All presently used batteries contain reactive, corrosive or toxic components and require strong cases, usually made of steel. As a battery is miniaturized, the required case dominates its size. Hence, the smallest manufactured batteries are about 50 mm3 in size, much larger then the integrated circuits or sensors of functional analytical packages, as exemplified by implantable glucose sensors for diabetes management. The status of the miniaturization of the power sources of such implantable packages is reviewed. Three microcells, consisting only of potentially harmless subcutaneously implantable anodes and cathodes, are considered. Because their electrolyte would be the subcutaneous interstitial fluid, the cells do not have a case. One potentially implantable cell has a miniature Nafion-coated Zn anode and a biocompatible hydrogel-shielded Ag/AgCl cathode. The core innovation on which the cell is based is the growth of a hopeite-phase Zn2+ conducting solid electrolyte film on the discharging anode. The film blocks the transport of O2 to the Zn, preventing its corrosion, while allowing the necessary transport of Zn2+. The second cell, with the same anode, would have a bioinert hydrogel-shielded wired bilirubin oxidase-coated carbon cathode, on which O2 dissolved in the subcutaneous fluid would be electroreduced to water. In the third cell, the glucose of the subcutaneous interstitial would be electrooxidized to gluconolactone at an implanted wired glucose anode, similar to that tested now for continuous glucose monitoring in diabetic people, and O2 in the subcutaneous fluid would be electroreduced to water on its wired bilirubin oxidase cathode.