UID Compliance - Policy

Policy

Department of Defense Instruction (DoDI) 5000.64 mandates that the following tangible items are marked with an item unique identifier:

• All delivered items for which the Government’s unit acquisition cost is $5,000 or more

• Items for which the Government’s unit acquisition cost is less than $5,000, when identified by the requiring activity as serially managed, mission essential, or controlled inventory;
  • Serially Managed - When DoD elects to serially manage an item it becomes "DoD serially managed". This means it is a tangible item used by DoD, which is designated by a DoD, or Service Item Manager to be uniquely tracked, controlled or managed in maintenance, repair and/or supply by means of its serial number.
  • Mission Essential - A measure of an item's military worth in terms of how its failure (if a replacement is not immediately available) would affect the ability of a weapon system, end item, or organization to perform its intended functions. (DoD 4140.1-R)
  • Controlled Inventory - Those items that are designated as having characteristics that require that they be identified, accounted for, segregated, or handled in a special manner to ensure their safeguard and integrity. Includes classified items (require protection in the interest of national security), sensitive items (require a high degree of protection and control due to statutory requirements or regulations, such as precious metals; items of high value, highly technical, or hazardous nature; and small arms), and pilferable items (items having a ready resale value or application to personal possession, which are especially subject to theft) (DoD 4140.1-R); and safety controlled items.

• Items for which the Government’s unit acquisition cost is less than $5,000, when the requiring activity determines that permanent identification is required; and

• Regardless of value—
  • Any DoD serially managed subassembly, component, or part embedded within a delivered item; and
  • The parent item (as defined in 252.211-7003(a)) that contains the embedded subassembly, component, or part.

Responsibility - Oftentimes, the question of responsibility for IUID comes into light when multiple organization are involved in the production and/or procurement of items. According to the guidance, IUID is required at the component level based on a program manager determination. Program managers should be interpreted as any activity member who manages the requirement for procurement of an item. This would include personnel such as Integrated Support Team Managers, Systems Managers, or Item Managers.

The prime contractor is responsible for ensuring uniqueness. The prime contractor can direct their vendors to use the prime's EID. However, from a manufacturing process perspective, this may not be the most efficient and effective way for their vendors to mark parts. If the item does not already have unique identification and meets IUID criteria, the enterprise furnishing the item to the Government must provide unique item identification marking as part of the purchase price. In situations where sub-contractors are furnishing items to the prime contractor, it is the responsibility of the prime contractor to ensure that the items are marked in accordance with the IUID requirements prior to furnishing to the Government, either by flowing down the requirements to the subcontractor or marking the item themselves. The prime will also have the added responsibility of ensuring uniqueness of the subcontractor's serial number within the prime's enterprise (Construct #1) or the subcontractor's serial number within the subcontractor's part number within the prime's enterprise (Construct #2).