NDAA Compliance and Readiness for Optical and Infrared Systems
A comprehensive guide for defense and aerospace EOIR programs
Signed into law on December 18, 2025, the Fiscal Year 2026 National Defense Authorization Act introduces one of the most consequential shifts in defense optics sourcing policy in decades. For the first time, optical glass, infrared materials, and optical systems are explicitly identified as technologies the Department of Defense must decouple from certain foreign nations. While the compliance deadline is set for January 1, 2030, the realities of defense acquisition timelines mean this requirement is already shaping decisions today.
Electro-optical infrared (EOIR) systems are foundational to modern defense platforms. They enable targeting, navigation, surveillance, threat detection, and situational awareness across land, sea, air, space, and emerging autonomous systems. As these capabilities become more central to mission success, the materials and supply chains behind them have become matters of national security.
This guide explains what the NDAA requires, why optics and infrared materials are in scope, how germanium and alternative materials factor into compliance, and what defense teams should be doing now to reduce risk and ensure long-term readiness. It also provides practical context for program managers, engineers, and procurement leaders navigating compliance across complex, multi-tier supply chains.
Executive Overview
The FY26 NDAA directs the Department of Defense to eliminate reliance on optical glass and optical systems sourced from covered nations by 2030. Covered nations include China, Russia, Iran, North Korea, and Belarus. The scope extends beyond finished EOIR systems to include raw optical materials, infrared substrates, and critical intermediate processes.
Because EOIR systems often take five to ten years to design, qualify, and deploy, programs entering development today must address compliance immediately. Waiting until the late 2020s risks forced redesigns, requalification delays, and long-term sustainment challenges.
Understanding the NDAA Requirement
The National Defense Authorization Act is the annual policy and funding framework governing US defense priorities. While many provisions focus on force structure or budget allocations, others directly influence industrial base strategy and technology sourcing.
Section 834 of the FY26 NDAA states that the Secretary of Defense shall develop and implement a strategy to eliminate reliance on any covered nation to acquire optical glass or optical systems by January 1, 2030. This language represents a meaningful escalation in how optics are treated within defense policy.
Optical glass and infrared materials were historically viewed as passive components. Today, they are recognized as enabling technologies that directly influence battlefield advantage. By explicitly calling out optics, the NDAA signals that material provenance, manufacturing geography, and supply chain transparency are now inseparable from system performance.
Covered Nations and Supply Chain Exposure
Under the NDAA, covered nations include China, Russia, Iran, North Korea, and Belarus. These countries have been identified due to geopolitical risk, adversarial posture, and state influence over strategic industries.
For optics and infrared systems, this matters because global supply chains have long been concentrated in regions now considered high risk. China has played a dominant role in optical glass manufacturing and infrared material processing. Russia has historically been a major contributor to germanium production and refinement. Belarus has participated in optical manufacturing ecosystems tied to Russian supply chains.
The NDAA not only addresses direct purchases. It compels defense programs to understand indirect exposure throughout the supply chain. Optical elements melted in one country, processed in another, and assembled elsewhere still carry origin risk. This makes traceability and documentation central to compliance.
Why Optics and Infrared Materials Are Now in Scope
Modern defense systems depend on EOIR performance at every level. Missiles rely on infrared seekers. ISR platforms depend on optical clarity and thermal sensitivity. Naval systems use EOIR for navigation and threat detection. Space-based sensors require extreme material stability over decades.
These systems are only as secure as their weakest component. Optical glass and infrared materials influence spectral transmission, thermal behavior, environmental durability, and long-term reliability. When sourced from adversarial or unstable regions, they introduce strategic vulnerability.
From a policy perspective, optics are no longer interchangeable parts. They are mission-critical technologies that must be secured just like electronics, propulsion systems, or communications infrastructure.
Germanium and Infrared Material Risk
Germanium has long been a foundational material for mid-wave and long-wave infrared optics due to its high refractive index and favorable transmission properties. For decades, it served as the default substrate for many IR systems.
The challenge is supply concentration. A significant portion of global germanium production and processing has historically been tied to China and Russia. This creates exposure to export controls, pricing volatility, and geopolitical disruption.
The NDAA does not prohibit germanium outright. Instead, it forces programs to assess sourcing risk in context. For long lifecycle defense platforms, reliance on constrained or adversarial supply chains is increasingly unacceptable.
As a result, material selection is no longer purely an optical decision. It is a strategic one that affects compliance, sustainment, and long-term availability.
Alternatives to Germanium and Material Innovation
In response to the germanium supply risk, the optics industry has pursued multiple mitigation strategies. Some programs attempt to dual-source material. Others stockpile inventory. Increasingly, attention has turned to alternative infrared materials engineered for both performance and supply security.
Chalcogenide-based infrared glass is a prominent example. This material can be tailored for specific spectral bands, molded at scale, and manufactured domestically. It also enables reductions in size, weight, and power at the system level.
Material innovation in this space allows defense teams to decouple performance from geopolitically constrained resources. It also supports scalable production for programs transitioning from low-rate initial production to full-rate manufacturing.
Compliance Extends Beyond Finished Systems
A common misconception is that NDAA compliance can be addressed at final assembly. In practice, scrutiny begins much earlier.
Material melt location matters. Infrared substrate origin matters. Intermediate processing steps such as polishing, coating, and shaping matter. Programs must be able to demonstrate transparency across the entire optical value chain.
This shifts the burden of proof upstream. Suppliers must provide documentation, certifications, and traceability data. Primes inherit the risk of any supplier in their ecosystem that cannot meet these requirements.
As a result, defense acquisition teams are increasingly favoring suppliers with vertically integrated, domestic manufacturing capabilities.
Timeline Realities for Defense Programs
Although the NDAA establishes a 2030 deadline, EOIR program timelines compress the effective window dramatically.
Most defense optical systems take years to progress from concept through qualification. Design decisions made today will define material choices well into the 2030s. Programs that delay compliance planning may find themselves locked into non-compliant architectures with limited remediation options.
Late-stage redesigns in optical systems are particularly disruptive. Changes to materials often cascade through mechanical design, thermal management, coatings, and calibration. Early action is significantly less costly than retroactive fixes.
How NDAA Compliance Reshapes EOIR System Architecture
NDAA considerations are now influencing system architecture decisions that were historically driven only by performance and cost.
Early trade studies increasingly account for supply chain resilience. This affects decisions such as monolithic versus modular designs, the number of optical elements per channel, and spectral band consolidation strategies.
Architectures that minimize reliance on constrained materials or enable domestic-scale manufacturing are often favored, even if they introduce modest optical complexity. In the NDAA context, resilience by design is becoming a core requirement.
Program Management and Risk Ownership
From a program management perspective, NDAA compliance elevates optics into a formal risk category.
Compliance readiness is now discussed during preliminary design reviews, critical design reviews, and manufacturing readiness assessments. Optical suppliers are evaluated not only on technical performance, but also on their ability to demonstrate material provenance and future capacity.
For primes managing complex supplier ecosystems, this risk extends beyond Tier 1 partners. A single non-compliant Tier 2 or Tier 3 supplier can jeopardize an entire program.
NDAA Language in RFIs and RFPs
NDAA readiness is increasingly embedded in early acquisition documents. RFIs and RFPs now commonly request disclosure of material origin, certification of non-reliance on covered nations, and guarantees of future compliance across the system lifecycle.
Some solicitations also include audit rights and change notification clauses tied to sourcing. This reflects a broader shift from informal trust to documented accountability.
Suppliers that can respond with clarity and confidence gain an advantage early in the acquisition process.
Allied Sourcing Still Requires Transparency
Sourcing from allied nations is generally acceptable under the NDAA, but it is not a blanket exemption. If allied manufacturers rely on raw materials or intermediate processing from covered nations, exposure remains.
For optics, indirect risk can arise from glass melts, infrared substrates, tooling, or coating materials sourced outside compliant regions. Programs must understand the full chain, not just final assembly locations.
This reinforces the value of vertically integrated suppliers with fewer handoffs and greater control.
Sustainment and Lifecycle Considerations
For many programs, the greatest NDAA risk lies not in initial qualification, but in sustainment.
Defense optical systems often require spare parts, refurbishment, and upgrades over decades. If a material or supplier becomes unavailable or non-compliant mid-lifecycle, programs may face forced redesigns long after deployment.
Designing around compliant, scalable materials from the outset reduces long-term sustainment risk and protects mission availability.
Enforcement Trajectory and Future Expectations
While enforcement guidance continues to evolve, most observers expect a phased approach.
Early stages emphasize disclosure and planning. Over time, enforcement is likely to include contractual penalties, funding restrictions, increased audits, and public scrutiny.
Programs that align early will experience minimal disruption. Those who delay may face limited options under time pressure.
The Strategic Value of Vertical Integration
Under the NDAA, vertical integration offers clear advantages.
Integrated control over materials, lenses, assemblies, and systems enables traceability, faster response to regulatory change, coordinated design decisions, and improved capacity planning. For EOIR systems, where optics and sensors must function as a unified system, this approach also improves performance consistency.
Domestic manufacturing as a differentiator
Domestic optical manufacturing is now a competitive differentiator in defense acquisition.
It signals long-term stability, reduces exposure to geopolitical disruption, and supports schedule confidence. Programs increasingly view domestic capacity as a form of risk mitigation rather than just policy alignment.
Implications for Space-Based and Emerging Platforms
Space-based EOIR systems face some of the most stringent constraints of any defense platform. Once launched, these systems cannot be serviced, repaired, or materially modified. Optical performance, material stability, and supply chain certainty must therefore be assured not just at deployment, but across decades of operational life. In this context, NDAA compliance is inseparable from mission assurance.
Space programs typically involve extended development timelines, early design freeze points, and long qualification cycles. Optical materials selected during initial architecture decisions may remain in use well beyond the 2030 NDAA deadline. Any future determination that a material or supplier is non-compliant could have severe consequences, including loss of mission capability or the need to redesign follow-on constellations at high cost.
As a result, space programs are increasingly conservative in material selection, favoring domestically produced or fully traceable optical materials even when commercial alternatives appear viable in the short term.
Emerging platforms such as autonomous systems, distributed sensing networks, counter-UAS solutions, and hypersonic vehicles introduce a different but equally challenging dynamic. These systems often demand compact, lightweight, high-performance EOIR payloads produced at scale.
As programs transition from experimental prototypes to operational deployments, supply chains must support higher volumes without introducing geopolitical risk. Optical materials that are viable for low-rate production may not be suitable for scaled deployment if they rely on constrained or foreign sources.
In both space and emerging platform contexts, NDAA compliance effectively shifts optics from a component-level concern to a platform-level risk consideration. Programs must evaluate whether their optical architectures can scale, sustain, and remain compliant over time. This is driving increased interest in materials and manufacturing approaches that support domestic production, consistent quality at volume, and long-term availability without reliance on adversarial supply chains.
Documentation and Audit Readiness
Programs that treat NDAA readiness seriously invest in robust documentation practices. This includes detailed bills of material, supplier certifications, configuration control, and internal audits. While this level of rigor may exceed current minimum requirements, it positions programs well as enforcement tightens.
In practice, audit readiness also requires close alignment between engineering, procurement, and quality teams. Optical material changes that might once have been treated as equivalent substitutions now require formal impact assessments, documentation updates, and, in some cases, customer notification. This has implications for engineering change orders, supplier change control, and long-term configuration management.
Programs that establish cross-functional governance around optical sourcing early are better positioned to manage these requirements without slowing development or production. By integrating compliance documentation into existing quality and configuration workflows, rather than treating it as a separate administrative task, defense teams can maintain both regulatory confidence and operational efficiency as NDAA oversight continues to mature.
How LightPath Approaches NDAA Readiness in Optical and Infrared Systems
NDAA compliance is most effective when it is built into optical and infrared systems from the earliest stages of design, rather than addressed as a downstream sourcing exercise. At LightPath Technologies, NDAA readiness is approached as a combination of material strategy, manufacturing control, and long-term program support.
A core element of this approach is vertical integration across optical materials, lens manufacturing, assemblies, and complete infrared systems. By maintaining in-house control over these stages, LightPath is able to provide clearer material traceability and reduce reliance on opaque, multi-tier supplier chains. This structure simplifies compliance documentation and allows program teams to better understand where materials originate and how they are processed.
Material selection plays a central role as well. LightPath has invested in proprietary infrared glass technologies designed to reduce dependence on geopolitically constrained materials while still meeting demanding EOIR performance requirements. These materials are engineered with both optical performance and manufacturability in mind, supporting consistent quality at scale and long-term availability for defense and aerospace programs.
Manufacturing location and capacity planning are also integral to NDAA readiness. LightPath continues to expand domestic glass melting and optical manufacturing capabilities to support defense demand, including large-format optics and advanced sensor programs. Multiple compliant manufacturing locations provide resilience against disruption and allow programs to plan for sustainment, spares, and future production blocks with greater confidence.
Equally important is early technical engagement. By working with customers during concept development and preliminary design, LightPath helps identify compliant material paths and optical architectures before designs are finalized. This reduces the likelihood of late-stage redesigns or requalification efforts driven by sourcing constraints.
Taken together, this approach supports defense teams that must balance performance, compliance, and long-term program risk. Rather than treating NDAA alignment as a discrete requirement, it is addressed as part of delivering optical and infrared systems that are ready for qualification, deployment, and sustainment over their full operational lifecycle.
Frequently Asked Questions
What does NDAA compliance mean for optical and infrared systems?
NDAA compliance requires defense programs to understand and control where optical glass, infrared materials, and optical systems originate. It extends beyond final assembly to include raw materials, intermediate processing, and manufacturing geography. Programs must be able to demonstrate that reliance on covered nations has been eliminated across the optical supply chain.
Does the NDAA prohibit all foreign optics?
No. It targets reliance on covered nations. Optics sourced from the US or allied countries are generally acceptable with proper documentation.
Are commercial off-the-shelf optics affected?
If used in defense systems and sourced from covered nations, they may introduce compliance risk.
Is germanium banned?
No. The concern is sourcing concentration and geopolitical exposure, not the material itself.
When should programs engage in compliance?
During concept development and early design, before architectures are locked.
Why is early compliance planning critical for EOIR programs?
EOIR systems often have long design and qualification cycles, with material choices locked in years before deployment. Addressing compliance early reduces the risk of redesigns, requalification testing, and schedule delays later in the program. Early planning also allows teams to evaluate alternative materials and architectures before constraints become costly.
How does material selection impact NDAA readiness?
Material selection directly affects compliance, scalability, and long-term sustainment. Materials with concentrated or geopolitically sensitive supply chains introduce risk over the life of a program. Programs increasingly evaluate infrared materials based on availability, traceability, and future capacity in addition to optical performance.
How should programs evaluate supplier compliance risk?
Supplier risk assessment should include visibility into material origin, manufacturing locations, and upstream dependencies. Programs benefit from working with suppliers that can clearly document provenance and maintain configuration control over time. Reduced reliance on opaque, multi-tier supply chains simplifies audits and compliance verification.
How does domestic manufacturing influence compliance outcomes?
Domestic manufacturing supports compliance by reducing exposure to geopolitical disruption and improving supply chain transparency. It also enables better control over quality, capacity planning, and sustainment support. For long-lived defense platforms, domestic capability is increasingly viewed as a form of program risk mitigation.
How does LightPath approach NDAA compliance for optical and infrared systems?
LightPath Technologies approaches NDAA readiness as an integrated part of system design and manufacturing. Compliance is evaluated across materials, lenses, assemblies, and complete systems, rather than at final integration alone. This approach supports clearer traceability and earlier identification of compliant design paths.
How does LightPath manage material provenance and traceability?
Material provenance is supported through vertical integration and direct control of optical manufacturing processes. By maintaining visibility into where optical materials are produced and processed, LightPath can support customer documentation needs during reviews and audits. This structure helps reduce uncertainty for programs operating under evolving compliance guidance.
How does LightPath support long-term program and sustainment needs?
Long-term availability and lifecycle support are central to compliance planning. LightPath emphasizes materials and manufacturing approaches that can be sustained over extended program timelines. This supports spares, repairs, and future production blocks without introducing new sourcing risks.
Closing Perspective
The NDAA’s inclusion of optical glass and optical systems marks a structural change in defense acquisition. Optics are now recognized as strategic technologies that demand the same level of scrutiny as electronics or propulsion systems.
Programs that treat compliance as part of system excellence will move faster, with less risk and greater confidence. Those who delay may find themselves constrained by decisions made years earlier. Early alignment between material choices, supplier partnerships, and system architecture is the most effective path to long-term readiness.
Defense and aerospace teams seeking deeper insight into NDAA-aligned optical materials, system design considerations, and long-term compliance planning can connect with LightPath Technologies to continue the conversation.
