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.
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:
Defense teams must now:
Programs that proactively address covered nation exposure reduce redesign risk, protect sustainment timelines, and align more effectively with evolving DoD acquisition expectations.
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:
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.
Under the NDAA and related policy discussions, the covered nations in this context are:
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 sits at the center of most conversations about supply chain risks in optics and infrared.
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 is less central than China in overall manufacturing, but it remains:
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 is identified as an adversary in multiple US security strategies. For supply chains, the primary risk is not massive production capacity, but:
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 contributes little to legitimate global manufacturing, but it is:
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 is closely tied to Russia economically and politically. Its relevance for defense optics supply chains comes from:
From a DoD and prime contractor standpoint, Belarus is often treated as an extension of Russian exposure, especially in dual-use technologies.
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:
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 is a good case study of how technical excellence and supply chain risk intersect.
A few realities:
Chalcogenide glasses and other engineered IR materials are often positioned as germanium alternatives or complements. They can be:
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:
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:
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.
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.
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:
When these situations arise, programs can find that:
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.
Defense and aerospace organizations are already adjusting their strategies in response to both the NDAA and broader concerns about critical materials.
Common approaches include:
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.
The NDAA and the covered nation issue show up differently depending on your role in a program. It helps to break it down.
When all three perspectives are aligned, NDAA readiness becomes part of normal program discipline rather than an external compliance burden.
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:
This kind of structured approach gives program teams a way to move forward even when guidance is still evolving.
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:
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.