Takeaways

• The FY 2026 NDAA adds new critical minerals to the Department of Defense “covered materials” regime and introduces phased restrictions on DoD procurement of advanced batteries linked to foreign entities of concern.

• The FY 2026 NDAA creates structured opportunities for industry input, including a defense industrial base working group and a voluntary public compliance certification repository.

• Prime contractors and subcontractors (at all tiers) should map supply chains through mining, refining and separation stages; identify materials subject to DFARS restrictions; evaluate recycled-material and waiver pathways; and develop a forward-looking compliance strategy before the 2027 expansion takes effect.