The question is twofold. 1) What should the classification of a repairable item be? The items received in are not all up systems so it doesn t seem like they meet the equipment definition. If the repairable items received in were in a production environment they would be classified as material because they would be in process of going into a next higher assembly but since they are not in a production environment, would that alter their classification?
2) The second question pertains to classification being part of the record elements. Since classification is not listed as a required data element in 52.245-1, are contractors required to have it as a data element in their records? If not, what is the requirement for providing data by classification.
After conversing with Repairables management subject matter experts, a contracts professor, the author of this Ask-A-Professor question and the Federal Acquisition Regulation (FAR) Part 52.245-1 regarding management of government property, the following response is submitted:
1) The FAR does not specify the classification criteria of a repairable item -- in this case components/materials used to repair/assemble a Target Acquisition and Designation Sight/Pilot Night Vision Sensor (TADS/PNVS). FAR Part 52.245-1 provides a definition for material in that it "...means property that may be consumed or expended during the performance of a contract, including component parts of a higher assembly, or items that lose their individual identity through incorporation into an end-item..."
With regard to whether the material and/or Repairables having to be listed as a data element in your records, recommend consulting the contract, applicable Administrative Contracts Officer, Defense Contract Management Agency Rep, etc. for it is a matter that is beyond the purview of the AAP program.