On August 13, 2026, President Trump released a new presidential memorandum titled “Rebuilding the United States Navy and America’s Shipbuilding Industrial Base.” In keeping with many themes of the second Trump administration, the memorandum and accompanying fact sheet continue to emphasize a desire to revitalize U.S. shipbuilding capacity for both military and commercial vessels. This presidential memorandum flows from and further builds upon numerous other orders and directives from the Trump administration, such as the Maritime Action Plan, aimed at enhancing the U.S. maritime industrial base and creating investment opportunities in U.S. shipyards.

Of particular note, the presidential memorandum directs the Department of Defense/War to engage in further review of investment and procurement methods for domestic shipbuilding, including a review of the so-called “Finland model,” which was implemented by the U.S. Coast Guard in its construction of icebreakers in 2025. That icebreaker procurement allowed for foreign construction of U.S. icebreakers in exchange for both technical expertise as well as investment by foreign companies into the U.S. maritime industrial base. That model followed similar actions by the Biden administration via the trilateral Icebreaker Collaborative Effort (ICE) Pact entered into by the United States, Finland, and Canada in 2024.

The presidential memorandum expands the Finland model to additional vessel classes, and would allow a foreign shipyard to construct U.S. naval vessels if the foreign entity:

• Builds a new shipyard in the United States or assumes ownership or a majority equity position in an existing U.S. shipyard and builds all ships after the first two vessels in U.S. shipyards.
• Hires and trains an American citizen workforce for U.S. shipyards.
• Licenses proprietary shipbuilding techniques and technologies used at the foreign shipyard to U.S. shipyards.
• Sources a U.S. supply chain for construction and maintenance of all ships at the U.S. shipyards.

The memorandum further directs the Department of Defense/War to submit, within 90 days, a plan to implement the Finland Model framework for the acquisition and construction of both Consolidated Cargo Replenishments at Sea (CONSOL) tankers as well as Roll-On/Roll-Off (Ro-Ro) vessels. This represents a significant shift in U.S. procurement of vessels, with potential for foreign shipyards to gain greater footholds in U.S. naval acquisition with commensurate investments in U.S. shipbuilding capabilities in the medium- to long-term.

In addition to the foregoing, the presidential memorandum also includes a number of other key provisions relevant to the U.S. shipbuilding sector:

• Establishment of a fifth public Navy Yard to specifically address nuclear-powered submarine and aircraft carrier readiness.
• Enhancement of the submarine repair industrial base through the creation of a Component Repair Center to be housed proximate to major road, rail, and river transportation networks to service the Los Angeles, Virgina, Seawolf, Ohio, and Columbia classes.
• Reform Naval Sea Systems Command (NAVSEA) organization and structure, with an emphasis on results-based accountability for the delivery of vessels and the elimination of iterative design changes on original mature parent designs.

Cozen O’Connor’s Transportation & Trade group continues to monitor all activities relating to developments in the U.S. maritime industrial base as well as the administration’s priorities regarding U.S. shipbuilding. Please contact the authors of this alert with any questions.