcing requirements, contact sales@upgradeenergytech.com before ordering with the product, quantity and applicable requirements. You may request product-specific sourcing verification and supporting documentation where available. Availability and suitability must be confirmed for the selected configuration and supply. We do not claim universal NDAA certification; cell origin alone does not establish compliance.

Supply resilience

For products without an agreed sourcing restriction, we may use multiple qualified cell suppliers to support supply resilience, as disclosed on the product page. RED V4 listings identify the possible cell models. If cell manufacturer or country of manufacture matters to your purchase, request confirmation before ordering.