NDAA Compliance for Batteries: What It Means and Why It Matters

If your product will ever be sold to the U.S. Department of Defense — or to a prime contractor who sells to the DoD — the batteries inside it are subject to federal sourcing restrictions. At Zero Point Energy Labs, we build battery packs that meet these requirements from day one, so compliance never becomes a redesign problem later.

What Is the NDAA?

The National Defense Authorization Act (NDAA) is the annual legislation that sets policy and funding for the U.S. Department of Defense. In recent years, Congress has used the NDAA to reduce the military's reliance on supply chains controlled by foreign adversaries — covering everything from telecommunications equipment to drones, semiconductors, and, most recently, batteries.

The Battery Provision: Section 154 of the FY2024 NDAA

Signed into law in December 2023, Section 154 of the Fiscal Year 2024 NDAA prohibits the Department of Defense from procuring batteries produced by six named Chinese manufacturers and their successors:

• Contemporary Amperex Technology Co., Ltd. (CATL)
• BYD Company, Ltd.
• Envision Energy, Ltd.
• EVE Energy Company, Ltd.
• Gotion High-tech Company, Ltd.
• Hithium Energy Storage Technology Company, Ltd.

Importantly, the law's definition of "produced" is broad. A battery is considered produced by a covered entity if that entity assembled or manufactured the final product or supplied a majority of the battery's components. Simply assembling a pack outside of China does not make it compliant if the cells inside come from a restricted manufacturer.

Who Needs NDAA-Compliant Batteries?

NDAA compliance directly affects:

• Defense contractors and subcontractors supplying hardware to the DoD, at any tier of the supply chain
• UAS and drone manufacturers, who face additional sourcing restrictions under the American Security Drone Act
• Robotics, communications, and sensor companies pursuing government contracts or SBIR/STTR programs
• Commercial manufacturers who want to keep the defense market open as a future sales channel

Even companies not selling to the government today often specify NDAA-compliant batteries to avoid costly requalification if a defense opportunity arises later.

What Makes a Battery Pack NDAA-Compliant?

There is no formal "NDAA certification" — compliance is a supply-chain fact that must be documented and defensible. In practice, a compliant battery pack means:

1. Cells sourced outside covered entities. Cells must not be manufactured by the six named companies or their successors. Cells made in allied countries such as South Korea and Japan, or in the United States, meet this requirement.
2. Traceable component origin. The pack builder must be able to document where cells and major components were made, down to the manufacturer level.
3. Compliant pack assembly. Final assembly and the majority of component value must not come from a covered entity.

How Zero Point Energy Labs Delivers NDAA-Compliant Packs

We design and manufacture custom battery packs with sourcing compliance built into the engineering process, not bolted on afterward. Our compliant offerings include:

• High energy density cells — up to 500 Wh/kg — sourced from allied, non-covered countries
• US-made cell options for programs with stricter domestic-content requirements
• Full documentation of cell origin and component traceability to support your prime contractor or contracting officer's due diligence
• Pack-level engineering, BMS integration, and testing performed in the United States

Whether you are bidding on a defense program now or protecting your product roadmap for the future, we can help you specify a pack that meets both your performance targets and federal sourcing rules.

This page is provided for general informational purposes and does not constitute legal advice. Requirements vary by contract and agency; consult your contracting officer or legal counsel regarding your program's specific obligations.