This means that the mandate will be contractual, or in other words, compulsory. Until now suppliers who were tagging their shipments, like Honeywell or Lockheed Martin, were doing it on a voluntary basis.

However, this DFARS concerns only two RFID-enabled military depots out of the 16 depots that DoD want to be RFID-enabled : Defense Distribution Depot (DD) Susquehanna, PA and DD San Joaquin, CA. According to the final rule, DoD suppliers who send material to these two military depots need to apply RFID Tags at the case and palletized unit load levels when shipping “packaged operational rations, clothing, individual equipment, tools, personal demand items, or weapon system repair parts” which designate three classes and one subclass of the DOD’s 10 supply classifications.

It is going to take time before the mandate becomes really effective. According to the Office of Management and Budget this Federal Acquisition regulation becomes effective 60 days from the publication date of the announcement in the Federal register, therefore 14 November 2005. The clause will be written in all new contracts that take effect after Nov. 13. Moreover for supplier whose contracts have to be reviewed after Nov.13 contract officers will still go through negotiations to determine whether the RFID mandate will be included in the reviewed contract.

Kathy Smith, special assistant in the DOD’s Office of Supply Chain Integration, said that on top of extending the number of RFID-enabled military depots to 16, DoD wants to add more supply classes to the list of tagged products. However, no timeline were mentioned.

DoD suppliers have been aware of the upcoming RFID mandate for nearly two years. We will see now who is ready for it and what are the consequences for those who are not.

“DoD considers the implementation of RFID to be a strategic imperative, necessary to deliver supplies to the warfighter more quickly, while increasing visibility of materiel throughout the supply chain. To create an automated and sophisticated end-to-end supply chain, the DoD is dependent upon initiating the technology at the point of origin, the DoD commercial suppliers. Without the assistance of DoD supplier base to begin populating the DoD supply chain with passive RFID tags, a fully integrated, highly visible, automated end-to-end supply chain is untenable.”

Download the 74-page DoD analysis:

Final Regulatory Flexibility Analysis of Passive Radio Frequency Identification (PDF, 1.1 Mb)