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The battery provenance record.
The fields a DoD prime or auditor will expect, what a complete record looks like, and the questions to put to your cell supplier. For drone and pack programs facing NDAA Sections 154 and 842.
Why This Record Exists
Origin and ownership, not the label on the pack.
Two DoD provisions now restrict where battery cells can come from. Section 154 of the FY2024 NDAA bars the Department of Defense from buying batteries produced by six named Chinese manufacturers, effective October 1, 2027. Section 842 of the FY2026 NDAA, signed December 2025, goes further: it bars advanced batteries, their cells, and key components that are owned, sourced, refined, or produced by a foreign entity of concern — a company located in or controlled by China, Russia, Iran, or North Korea. Its restrictions phase in from January 1, 2028, and reach upstream past final assembly.
If you sell batteries or packs into DoD programs, directly or as a subcontractor at any tier, you will have to show your cells are clean. The implementing DFARS clauses are still being written, so the exact certification language is not final. The way to be ready regardless is to hold a per-lot record tying every cell to its manufacturer, its plant and country, its ownership, and your own test evidence. The spec below is that record. Carve-outs exist for some commercial off-the-shelf items and through a narrow waiver, so confirm how the rules apply to your contracts.
The Record, Field by Field
What turns a claim into proof.
For each cell lot you receive, a record that survives scrutiny carries these fields. Most teams capture the identity fields and stop. The origin, ownership, and evidence fields are what turn an assertion into proof.
A Worked Example
One lot, recorded to that standard.
Every field is answerable, and every claim is backed.
The same lot without the origin, ownership, and test fields reads as "500 cells, supplier X, looks fine." That is an assertion. A prime cannot accept an assertion, and you cannot prove Section 842 compliance with one.
Questions To Put To Your Cell Supplier
Copy these into your next PO.
The answers populate the record above, and the gaps show you where your exposure is.
- At which plants, and in which countries, are the cells for our orders manufactured?
- What legal entity manufactures them, and who is its parent or ultimate owner?
- Will you provide per-lot country-of-origin documentation with every shipment?
- Can you give cell-level lot traceability tied to each shipment, including lot IDs and production dates?
- Will you notify us in writing before moving production to a different plant or country?
- Are any of your manufacturing entities or owners on the DoD 1260H list, among the six manufacturers named in NDAA Section 154, or otherwise a foreign entity of concern under Section 842?
Where Micantis fits.
Micantis is where this record lives and stays current. We turn the cycler data you already generate into a per-lot record like the one above, tied to its supplier and to your own test verdicts, and keep it exportable as lots and suppliers change. The proof stays yours, in formats you own.
For the drone supply-chain context, see the DroneQC page.
General guidance, not legal or compliance advice. Confirm requirements against your contracts and counsel. Sources: FY2024 NDAA Section 154; FY2026 NDAA Section 842 (P.L. 119-60, signed December 18, 2025). Implementing DFARS regulations were not yet finalized as of mid-2026.