Overview
If you build, supply, or overhaul industrial machinery, generators, pumps, material handling equipment, or ground support equipment for the military, your purchase orders, drawings, technical manuals, and delivery records are Federal Contract Information. That triggers FAR 52.204-21 and a CMMC Level 1 self-assessment with an annual SPRS affirmation.
Equipment supply and overhaul is usually Level 1 because the work is build to print or repair from unmarked packages. A specific program reaches Level 2 only when a prime flows down DFARS 252.204-7012 and sends marked technical data.
These shops run on an ERP or MRP system, engineering and service stations, and an email tenant. Level 1 covers the systems that hold program FCI, which means named accounts, MFA, controlled access to drawings and manuals, and a clean boundary.
Typical contracts you'll see
- Subcontracts and direct buys for machinery, generators, and pumps
- Material handling and ground support equipment contracts
- Equipment overhaul, rebuild, and repair contracts
- DLA buys for machinery parts and assemblies
- GSA and SEWP supply of industrial equipment
What FCI actually looks like for you
Anything below is Federal Contract Information and triggers FAR 52.204-21. None of it is CUI on its own.
Common pitfalls in this industry
- Storing drawings and manuals on an open share readable by everyone, which fails FAR 52.204-21 (b)(1)(iii).
- Running the ERP or service system on a shared login, which fails (b)(1)(i) and (ii).
- Emailing POs and drawings from personal accounts, which fails (b)(1)(iii).
- Assuming heavy equipment work is out of scope. The FCI in the paperwork is what triggers CMMC.
- Missing a real -7012 flow-down on a specific program.
- Letting the annual SPRS affirmation lapse.
Your Level 1 action plan
- 01Confirm with each prime or agency whether any -7012 flow-down applies and whether marked technical data is in play.
- 02Inventory the systems that hold program FCI: ERP or MRP, engineering and service stations, the file share, email, and backups.
- 03Move PO and drawing exchange onto a paid Microsoft 365 or Google Workspace tenant with MFA enforced.
- 04Give every engineer and service tech a named account and set drawing and manual access to least privilege.
- 05Separate program systems from public web browsing and the company website.
- 06Write a short boundary description naming the systems that hold program FCI and who can access them.
- 07Run the 15 practice self-assessment, capture evidence, then have a senior official affirm the score in SPRS and set the annual reminder.
Most common NAICS codes
Use these when searching SAM.gov, filing for set-asides, or checking size standards.
- 333120Construction Machinery Manufacturing
- 333611Turbine & Turbine Generator Set Units Manufacturing
- 333924Industrial Truck, Tractor, Trailer & Stacker Machinery Manufacturing
- 333998All Other Miscellaneous General Purpose Machinery Manufacturing
- 811310Commercial & Industrial Machinery & Equipment Repair & Maintenance
Frequently asked questions
Q.We just supply generators to a base. Do we need CMMC?
Yes, once you hold a federal contract or subcontract. The purchase orders, drawings, manuals, and delivery records are Federal Contract Information, and FAR 52.204-21 applies to the systems that hold them. The 15 practices are basic protections on your ERP and email, not on the equipment.
Q.When would equipment work be Level 2?
When a prime flows down DFARS 252.204-7012 and sends technical data explicitly marked as CUI or Controlled Technical Information for a specific program. General machinery supply and overhaul from unmarked packages stays at Level 1.
Q.Are our technical manuals FCI or CUI?
Manuals you produce or receive under the contract are FCI unless they are explicitly marked as CUI. Look for a CUI banner and category. If something should be marked but is not, ask the contracting officer rather than assuming.
Q.Do I need an SSP at Level 1?
No. Level 1 does not require a System Security Plan under 32 CFR Part 170. You need evidence the 15 practices are met for the systems that handle FCI, plus a short boundary description and a current list of authorized users.
Related clauses
Related terms
Read more in the Library
- CMMC Level 1: All 15 FAR Safeguarding Requirements Explained in Plain English (2026 Guide)Every CMMC Level 1 safeguarding requirement, in language a non-cybersecurity founder can act on — what each control means, what evidence satisfies it, and where teams trip up.
- CMMC Level 1: The Complete 2026 Guide for Small DoD ContractorsThe single page to read first. What CMMC Level 1 is, who it applies to, what's actually required, what it costs, and the fastest honest path through it in 2026.
- How to Do CMMC Level 1 Yourself (Free, Complete Guide) — 2026CMMC Level 1 is self-assessed. You don't need a consultant. Here is the entire DIY path, with every template you'll need, written for the small defense contractors actually doing the work.
- CMMC Level 1 Scoping — How to Draw the Boundary (Free Worksheet) — 2026Treating the whole company as in-scope doubles your work for no compliance benefit. Here's the right way to scope CMMC Level 1.
- What to Tell Your Prime When They Ask for Your SPRS Score (And You're Level 1)If your prime is asking for a 0–110 SPRS score and you're a Level 1 contractor, the answer is not zero. It's that you're a different tier of the regulation. Here's how to say that without losing the contract.
- CMMC Level 1 vs Level 2: Which One Do You Actually Need? (2026 Plain-English Guide)Most small defense contractors are Level 1, not Level 2 — but the wrong answer here costs you a year and tens of thousands of dollars. Here's the single question that decides it.