FAQ
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IUID Frequently Asked Questions
- What resources are available to assist with IUID implementation?
- How will the additional cost of implementing IUID be addressed, specifically for small businesses that supply DoD?
- Is IUID training available?
- What if a supplier is not ready or able to comply with the IUID requirements?
- Will waivers or exceptions to IUID be granted?
- Does the IUID requirement apply to any of the following?
- According to the guidance, IUID is required at the component level based on a program manager determination. What if we do not have a Program Manager?
- Does IUID require manufacturing drawings to be changed?
- How should a UII be constructed for surplus, remanufactured, or overhauled items?
- Does IUID apply to Contractor Logistics Support (CLS) contracts?
- Will the UII replace the NSN? Will the UII be used in place of part numbers in publications?
- If a contractor elect to mark all of its serialized items as part of its internal business rules or strategies, which may mean delivering marked items in addition to those required by a contact, is this acceptable to the Government?
- Can a prime contractor direct their vendors to use their (prime's) EID on the items the vendor produces for the prime to deliver to the Government or would the vendor need to use their own EID since they are the one's actually manufacturing the item?
- How is the acquisition cost of an item valued?
- How are the data elements required for item unique identification placed on the item?
- How are the data elements for unique item identification structured so they are machine-readable?
- How do you decide when to place data elements for item unique identification on items?
- What exactly is Wide Area Workflow (WAWF) and how do we report IUID data in it?
- How is the unique item identifier (UII) to be used in automated information systems?
- What is the difference between Radio Frequency Identification (RFID) and Item Unique Identification (IUID)?
For further inquiries, please email defensepolicysupport@ebpsc.org
- What resources are available to assist with IUID implementation?
The DoD does not endorse any specific vendors of materials or services designed to support IUID implementation. Many commercial vendors of solutions and products are accessible via the internet. AIM Global, the Association for Automatic Identification and Mobility, consists of a number of member companies that provide marking products and services, including labels. Regardless of which solution your company selects, the marking will need to conform to MIL-STD-130 requirements.
Back to Top - How will the additional cost of implementing IUID be addressed, specifically for small businesses that supply DoD?
DoD has determined that it is a strategic imperative that items valued at or above $5,000, or meeting other specified conditions, be marked with unique identification. There are no exceptions. Small businesses will find there are a number of vendors, many of them small businesses, which can provide unique identification marking assistance. DoD considers the cost of implementing unique identification requirements to be an allowable cost under FAR Part 31.
Back to Top - Is IUID training available?
Visit the Training and Communication page for a listing of the latest training opportunities, including UID Policy Office sponsored UID Forums, Defense Acquisition University modules, and IUID Toolkit tutorials.
Back to Top - What if a supplier is not ready or able to comply with the IUID requirements?
The September 3, 2004 policy memorandum recognized that situations may arise where small businesses and vendors of commercial products are not prepared to comply with DoD IUID requirements within the cost constraints and/or time frames required for product deliveries. Should this occur, DoD requiring activities whose acquisition will be conducted under the regulations in FAR Part 8 or Part 12 may consider implementing a strategy under which the requiring activity would either: (1) coordinate and fund the furnishing of product IUID data plates, labels or other marking media that meets MIL-STD-130 requirements, including durability, to the commercial vendors for application to products before shipment, or (2) contract with third parties to furnish and apply the IUID markings after product delivery from the commercial vendors. This strategy should only be implemented if significant cost or schedule advantages would accrue to the Department and a determination and findings has been conducted
Back to Top - Will waivers or exceptions to IUID be granted?
The rule is considered to be a strategic imperative, necessary to efficiently move supplies to warfighters. The IUID DFARS final rule outlines the scenarios under which exceptions may occur, including exceptions for (1) items which, as determined by the head of the agency, are to be used to support a contingency operation or to facilitate defense against or recovery from nuclear, biological, chemical, or radiological attack; or (2) a determination and findings has been executed concluding that it is more cost effective for the Government requiring activity to assign, mark, and register the unique item identification after delivery of an item acquired from a small business concern or a commercial item acquired under FAR Part 12 or Part 8. CAE approval is required for ACAT 1D programs and the HCA approval for ACAT II, ACAT III, and non-ACAT programs. These are not exceptions to the IUID requirement itself. Items granted an exception will have to be marked by the Government under legacy implementation efforts.
Additionally, DCMA, as part of its Single Process Initiatives may grant near-term extensions of IUID implementation if they are consistent with the implementation schedules of the negotiated corporate/facility strategies.
Back to Top - Does the IUID requirement apply to any of the following?
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a. Not-for-profit contracts such as research contracts with universities? Yes
b. Classified items? Yes
c. Foreign Military Sales? Yes
d. Small businesses? Yes
e. Government Furnished Property? Yes
f. Software, manuals, etc.? No
g. DLA requests? Yes
- According to the guidance, IUID is required at the component level based on a program manager determination. What if we do not have a Program Manager?
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.
Back to Top - Does IUID require manufacturing drawings to be changed?
Drawings will be changed in accordance with contract provisions, or in their absence, contractor practice. Generally, any markings to be placed on an item are required to be detailed in the technical documentation. The policy requires that IUID markings comply with the provisions of MIL STD 130. The UID Policy Office has developed a guide focused on the non-recurring engineering issues, accessible at http://www.acq.osd.mil/dpap/UID/attachments/guides/uid-engdocguidever1_2-20070416.pdf
Back to Top - How should a UII be constructed for surplus, remanufactured, or overhauled items?
If the item does not already have IUID and meets the criteria for IUID, the enterprise furnishing the item to the Government must provide UII marking as part of the purchase price. In situations where subcontractors 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 IUID requirements prior to furnishing to the Government, either by flowing down the requirements to the subcontractor or by marking the items themselves.
Back to Top - Does IUID apply to Contractor Logistics Support (CLS) contracts?
Yes. IUID policy does apply to CLS programs when the contract will result in the delivery of tangible items to the DoD. If the contract supports end items that are the property of the Department, when the Component pays for the end item, it constitutes delivery and acceptance. The DFARS indicates that the contracting officer is to put the IUID clause in the contract if the contract will result in the delivery of an end item to the Department. In most cases, CLS contracts will result in such deliveries. However, please keep in mind that IUID is only for items and does not include services.
Back to Top - Will the UII replace the NSN? Will the UII be used in place of part numbers in publications?
The UII will not replace the NSN or part number. NSNs and part numbers reflect more of the form, fit, and function of an item and remain somewhat static over time. A UII is unique to the item, is used only for uniquely identifying that item among other items, and does not reflect what the item's purpose is.
Back to Top - If a contractor elect to mark all of its serialized items as part of its internal business rules or strategies, which may mean delivering marked items in addition to those required by a contact, is this acceptable to the Government?
Yes. Additional item marking is acceptable. Note that all IUID-marked items, including additional items beyond those required by contract, must be registered in the IUID Registry upon Government acceptance of the items into DoD inventory.
Back to Top - Can a prime contractor direct their vendors to use their (prime's) EID on the items the vendor produces for the prime to deliver to the Government or would the vendor need to use their own EID since they are the one's actually manufacturing the item?
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. 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).
Back to Top - How is the acquisition cost of an item valued?
It is the policy of the Department of Defense that Contractors shall be required to identify the Government's unit acquisition cost (as defined in DFARS 252.211-7003(a)) for all items delivered even if none of the criteria for placing a IUID mark applies.
For fixed price type line, subline, or exhibit line items, the unit acquisition cost is the unit price identified in the contract at the time of delivery.
For cost type contracts [or undefinitized] line, subline, or exhibit line items, the unit acquisition cost is the contractor's estimated fully burdened unit cost to the Government at the time the item is delivered.
For items delivered under a time-and-materials contract, the unit acquisition cost is the contractor's estimated fully burdened unit cost to the Government at the time of delivery.
The Government's unit acquisition cost of subassemblies, components, and parts embedded in delivered items need not be [separately] identified.
An end item may be composed of embedded items, such as subassemblies, components and parts. The prime contractor will pass down appropriate specifications, including the IUID marking requirements, to the tiered vendors for subcontracted subassemblies, components and parts.
Spares may be purchased directly from the vendors or through the prime. IUID-qualifying spare items (subassemblies, components and parts) have to be marked appropriately with the IUID data elements.
So, when the prime delivers the end item-that is one UII. The spares are delivered with their own UIIs. The Government has the option of asking the prime to deliver a list of all UIIs for IUID-qualifying embedded items in the end item.
Back to Top - How are the data elements required for item unique identification placed on the item?
The IUID component data elements, at a minimum, shall be contained in a Data Matrix symbol, as required by the latest version of MIL-STD-130. Data may be contained in other AIT media (e.g., contact memory buttons, linear bar codes, radio frequency identification, etc.) in addition to the Data Matrix. The physical marks that contain the IUID-required elements shall remain legible until the item is destroyed.
Back to Top - How are the data elements for unique identification structured so they are machine-readable?
For the IUID data elements to be machine-readable by any AIT device, they must be identified by some means such that the reader device can recognize, through its resident software, what data element it is reading. This is accomplished by employing the concept of semantics, which is literally "the meaning of language."
For the purposes of constructing machine-readable data elements, semantics take the form of data qualifiers. There are three types of data qualifiers used to encode UIIs: Application Identifiers (AIs, Format Indicator 05), Data Identifiers (DIs, Format Indicator 06), and Text Element Identifiers (TEIs, Format Indicator 12). Data qualifiers define each data element placed on the item to tell the AIT devices how to derive the unique item identifier.
ISO/IEC International Standard 15418, Information Technology - EAN/UCC Application Identifiers and ASC MH 10 Data Identifiers and Maintenance, governs AIs and DIs. Air Transport Association (ATA) Common Support Data Dictionary (CSDD) defines TEIs. ISO/IEC International Standard 15434, Information Technology - Syntax for High Capacity ADC Media, governs Data Matrix syntax, which is the order the data elements, data qualifiers, and overhead characters are placed in the code string.
Please see the DoD Guide to Uniquely Identifying Items for further discussion.
Back to Top - How do you decide when to place data elements for item unique identification on items?
Strategies that produce the greatest business advantage for the items at the lowest cost and in the shortest possible time should be considered. The question of how this could be done leads to a conclusion that the probable scenario would be a mixture of vendor-applied-at-source, opportunity-based, seek-and-apply, and gated strategies. Requiring vendor-applied-at-source on future contracts for new equipment, major modifications, and reprocurements of end items and spares is important for sustainment, but has limited impact on a retrospective application program.
Vendor-applied-at-source provides a relatively inexpensive and unobtrusive application option for future purchases; however, it will not provide the speed of response necessary to successfully implement a retrospective application program for legacy items.
Opportunity-based item application can be done in the field or factory, wherever it is convenient to gain access to items either on an end item or available in a storage facility. Projected situations or processes where this might be deployed include phase maintenance, scheduled servicing, depot rebuild or overhaul processes, and work-order processes during modification.
The seek-and-apply strategy can be used for particular items in operational use, either at the end item or in storage. This strategy is dependent on establishing the location and availability of items before deployment of application equipment and teams. The location of items can be determined through the supply chain management information systems and inventory control systems. This approach is dependent upon good legacy data, and will demand greater overhead of coordinated effort to effect access to the assets. By concentrating application efforts, the advantage is faster fielding of configuration management for specific items.
The interception of items as they transit specific gates within the supply chain can ensure no item enters service without the data elements needed to construct a unique identifier. Having identified an item at the gate which requires a unique identifier, the situation can be resolved by either diverting the item back to the vendor for application, provision of an application capability at the specific supply gate, or diversion of the item to a centralized application facility.
Back to Top - What exactly is Wide Area Workflow (WAWF) and how do we report IUID data in it?
Wide Area Workflow is a paperless contracting environment. It enables contractors to transmit shipping notices electronically and DoD to perform both receipt and acceptance electronically. Resources can be found on the web at http://www.wawftraining.com/ and https://wawf.eb.mil.
Please see the Data Submission Information Page for details on submitting IUID data in WAWF
Back to Top - How is the unique item identifier (UII) to be used in automated information systems?
In the Service or Agency material management and supporting automated information systems (AISs, developed or maintained in compliance with FMMP/FMEA requirements), once the UII is created from the separate data elements placed on the item, the UII shall not be parsed to determine the original elements, since parsing and recombination of the elements will invariably result in the introduction of errors in the UII. However, the UII, the enterprise identifier, the serial number and (in the case of Construct #2) the original part number will be captured separately at the time of inspection and acceptance.
The UII shall be a primary pointer or key data element for traceability in all computational functions including inventory acceptance, item accountability, storage, issue, receipt, valuation, maintenance, and disposal.
Back to Top - What is the difference between Radio Frequency Identification (RFID) and Item Unique Identification (IUID)?
Within IUID, the unique item identifier (UII) is a piece of data associated with an item that uniquely identifies it throughout its life. RFID is a vehicle for holding and sharing data.
IUID of tangible items deals with physical markings applied directly (or indirectly via label, data plate, etc.) on items. IUID also requires data to be captured about the item and submitted electronically to a registry database. Think of this as creating a birth certificate for the item.
RFID is either a passive (unpowered) or active (powered) transmitter/receiver that stores information on the case, pallet, or packaging in which IUID'd and non-IUID'd items are placed. The RFID tag may store the unique item numbers for the items in the case/pallet/package or it may store a different unique packaging number that when accessed in a transportation or logistics database provides an inventory of the items in the case, pallet, or package.
Please visit the DoD RFID website for further information on the RFID initiative at http://www.acq.osd.mil/log/rfid/index.htm
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