President Trump Signs Memorandum for Major Navy Shipbuilding Overhaul

President Donald Trump on August 13, 2026, signed a presidential memorandum, "Rebuilding the United States Navy and America's Shipbuilding Industrial Base," identifying a shipbuilding industrial base in crisis. According to the directive, the U.S. Navy faces backlogs across six major shipbuilding programs due to overly complex ship designs, iterative design changes imposed mid-construction, and a lack of capacity and competition among domestic shipyards. The commercial shipbuilding sector, the memorandum notes, is "not globally competitive," contributing to an atrophied industrial base that has increased delivery delays and driven up costs.

This memorandum builds on a series of prior presidential actions:

• Executive Order 14269 (April 9, 2025). Established the policy framework for restoring America's maritime dominance, including creation of the Office of Maritime and Industrial Capacity at the National Security Council
• The White House Fact Sheet (April 9, 2025). Outlined the Trump Administration's goal of achieving the largest increase in naval strength since President Ronald Reagan and the largest investments in the U.S. Coast Guard in history
• Finland Memorandum of Understanding (MOU) (October 2025). Established the model for foreign participation in U.S. shipbuilding under the MOU with Finland for the construction of a medium icebreaker
• Maritime Action Plan (February 2026). Released a comprehensive strategy for rebuilding maritime capacity, including nearly $9 billion for Arctic security cutters authorized through the Working Families Tax Cuts (see Holland & Knight's previous alert, "White House Releases America's Maritime Action Plan," February 25, 2026)

For additional analysis, see Holland & Knight's previous alert, "White House Unveils Historic Maritime Budget: What It Means for America's Shipping Future," April 15, 2026.

The "Finland Model": A New Paradigm for Shipbuilding Competition

The most consequential provision of the memorandum is its expansion of the "Finland Model" – first implemented through the October 2025 icebreaker MOU – into a broader acquisition framework for naval and strategic sealift vessels. Under this approach, foreign shipbuilders may participate in U.S. government vessel programs provided they satisfy four core conditions:

• Domestic Investment. Build a new shipyard in the United States or acquire majority equity in an existing U.S. shipyard, and construct all vessels after the first two in domestic yards
• American Workforce. Hire and train American citizen workers
• Technology Transfer. License proprietary shipbuilding techniques to U.S. shipyards
• Supply Chain Localization. Source materials and components from the U.S. supply chain

The memorandum delegates to the U.S. Department of War Secretary the authority to make national security interest determinations and provide required congressional notifications under 10 U.S.C. § 8679, streamlining what has historically been a cumbersome approval process.

Ro-Ro Vessels and Strategic Sealift: A Critical Priority

Significantly for the strategic sealift and defense logistics sectors, the memorandum directs the Secretary of War to submit, within 90 days, a plan for acquiring Consolidated Cargo Replenishments at Sea (CONSOL) tankers and Roll-on/Roll-off (Ro-Ro) vessels using the Finland Model framework. This is the first time a presidential directive has specifically mandated a competitive acquisition strategy for Ro-Ro vessels under this innovative foreign participation model.

Ro-Ro vessels are essential to the U.S. military's power projection capability, enabling the rapid deployment of wheeled and tracked vehicles, heavy equipment and outsized cargo to theater. The current Ready Reserve Force fleet of Ro-Ro ships has aged significantly, and the need for recapitalization has been identified in multiple U.S. Government Accountability Office reports and congressional studies. By directing their acquisition under the Finland Model, the Trump Administration is simultaneously addressing the sealift capacity gap and leveraging the program to attract foreign shipbuilding expertise and capital investment into the U.S.

For sealift operators, logistics companies and defense transportation providers, this creates a dual opportunity: participation in vessel construction programs and potential long-term charter or operating arrangements for the new Ro-Ro fleet. Companies with existing Ro-Ro expertise – whether in vessel design, operations or cargo handling systems – should monitor the forthcoming acquisition plan closely.

New Surface Combatant Competition

The memorandum also directs, within 90 days, a new competitive acquisition approach for surface combatants dedicated to antisubmarine warfare, surface warfare and convoy escort duties. Significantly, the directive prohibits the Navy from imposing iterative design changes on parent ship designs; any modifications must receive the personal approval of the Secretary of War. This provision directly responds to the cost overruns and schedule delays that have plagued programs such as the littoral combat ship and Constellation-class frigate.

The emphasis on proven parent designs and design stability represents a significant shift in naval acquisition – one that may favor shipbuilders that can offer mature, sea-proven platforms over those proposing clean-sheet designs.

Return to Steam and Hydraulic Systems on Carriers

In a notable technology decision, the memorandum directs the Secretary of War to provide, within 60 days, a plan to replace the Electromagnetic Aircraft Launch System (EMALS) and Advanced Weapons Elevators on CVN-81 (the next Ford-class carrier) with traditional steam catapults and hydraulic weapons elevators. This decision reflects the Trump Administration's position that these advanced systems have caused unacceptable delays and reliability issues on the USS Gerald R. Ford (CVN-78) and in construction of the USS John F. Kennedy (CVN-79).

5th Public Navy Shipyard

Within 120 days, the memorandum directs development of a plan to establish a fifth public Navy shipyard – the first new public yard in more than 80 years. The facility would focus on nuclear submarine and aircraft carrier depot-level maintenance and be located near the Pacific Fleet, with candidate locations covering the continental U.S., Alaska, Hawaii and U.S. territories. The plan must include up to three new drydocks capable of servicing all submarine classes and explore public-private partnership financing options.

This initiative represents a significant opportunity for construction firms, engineering companies and infrastructure investors. The public-private partnership component suggests the government is open to innovative financing structures that could attract private capital into what has traditionally been a purely government-funded enterprise.

Component Repair Center

Within 90 days, the Secretary of War must submit a plan to establish a Component Repair Center to receive new and refurbish old submarine components. The center must be geographically centralized near road, rail and river transportation networks and maintain spare equipment for the Los Angeles- Virginia- Seawolf- Ohio- and Columbia-class submarines. This presents opportunities for industrial maintenance providers and component manufacturers serving the submarine supply chain.

NAVSEA Reform

The memorandum requires a 120-day review of Naval Sea Systems Command (NAVSEA) focused on results-based accountability, reducing bureaucracy, eliminating competing priorities and preventing the iterative design changes that have plagued Navy shipbuilding programs. For industry, this signals a potential streamlining of the notoriously complex NAVSEA oversight and approval processes that add cost and delay to shipbuilding contracts.

Practical Implications for Industry

• Foreign Shipbuilders and Stakeholders: The Finland Model creates a defined pathway for international shipbuilders and stakeholders – particularly those with Ro-Ro, tanker or combatant expertise – to enter the U.S. market. However, the requirements for domestic facility investment, American workforce hiring, technology licensing and supply chain localization may represent substantial commitments. Foreign firms with design capabilities should evaluate opportunities to strengthen domestic naval architecture and marine engineering programs. European Ro-Ro vessel owners and operators, for example, could advance the memorandum's objectives by partnering with U.S. shipyards to transfer proven and mature vessel designs and operational expertise, investing in domestic workforce training programs or establishing joint ventures that leverage their Ro-Ro fleet management experience to support U.S. sealift capacity expansion. Similarly, companies with tanker construction or operational experience bring valuable expertise to a vessel class critical for underway replenishment capabilities.
• Domestic Shipyards: Existing U.S. shipyards may benefit from increased demand and potential foreign partnership or investment. At the same time, the Finland Model introduces new competitive dynamics that could challenge incumbents. Yards should evaluate their positioning for the forthcoming Ro-Ro, CONSOL tanker and surface combatant competitions.
• Vessel Sealift and Logistics Operators: The directed acquisition of Ro-Ro vessels under an accelerated timeline creates opportunities for domestic and foreign vessel owners and operators with strategic sealift experience. Companies should position themselves for potential operating agreements, crew provision and maintenance contracts associated with the new fleet. Early engagement with relevant congressional committees overseeing defense authorization and appropriations can help demonstrate how foreign participation aligns with U.S. strategic objectives while ensuring sustained program funding.
• Defense Contractors: The prohibition on iterative design changes and emphasis on parent designs may shift competitive dynamics, favoring contractors with proven, stable platforms. The surface combatant competition and carrier technology decisions could reshape subcontractor and supplier relationships.
• Supply Chain Companies: The Finland Model's requirement for U.S. supply chain sourcing, combined with the Component Repair Center initiative, will drive demand for domestic manufacturers of ship components, submarine parts and maritime systems.

Key Deadlines

• 60 Days (approximately October 12, 2026): Plan for replacing EMALS and Advanced Weapons Elevators on CVN-81
• 90 Days (approximately November 11, 2026): New competitive acquisition approach for surface combatants; plan for CONSOL tankers and Ro-Ro vessels under the Finland Model; plan for Component Repair Center
• 120 Days (approximately December 11, 2026): Plan for fifth public Navy shipyard; NAVSEA reform review

Conclusion and Next Steps

This presidential memorandum represents the most prescriptive and action-oriented naval shipbuilding directive in decades. By applying the Finland Model to Ro-Ro vessels and CONSOL tankers, opening surface combatant competitions, establishing a fifth naval shipyard and reforming NAVSEA, the Trump Administration is simultaneously addressing near-term readiness gaps and building long-term industrial capacity.

Industry stakeholders should:

• monitor the 90-day deadline for the Ro-Ro and CONSOL tanker acquisition plan, which will define the competitive framework and qualification requirements under the Finland Model
• assess partnership and investment opportunities with foreign shipbuilders seeking to establish a U.S. presence
• evaluate positioning for the surface combatant competition, particularly firms with mature parent designs
• track the fifth shipyard site selection process and public-private partnership opportunities
• engage with congressional oversight activities related to the significant policy shifts embedded in this memorandum

Holland & Knight's Public Policy & Regulation Group and Maritime Team continue to monitor these developments closely. For more information, please contact the authors.

Information contained in this alert is for the general education and knowledge of our readers. It is not designed to be, and should not be used as, the sole source of information when analyzing and resolving a legal problem, and it should not be substituted for legal advice, which relies on a specific factual analysis. Moreover, the laws of each jurisdiction are different and are constantly changing. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. If you have specific questions regarding a particular fact situation, we urge you to consult the authors of this publication, your Holland & Knight representative or other competent legal counsel.