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Key Takeaway

  • DFARS 252.211-7006 is a clause that governs the use of passive radio frequency identification (RFID) tags for certain shipments to the U.S. Department of Defense, requiring contractors to affix readable RFID tags to specified packages and electronically submit advance shipment notices
  • The standardization of labeling and identification requirements for shipments is becoming increasingly important across all industries as warehouse automation and software integrations continue to connect critical aspects of the supply chain. Particularly for the military industry, there has been a recent, aggressive push to adopt the latest in technology while, at the same time, provide guidance and additional requirements for its use in the logistics loop. 

    With the growing adoption of Radio Frequency Identification (RFID) tags, the U.S. Department of Defense (DoD) has released specific requirements for their use within the defense sector. One particularly important regulation that military subcontractors and suppliers need to be aware of is DFARS 252.211-7006, a clause which impacts the practice of passive RFID tagging. This post will explain what these requirements are and how they fit into the overall labeling procedures for certain types of material military shipments.

    What is DFARS 252.211 7006?

    The Defense Acquisition Regulations Supplement (DFARS) is a series of requirements maintained by the U.S. Department of Defense that government acquisition officers and third-party contractors must follow in procuring military goods and services. One of these requirements is DFAR 252.211-7006, which pertains to passive radio frequency identification

    Who Must Follow This Requirement?

    Suppliers who have a contract with the DoD are the ones who most often deal with this requirement. In particular, the suppliers who have a written agreement or contract which contains the DFARS 252.211-7006 clause or which specifically requires RFID tags must affix them to the bulk package (case and palletized units). DFARS stipulations apply when the following requirements are met:

    • The shipped item falls into one of the following categories:
      • Subclass of Class I – Packaged operational rations.
      • Class II – Clothing, individual equipment, tentage, organizational tool kits, hand tools, and administrative and housekeeping supplies and equipment.
      • Class IIIP – Packaged petroleum, lubricants, oils, preservatives, chemicals, and additives.
      •  Class IV – Construction and barrier materials.
      • Class VI – Personal demand items (non-military sales items).
      • Subclass of Class VIII – Medical materials (excluding pharmaceuticals, biologicals, and reagents – suppliers should limit the mixing of excluded and non-excluded materials).
      • Class IX – Repair parts and components including kits, assemblies and subassemblies, reparable and consumable items required for maintenance support of all equipment, excluding medical-peculiar repair parts.
    • The item is being shipped to an RFID-enabled location, a location outside the U.S which is assigned Transportation Priority 1, or to a location deemed necessary for RFID in your contract.  
    • There are exceptions made for bulk commodities and for certain shipment locations that include the clause at FAR 52.213-1 for fast payment procedures. 

    Although the above requirements have been carefully set by the DoD, it should be noted that they may shift in unique situations, such as uncommon or potentially dangerous goods. If a supplier finds itself in this situation, special stipulations must be agreed upon and included in the contract.

    Passive RFID Tag Placement

    For required shipments, contractors must affix a readable passive RFID tag on each specific level of package at the appropriate location. The specifications for tag placement are defined in Section 4.9.2 of MIL-STD-129. Data encoded on each tag must be globally unique (meaning never repeated on two or more tags) and be programmed in accordance with the EPC Tag Data Standards

    Special Tag Programming Identifiers

    There are two tag identifiers that are accepted for shipments. If the contract subscribes to EPCglobal and has a unique EPC company prefix, they may use any identifiers described in the EPC Tag Data Standards and follow those instructions. Contractors who use the DoD identifier must use its previously assigned Commercial and Government Entity (CAGE) code and follow the instructions in the DoD Suppliers’ Passive RFID Information Guide. If contractors utilize a third party to encode their RFID tags, the CAGE code of that supplier is acceptable. 

    Advance Shipment Notices

    Advance Shipment Notices

    Contractors must use Wide Area WorkFlow (WAWF), as required by DFARS 252.232-7003, to electronically submit an advance shipment notice (ASN) with the associated RFID tag ID(s) listed or other item unique identification (IUID) information, including information such as a product description, the physical characteristics of the product, the type of packaging and markings used, carrier information, and other details. 

    For additional details about the specific procedures to be used, you can consult the WAWF website. It is very important to ensure that this ASN is submitted before the shipment arrives at the depot for processing. Otherwise, the RFID tag(s) cannot be read and will be flagged as non-compliant. 

    Complying with the many regulations for unique item identification and item tracking requires implementing clear, comprehensive processes and procedures. Camcode offers customized UID compliance services, including data management for your Unique Item Identifiers (UIIs), IUID registration with WAWF, and other services to help you meet the requirements of MIL-STD-130 and other military standards. With more than 60 years of experience in defense labeling and automatic identification technology, our experienced staff can guide you through your UID project to ensure accurate and unique identification for every item.

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