PE-22: Component Marking

To meet the pe-22: component marking requirement, you must physically mark hardware components so personnel can immediately tell the impact level or classification level of information the component is allowed to process, store, or transmit ¹. Operationalize it by defining label rules, applying labels at receipt/build time, and proving the labels match your system’s data classification and authorization boundaries.

Key takeaways:

• Mark hardware components with the permitted information impact/classification level, not just an asset tag ¹.
• Make labeling part of procurement, receiving, imaging, and decommission workflows so it is repeatable.
• Retain evidence that ties each label to an approved classification decision and to the system boundary documentation.

PE-22 is a deceptively small control that fails in predictable ways: teams treat it as “asset tagging,” labels drift from the system’s actual authorization/classification posture, or components get swapped during maintenance and the markings never get updated. Auditors then see inconsistent labeling and conclude your physical security program is not reliably enforcing boundary conditions for where certain data types are permitted.

The requirement is straightforward: hardware components must be marked to indicate what level/classification of information they are allowed to handle ¹. That marking becomes an operational guardrail for IT operations, facilities, field support, and third parties who handle equipment. It also reduces the chance that a component approved only for lower-impact data ends up inside a higher-impact enclave (or the reverse) through routine moves, adds, and changes.

This page gives you requirement-level implementation guidance you can execute quickly: who owns it, where it fits into build/receive/change processes, how to decide what to mark, what evidence to retain, and what exam questions to expect. Where helpful, it also shows how to structure the control in your GRC system so you can produce consistent artifacts on demand (including with Daydream).

Regulatory text

Requirement (verbatim): “Mark {{ insert: param, pe-22_odp }} indicating the impact level or classification level of the information permitted to be processed, stored, or transmitted by the hardware component.” ¹

Operator interpretation (what you must do):

• You must place a visible marking on hardware components.
• The marking must communicate the maximum permitted information impact level or classification level for that component (for example, “High,” “Moderate,” “Low,” or an organizational classification scheme), aligned to what your organization has authorized that component to handle.
• The marking must be accurate through the component lifecycle: receipt, deployment, moves, maintenance, and disposal.

Practical point: PE-22 is about risk-limiting placement and handling of components. If the label only helps finance depreciation, it does not satisfy the intent.

Plain-English interpretation of the requirement

PE-22 requires “at-a-glance” identification of what data sensitivity a piece of hardware is approved to handle. Think of it as physical “data boundary metadata” attached to the component. A correct label helps prevent:

• Installing the wrong device into a restricted environment.
• Sending devices to the wrong repair channel.
• Storing spares from different impact/classification environments in the same cage without controls.
• Accidental cross-use during incident response or emergency replacement.

Who it applies to (entity and operational context)

PE-22 commonly applies to:

• Federal information systems implementing NIST SP 800-53 controls ².
• Contractor systems handling federal data where NIST SP 800-53 is contractually required ².

Operationally, it touches multiple teams:

• IT Asset Management (ITAM) and Configuration Management (asset records and change control).
• Security/GRC (classification mapping, boundary decisions, audit evidence).
• Data center operations / facilities (rack-and-stack, cage access, moves).
• Endpoint/field services (laptops, rugged devices, swap/repair logistics).
• Third parties who ship, store, or service your equipment (logistics, maintenance, OEM repair).

What you actually need to do (step-by-step)

1) Define the marking schema (your “label standard”)

Decide what the marking must convey and how it maps to your information authorization model:

• Label values: impact levels (High/Moderate/Low) or classification levels used in your program ¹.
• Scope: which hardware types require marking (servers, network devices, storage arrays, laptops, removable media encryptors, HSMs, IoT, etc.).
• Visibility rules: where the label is placed so it’s visible during installation and inventory without disassembly.
• Durability rules: tamper-evident labels for sensitive enclaves, and labels that survive expected environmental conditions.

Deliverable: a one-page “Component Marking Standard” that operations can follow without interpretation.

2) Establish ownership and workflow insertion points

Assign a single control owner (often Physical Security or IT Operations) and make other teams responsible for specific steps:

• Procurement/receiving: “no label, no deploy.”
• Build/imaging: apply label during staging.
• Change management: update label when reclassified or repurposed.
• Decommissioning: remove or deface labels as part of sanitization/disposal procedure to prevent misrouting.

In Daydream, model this as a control with mapped owners, procedures, and recurring evidence tasks so the artifacts regenerate each cycle without a scramble.

3) Map each component to an authorized boundary and permitted data level

You need a deterministic rule for how a component gets its label. Common approaches:

• System-boundary driven: the label is inherited from the system authorization package boundary where the component is deployed.
• Environment-driven: the label is inherited from the zone/cage/room classification.
• Purpose-driven exceptions: test benches, break-glass spares, or shared infrastructure get explicit approvals and distinct labels.

Minimum expectation: you can explain, for any labeled component, why that label is correct and who approved the classification decision.

4) Apply markings consistently at receipt/build time

Operational steps that work in practice:

• At receiving, create/verify the asset record, then print/apply the PE-22 label.
• At staging, validate the label matches the intended deployment environment before rack-and-stack.
• For endpoints, apply labels during imaging/kitting, then verify at handoff.

Add a “label check” to installation checklists so technicians do not bypass it.

5) Control label integrity during moves, maintenance, and repair

Most PE-22 failures happen after initial deployment.

• Moves/adds/changes: require a label verification step in the change ticket.
• Loaners/spares: store by label category; do not mix categories without a control (locked bins, separate cages).
• Repair: ensure shipping documents and RMA processes preserve the classification handling requirements implied by the label.

6) Audit with sampling and fix drift

Run periodic spot checks:

• Sample assets from each environment and compare physical labels to the inventory record and authorized boundary.
• Track exceptions: missing label, illegible label, wrong label, conflicting labels after component replacement.

Close gaps with corrective actions and update the standard if the drift is systemic (for example, too many device types not covered by the current scope).

Required evidence and artifacts to retain

Keep evidence that proves both design (you defined rules) and operation (you actually mark components).

Policy/procedure artifacts

• Component Marking Standard (schema, placement, durability, exceptions).
• Work instructions for receiving/staging/field services.
• Exception process (who can approve deviations and how they are documented).

Operational records

• Asset inventory exports showing label value fields (impact/classification attribute).
• Photos or inspection logs demonstrating labels on a sample of components (especially for data center gear).
• Change tickets showing label verification during moves/repairs.
• Decommissioning records showing labels handled appropriately at disposal.

Governance

• Control owner assignment and RACI.
• Training/technician acknowledgement that marking steps are required.

Daydream fit: store the standard, map owners, then schedule recurring evidence pulls (inventory export + inspection log + change-ticket samples) so audit packages stay current.

Common exam/audit questions and hangups

Expect assessors to probe these areas:

• “Show me your marking standard. What exactly gets marked and how?” ¹
• “Pick five servers in this cage. Do their labels match the authorized impact/classification of this environment?”
• “What happens when a device is repurposed from one system boundary to another?”
• “How do you prevent unlabeled spares from being installed during an outage?”
• “How do third parties (shippers/repair depots) know the handling requirements?”

Hangups:

• Confusion between asset tag and classification/impact marking.
• Inability to tie label values back to an approved boundary decision.

Frequent implementation mistakes (and how to avoid them)

1. Marking only the rack or room, not the component.
   Fix: if the requirement says “hardware component,” label the component itself ¹.

2. Labels drift after maintenance swaps.
   Fix: require label verification in change tickets and maintenance SOPs.

3. Too many label categories.
   Fix: keep categories aligned to your actual authorization model; add exceptions only with documented approvals.

4. No evidence beyond a policy.
   Fix: keep inspection logs/photos and inventory exports that demonstrate ongoing operation.

5. Ignoring third-party handling.
   Fix: embed label meaning into RMA/shipping instructions and third-party statements of work where they touch equipment.

Enforcement context and risk implications

No public enforcement cases were provided in the source material for PE-22. Practically, the risk is assessment failure and operational mishandling: incorrect placement of components can expand a system boundary unintentionally, cause data to be processed in an unauthorized environment, or lead to improper repair/disposal routing. Those outcomes create downstream noncompliance and incident exposure even if the initial gap looks like “just labeling.”

Practical 30/60/90-day execution plan

First 30 days (standards + ownership + quick wins)

• Assign control owner and publish a short Component Marking Standard aligned to impact/classification labeling ¹.
• Identify in-scope hardware categories and environments.
• Add a “label required” step to receiving and staging checklists.
• Pilot labels in one environment (data center row, restricted lab, or endpoint kitting line).

By 60 days (rollout + evidence generation)

• Roll out labels to remaining in-scope environments.
• Update change management templates to include label verification for moves/repairs.
• Train technicians and facilities staff on label meaning and handling.
• Start collecting repeatable evidence: inventory export with label fields plus inspection logs.

By 90 days (stabilize + audit readiness)

• Run a formal spot-check cycle and document findings/corrections.
• Tune exceptions and edge cases (spares, loaners, test benches).
• Package artifacts in your GRC system; in Daydream, map PE-22 to owners, procedures, and recurring evidence tasks so you can regenerate the audit packet on demand.

Frequently Asked Questions

Do virtual assets or cloud services need PE-22 markings?

PE-22 is explicitly about “hardware component” marking ¹. For cloud, focus on analogous controls (inventory, boundary, configuration), but don’t claim PE-22 coverage unless you can show how you mark the relevant physical components under your control.

Is an asset tag barcode enough to satisfy pe-22: component marking requirement?

Not by itself. The marking must indicate the impact level or classification level of information the component is permitted to process, store, or transmit ¹.

What components are “hardware components” for PE-22?

Treat it broadly: servers, network devices, storage, endpoints, appliances, and specialized security hardware when they can process/store/transmit sensitive data ¹. Define the exact scope in your marking standard and apply it consistently.

How do we handle components that move between environments (e.g., spares, loaners)?

Use a controlled exception path or dedicate spares by category. Operationally, require label verification at checkout/installation and keep spares physically separated by label class to reduce mix-ups.

Do we need to include the full classification (e.g., program name) on the label?

The text requires indicating the impact or classification level ¹. Keep labels minimal to avoid oversharing; store detailed mapping (system name, owner, boundary) in inventory records tied to the asset ID.

How do we prove ongoing compliance without photographing every device?

Use a repeatable sampling approach: inspection logs with a small photo set for representative assets, plus an inventory export showing label attributes and recent change tickets evidencing label checks. Auditors typically want proof of operation, not a photo archive of the entire fleet.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5