Covered Nations and Defense Optics Supply Chain Risk under the NDAA

The Fiscal Year 2026 National Defense Authorization Act, signed into law on December 18, 2025, marks a significant evolution in how the United States approaches supply chain security for defense technologies. Optical glass, infrared materials, and electro-optical infrared systems are no longer treated as passive components within larger systems. They are now explicitly recognized as strategic technologies whose sourcing and manufacturing geography directly affect national security.

Under Section 834 of the FY26 NDAA, the Department of Defense is required to develop and implement a strategy to eliminate reliance on optical glass and optical systems sourced from covered nations by January 1, 2030. This requirement extends beyond finished EOIR systems to include the underlying materials and upstream supply chains that enable them. For defense and aerospace programs, this shifts compliance from a downstream procurement issue to a design-stage consideration.

Electro-optical infrared systems are foundational across land, sea, air, space, and emerging autonomous platforms. These systems depend on specialized substrates such as germanium, engineered infrared glasses, precision coatings, and tightly integrated assemblies. Many of these inputs trace back to globally concentrated supply chains that intersect with covered nations. As the 2030 deadline approaches, understanding where exposure exists and how to reduce it has become essential for program managers, engineers, and procurement teams alike.

Executive Overview

The NDAA requires the Department of Defense to eliminate reliance on optical glass and optical systems from covered nations, including China, Russia, Iran, North Korea, and Belarus, by 2030.

Optical and infrared systems are especially vulnerable because:

• Critical materials such as germanium and certain specialty glasses have highly concentrated global supply chains
  
  
• Covered nations, particularly China, play dominant roles in refining and processing key infrared materials
  
  
• EOIR programs have long development and sustainment cycles, making late-stage material shifts costly and disruptive
  
  

Defense teams must now:

• Map optical and infrared bills of material for country-of-origin exposure
  
  
• Evaluate material strategies that balance performance with supply chain resilience
  
  
• Align engineering, procurement, and compliance functions early in the program lifecycle
  
  
• Build documentation and traceability processes that support audit readiness
  
  

Programs that proactively address covered nation exposure reduce redesign risk, protect sustainment timelines, and align more effectively with evolving DoD acquisition expectations.

Why the NDAA Targets Optical Glass and Optical Systems

Recent NDAA language requires the Department of Defense to develop and implement a strategy to eliminate reliance on optical glass and optical systems from certain foreign nations by January 1, 2030. That mandate is centered in Section 834 of the FY26 NDAA, which specifically points to optical glass and optical systems as areas where reliance on “covered nations” must end.

This is not a symbolic move. It is a direct response to growing concern about how much critical defense capability rests on supply chains that lie outside US and allied control.

A few key points about what the NDAA actually does here:

• It focuses on optical glass and optical systems as specific categories
• It directs DoD to develop a strategy to eliminate reliance by 2030, rather than imposing an immediate ban
• It is concerned with “covered nations,” not all foreign suppliers
• It signals to primes and suppliers that future procurements will increasingly favor compliant, traceable, non-adversary sources

For EOIR systems, that means materials and suppliers that felt “good enough” a few years ago are already starting to look risky in a 2030 timeline.

Who Are the Covered Nations and Why Do They Matter?

Under the NDAA and related policy discussions, the covered nations in this context are:

• China
• Russia
• Iran
• North Korea
• Belarus

These countries are not grouped together by accident. They share a mix of adversarial posture, state control over strategic industries, and demonstrated willingness to use economic leverage for political or military advantage.

China

China sits at the center of most conversations about supply chain risks in optics and infrared.

• It dominates the production and refining of several critical minerals and minor metals, including gallium and germanium, that are essential for infrared optics, semiconductors, and advanced electronics
• It has repeatedly used export controls and licensing as a lever, including restrictions on germanium and gallium exports that disrupted global markets and introduced long lead times and price spikes
• It already produces a large share of mature-node semiconductors and plays an outsized role in refining and processing critical materials across multiple sectors

For EOIR programs, China’s position as a dominant producer of germanium and other infrared-relevant materials, combined with its control over many optical manufacturing chains, is a direct national security concern.

Russia

Russia is less central than China in overall manufacturing, but it remains:

• A significant source of raw materials and processing capacity for specific critical minerals
• A driver of geopolitical instability that can disrupt global trade patterns and supply routes

Sanctions, export controls, and reciprocal trade measures tied to Russia’s actions create an environment where long-term reliance on Russian-linked supply chains is inherently risky for defense programs.

Iran

Iran is identified as an adversary in multiple US security strategies. For supply chains, the primary risk is not massive production capacity, but:

• Exposure to procurement networks and intermediaries linked to Iranian entities
• Potential rerouting of sensitive technologies and materials through third parties

In a supply chain context, Iran poses more of a sanctions and compliance risk than a single point of failure for optics or minerals, but that risk still needs to be managed.

North Korea

North Korea contributes little to legitimate global manufacturing, but it is:

• A focal point for sanctions evasion, illicit procurement, and front companies
• A potential actor in cyber or physical interference with supply chain data and logistics

The risk here is more about contamination of the chain with proscribed entities than about losing direct material supply, but for programs under NDAA scrutiny, that still matters.

Belarus

Belarus is closely tied to Russia economically and politically. Its relevance for defense optics supply chains comes from:

• Participation in broader Eurasian industrial networks
• Potential involvement in processing or assembly chains linked to Russian entities

From a DoD and prime contractor standpoint, Belarus is often treated as an extension of Russian exposure, especially in dual-use technologies.

How Defense Optics Depend on Vulnerable Materials

Defense EOIR systems draw on a complex stack of materials and components that connect, directly or indirectly, to these covered nations.

At the material level, critical dependencies include:

• Infrared substrates such as germanium and certain chalcogenides
• Specialty optical glasses for visible and multispectral systems
• Coating materials and chemicals with limited global suppliers

Many of these materials appear on the US government’s lists of critical minerals, which identify resources that are essential for economic and national security and vulnerable to disruption. For example, germanium is listed as a critical mineral due to its importance in fiber optics, infrared optics, and electronics.

From a purely technical perspective, these materials are chosen for their performance in demanding environments: high-temperature operation, multi-band transmission, resistance to radiation and shock, and stable performance across wide temperature ranges.

From a supply chain perspective, the problem is simple: too much of this capability rests on a small number of processing hubs and producers located within or adjacent to covered nations.

Germanium, Chalcogenides, and Critical Exposure

Germanium is a good case study of how technical excellence and supply chain risk intersect.

A few realities:

• Germanium is a key substrate for mid-wave and long-wave infrared optics, fiber optics, and certain semiconductor applications
• Production is highly concentrated. Different market analyses put China’s share of refined germanium in the range of roughly two-thirds or more of global supply, and in some forms, even higher
• China has already used export bans and licensing regimes around germanium as part of broader technology and trade disputes, causing price spikes and extended lead times

Chalcogenide glasses and other engineered IR materials are often positioned as germanium alternatives or complements. They can be:

• Formulated to cover specific spectral bands
• Molded at scale for certain lens designs
• Produced in domestic or allied facilities when the right infrastructure exists

The core issue for EOIR programs is not that germanium or any one material is “bad.” It is that heavy reliance on any material whose supply chain runs through a covered nation becomes increasingly hard to justify under the NDAA and related policies.

For program teams, this translates to a need for material strategies that:

• Maintain performance across required bands and environments
• Diversify sourcing away from single-country concentration
• Enable domestic or allied production at the scales required for long program lifecycles

How Covered Nations Shape Supply Chain Risk for Optics

Supply chain risk in defense optics is not hypothetical. Recent years have provided a steady stream of signals that global access to critical materials can be quickly and strategically restricted.

Some of the recurring patterns:

• Export controls and licensing regimes that slow or limit shipments of critical minerals and minor metals, including germanium and gallium, especially when tied to broader disputes over semiconductors or advanced electronics
• Use of dominant positions in rare earths and critical minerals as leverage, putting pressure on defense and high-tech industrial bases that depend on a stable supply
• Growing recognition inside the US government that adversary control over critical materials is a strategic vulnerability, reflected in policies on critical minerals, stockpiles, and industrial base investments

For optics and infrared systems, the risk is compounded by the fact that optical elements are often custom, highly engineered parts. Swapping materials late in a program lifecycle is not a simple catalog substitution. It can affect optical performance, thermal behavior, mechanical design, coatings, and calibration.

That is part of why the NDAA sets a 2030 target. It is an acknowledgment that shifting away from covered nations for optical glass and systems will take time and careful planning.

What GAO and Other Analyses Are Saying about Supply Chain Blind Spots

Multiple recent government and independent analyses have highlighted the depth of supply chain blind spots in the defense industrial base.

A recent GAO report on defense industrial base risks found that DoD often lacks clear, integrated data on supply chains and country-of-origin information, and recommended using contract requirements to obtain better data from suppliers.

Separately, work on critical materials and stockpile policy has emphasized that adversary nations can shape markets in ways that undercut US resilience if sourcing is not diversified.

Outside government, independent analyses have warned that China’s control over key materials can “turn off” parts of the defense industrial base, and have urged a shift toward diversified, allied, and domestic production for critical inputs.

For EOIR programs, the takeaway is straightforward. If you cannot see where your optical materials and components originate, you probably cannot prove compliance. If you can see it and it runs through covered nations, you have a problem that grows more urgent as 2030 approaches.

Defense Optics Supply Chain Risk in Practice

It helps to translate all of this into scenarios that defense and aerospace teams actually face.

Common risk patterns in optics and infrared systems include:

• A technically strong supplier that sources glass melts or IR substrates from a covered nation while performing final assembly elsewhere
• A complex multi-tier chain where a Tier 2 or Tier 3 vendor introduces covered nation exposure that the prime cannot easily see
• Legacy designs that rely on materials whose pricing, availability, or export status has become volatile
• Programs that passed qualification years ago and now face obsolescence issues or supply interruptions as export rules change

When these situations arise, programs can find that:

• Redesigning optics late in the lifecycle is expensive and slow
• Requalification testing can impact schedules and downstream integration
• Documentation gaps make it difficult to prove that systems are compliant, even if risk has been reduced in practice

That is why serious NDAA readiness work starts with a clear understanding of the optical and infrared bill of materials and the actual country-of-origin profile behind it.

How the Defense Industrial Base Is Responding

Defense and aerospace organizations are already adjusting their strategies in response to both the NDAA and broader concerns about critical materials.

Common approaches include:

• Increasing use of critical mineral task forces and industrial base mapping to understand where dependencies exist and how they interact with covered nations
• Supporting domestic and allied projects for critical minerals and advanced materials, including DoD-backed investments in rare earth and critical mineral producers that serve defense markets
• Encouraging primes and major subsystem suppliers to build more transparent supply chains and provide better provenance data as part of contracts
• Shifting new designs toward materials and suppliers that can demonstrate long-term availability and NDAA alignment

None of this is specific to optics. However, EOIR systems are a particularly sharp example because they combine long lifecycles, specialized materials, and very concentrated supply chains.

Program-Level Implications for EOIR Teams

The NDAA and the covered nation issue show up differently depending on your role in a program. It helps to break it down.

For program managers

• Compliance and supply chain risk are now program-level risks that belong in risk registers, milestone reviews, and program plans
• NDAA alignment for optics is something customers and oversight bodies will expect to see addressed explicitly, not assumed
• Early decisions about suppliers and materials will define compliance options for the life of the program

For engineering leads and EOIR architects

• Material selection is now linked directly to compliance and lifecycle risk, not only performance
• Designs that can be manufactured and sourced domestically or from allied supply chains reduce future rework risk
• Traceability of materials and design decisions will matter when audits or customer questions arise

For procurement and supply chain teams

• Supplier qualification must include country-of-origin transparency and willingness to provide provenance data
• Contract structures may need to require notification if suppliers change material sources or processing locations in ways that affect covered nation exposure
• Working with suppliers that have vertically integrated and geographically aligned manufacturing reduces hidden exposure

When all three perspectives are aligned, NDAA readiness becomes part of normal program discipline rather than an external compliance burden.

Practical Steps to Map and Mitigate Optics Supply Chain Risk

Most EOIR programs will need a systematic approach to get from “we know this is an issue” to “we have a credible plan and documentation.”

A practical sequence might look like this:

1. Inventory your optics and IR bill of materials
• Identify all optical glass types, IR substrates, coatings, filters, and assemblies
• Capture supplier names and part numbers, including Tier 2 information where possible
2. Map the country of origin and processing locations
• Ask suppliers to provide country-of-origin and key process locations for materials and critical steps
• Flag any exposure to China, Russia, Iran, North Korea, and Belarus
3. Assess risk by program phase and lifecycle
• For systems in early design, consider design changes or alternate materials where exposure exists
• For fielded systems, assess sustainment and obsolescence risk and plan for phased mitigation
4. Prioritize mitigation actions
• Focus first on high-impact programs and components with single-country exposure in covered nations
• Evaluate domestic or allied alternatives, including materials such as chalcogenide IR glasses that can be produced in compliant facilities
5. Integrate compliance into governance
• Add optics-related NDAA dependencies into risk registers and program reviews
• Align engineering change processes, supplier change control, and configuration management with NDAA documentation needs
6. Build ongoing visibility
• Treat supply chain mapping and provenance as ongoing data, not a one-time exercise
• Leverage emerging DoD frameworks for supply chain risk management and country-of-origin visibility as they become available

This kind of structured approach gives program teams a way to move forward even when guidance is still evolving.

Where LightPath Fits in the Emerging Landscape

As primes and subsystem suppliers adjust to NDAA requirements, there is increasing value in working with optical and infrared partners that already align with the direction of policy.

Recent public statements highlight that LightPath Technologies has been designing and delivering optical assemblies, infrared cameras, and thermal imaging systems in alignment with NDAA requirements for years, with a focus on domestic manufacturing and proprietary infrared glass technologies as alternatives to foreign-sourced materials.

At a high level, this type of approach addresses several of the risk vectors discussed in this pillar:

• Vertical integration across materials, lenses, assemblies, and systems helps reduce hidden exposure and improve provenance transparency
• Domestic and allied manufacturing footprints support NDAA goals around eliminating reliance on covered nations by 2030
• Investment in alternative IR materials, including chalcogenide glasses, provides options where germanium-centric supply chains appear vulnerable or misaligned with long-term policy trends

For defense and aerospace teams, the important thing is not the name on the door, but whether a supplier’s material strategy, manufacturing footprint, and documentation practices make compliance easier, not harder.

Frequently Asked Questions

Are all foreign optics suppliers a problem under the NDAA?

No. The NDAA is focused on eliminating reliance on covered nations, not all foreign suppliers. Optics sourced from the US or allied countries are generally acceptable, as long as provenance and processing paths do not route through covered nations.

Does the NDAA ban germanium or other specific materials?

The NDAA does not ban germanium. The concern is heavy reliance on supply chains that run through covered nations that dominate production and refining. Programs are encouraged to evaluate the sources of their materials and whether that reliance introduces unacceptable risk.

What if a supplier assembles in an allied country but sources materials from a covered nation?

Final assembly location alone is not enough. If the material is melted, refined, or undergoes key processing steps in a covered nation, that exposure still matters under the spirit of the NDAA and related supply chain policies. Programs should request clear provenance data from suppliers.

How quickly will enforcement become strict?

The NDAA sets a 2030 target and focuses on strategy development. However, acquisition teams are already incorporating these expectations into RFIs and RFPs, and audits will increasingly expect to see credible plans and documentation. It is safer to assume the enforcement curve will steepen rather than wait for a single hard cutoff.

What is the most important step EOIR programs can take now?

Start by mapping your optics and infrared bill of materials and understanding where your materials and processes originate. With that clarity, it becomes much easier to identify which components are exposed to covered nations and where design changes, alternates, or new supplier relationships can reduce risk.

How does the NDAA differ from traditional export controls like ITAR?

ITAR and EAR regulate the export and transfer of defense articles and dual-use technologies. The NDAA provision on optical glass and optical systems focuses on eliminating reliance on covered nations within the defense supply chain itself. In other words, ITAR governs where products can go, while the NDAA increasingly influences where materials and systems can come from.

Does this requirement apply only to new programs?

No. While new programs are the most directly affected because design decisions are still flexible, existing programs may also face scrutiny during upgrades, production extensions, or sustainment phases. If a program relies on materials from covered nations and those materials become restricted or unavailable, sustainment risk increases significantly.

How does this affect commercial off-the-shelf optical components used in defense systems?

Commercial off-the-shelf components are not automatically exempt. If those components contain optical glass or infrared materials sourced from covered nations, they may create compliance challenges when integrated into defense platforms. Programs should evaluate COTS optics with the same country-of-origin diligence as custom components.

What level of documentation should programs expect to provide?

Programs should anticipate increasing expectations around material provenance documentation. This may include country-of-origin certifications, supplier disclosures, and configuration management controls that track material changes. As GAO and DoD continue emphasizing supply chain visibility, documentation standards are likely to become more formalized.

How does supply chain concentration create risk even if materials are currently available?

Supply chain concentration creates vulnerability even when no restrictions are in place. If a single nation controls a majority share of refining or processing capacity for a material, that country has leverage to restrict exports, impose licensing requirements, or shift pricing structures. The NDAA seeks to reduce exposure to that leverage before it becomes a crisis.

Are allied nations automatically considered low risk?

Allied sourcing is generally lower risk than sourcing from covered nations, but it still requires transparency. If an allied manufacturer relies on upstream materials or processing in a covered nation, the exposure remains. Programs must understand not only final assembly locations, but also upstream material flows.

What is the most common blind spot in optics supply chain assessments?

The most common blind spot is exposure to Tier 2 and Tier 3 materials. Many primes have visibility into their direct suppliers but lack insight into where those suppliers source raw optical materials or infrared substrates. Without deeper mapping, programs may underestimate their actual covered nation exposure.

Conclusion: Designing for Performance, Resilience, and Compliance

The inclusion of optical glass and optical systems in the FY26 NDAA is not a narrow procurement update. It is a signal that the United States considers optical and infrared supply chains to be strategic infrastructure. For decades, EOIR programs optimized for performance, cost, and schedule. Now, material origin and manufacturing geography sit alongside those traditional priorities.

Covered nation exposure is not always obvious. It may reside in raw material refinement, intermediate processing, or single-country concentration of critical minerals. For defense programs with long design and sustainment timelines, ignoring these dependencies introduces risk that compounds over time.

The 2030 deadline provides a horizon, but the practical work must begin much earlier. Engineering teams must evaluate materials in the context of compliance and lifecycle risk. Procurement teams must demand clearer provenance from suppliers. Program managers must elevate optics supply chain exposure into formal risk frameworks.

Organizations that move early will reduce the likelihood of redesigns, qualification delays, or sustainment disruptions. Those who wait may find their flexibility constrained as enforcement tightens and alternatives narrow.

For defense and aerospace teams seeking to better understand covered nation exposure in optical and infrared systems, or to evaluate compliant material and manufacturing strategies, connecting with a LightPath Technologies expert can provide clarity and reduce long-term program risk.