By Jim Will, Defense Opinion Writer.
The Department of Defense’s “commercial-first” directive aligns with longstanding defense procurement practices, with every major defense system now relying heavily on commercial-off-the-shelf (COTS) electronics.
But the challenge is ensuring COTS electronics can be scaled, surged and, most importantly, trusted as one element within a broader, deliberate national strategy.
Today’s commercial electronics ecosystem is overwhelmingly concentrated in Asia and increasingly dominated by China. This exposes U.S. defense capabilities to supply denial, counterfeiting, malicious tampering and chronic long lead times.
Key COTS component families, such as microcontrollers, power management integrated circuits (PMICs) and radio frequency (RF) modules, often have lead times of 20 weeks to 52 weeks. An Indo-Pacific conflict, contested logistics or geopolitical disruption could further exacerbate lead times and restrict access to components essential to the sustainment of U.S. ships, aircraft, munitions, missiles, platforms and unmanned aerial vehicles (UAVs).
Attritable UAVs, for example, rely entirely on COTS electronics. These low-cost drones are designed to be produced rapidly and at high volume due to their expendable nature. During a conflict, replenishment must occur in weeks and requires a rapid, reliable COTS supply. Scenario analysis indicates that a supply chain disruption collapses UAV replenishment capacity, slowing recovery by months and leaving the U.S. without enough eyes in the sky.
Long lead times for COTS components are severely straining DoD’s ability to surge and scale beyond just attritable UAVs, and they’re quietly reshaping sourcing behavior. Sub-tier suppliers operate under constant schedule and cost pressure, choosing whatever COTS parts are available and affordable. That dynamic drives demand toward less-assured Asian and particularly Chinese sources. Without a broader national electronics strategy to develop assured domestic and allied capacity, including COTS, DoD’s commercial-first posture will default to potentially adversarial supply chains.
Hardwiring an assured supply chain
The U.S. already has substantial electronics foundry, packaging and test capacity that’s been bolstered by government and industry investment through initiatives like the Creating Helpful Incentives to Produce Semiconductors (CHIPS) for America Act, Industrial Base Analysis and Sustainment (IBAS) and Defense Production Act (DPA) Title III. A national electronics strategy will ensure COTS component families are built using trusted domestic and allied manufacturers, supported by recognized, commercially adopted, standards-based assurance and traceability frameworks, hardwiring scale, capacity and surge capability into the supply chain.
The first step in developing a national strategy for COTS electronics is the systematic identification of at-risk COTS electronics families across defense and dual-use systems, particularly those where global supply is concentrated in Asia or directly influenced by Chinese-controlled firms. This risk assessment should combine bill-of-materials analysis, supplier dependency mapping and a forward-looking view of technology nodes that are most vulnerable to disruption.
The next step is surveying and mapping domestic and allied foundry capabilities that can support the at-risk COTS electronics families. This means making sure designs match the specific “factory rulebooks” used for different types of chips, such as analog, digital, mixed-signal, RF and power, so they can be fabricated. The core task is to match each at-risk device class with a foundry process that can produce an electrically equivalent part using fully transparent and assured supply chains.
Packaging, testing evaluation
In parallel, packaging and test capabilities must be evaluated. This includes identifying domestic and allied providers with suitable ultra-high-density interconnect (UHDI) substrate, advanced packaging and test services with the explicit goal of shifting away from Asia-dominant supply chains.
Substrate manufacturing and modified semi-additive process/UHDI capabilities are especially important since many modern COTS devices can’t be properly packaged or connected without substrates. Domestic packaging houses, trusted outsourced semiconductor assembly and test providers, and emerging allied facilities must be cataloged and aligned to the component roadmap.
The next stage is designing, building, packaging and testing assured COTS equivalents that match the electrical, functional and interface behavior of widely used but less-assured commercial parts. These components must meet dual-use reliability expectations as defined by their commercial datasheets while considering military-specific requirements that could impact affordability or scale.
Distribution through cleared companies
Finally, assured COTS components should be distributed through certified companies that serve defense and commercial sectors. They unify demand, simplify access and create the volume flows that make domestic and allied COTS production economically viable. By pushing assured parts through these distribution channels paired with procurement incentives or buyer-directed requirements, the U.S. can build a commercially grounded path to scale rather than relying solely on defense-unique purchasing behavior.
Assured COTS electronics are essential for scale and surge capacity across all defense systems. A national electronics strategy can establish assured domestic and allied supply chains, aggregate demand, reduce dependency on Asia, provide predictable lead times and improve supply chain resilience. COTS is one important component of this broader effort.
Commercial first only works if commercial is available and assured. The key to achieving both is aligning the U.S. and its allies under a national electronics strategy.
With over 30 years of experience in the semiconductor and microelectronics industry, Jim Will is executive director of the U.S. Partnership for Assured Electronics. He has held leadership roles across defense and commercial industry, focused on supply chain and assured microelectronics.
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