Industry Solutions

CMMC Compliance for Manufacturers

Manufacturing

Manufacturing companies working on defense contracts face a unique challenge: securing Controlled Technical Information (CTI) while maintaining uptime on legacy systems and shop-floor operations.

Between CMMC, International Traffic in Arms Regulations (ITAR), and Export Administration Regulations (EAR), compliance can’t wait, and it can’t interrupt your production.

Top CMMC Pain Points in Manufacturing

Export-Controlled Data

Controlled Unclassified Information (CUI) often includes ITAR/EAR-regulated content not just CMMC, but also U.S. person-based access rules.

Legacy Equipment

Shop-floor systems (Windows XP, MS-DOS, OT/ICS) break under traditional cybersecurity controls you need a solution that supports them.

Subcontractors

Sending CUI downstream triggers CMMC obligations for your vendors which is not always realistic.

Shared Teams

Enterprises often have global or non-U.S. cyber teams and tools therefore noncompliant by default.

Scoped Size or Teams

Only one or two plants might need compliance: how do you isolate without disrupting the rest?

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All-In
Enclave

All-In

Move your entire org into a fully compliant environment.

Complete migration to Government Community Cloud (GCC) High
Includes licensing, IT, security, and ongoing support
Seamless across desktops, networks, and users

Ideal for: Machine shops or Original Equipment Manufacturers (OEMs) fully dedicated to defense.

CUI Enclave

Isolate CUI users inside a secure environment without touching your larger business.

Microsoft Gov Cloud + virtual/physical desktops
Runs SolidWorks, Autodesk, ProShop and more
Links securely to shop floor without bringing Operational Technology (OT) in scope
Keeps commercial and defense work cleanly separated

Ideal for: Mixed businesses with a small defense footprint.

Frequently Asked Questions

How is CUI handled in manufacturing environments and G-code outputs?

CUI classification in manufacturing depends on whether technical data is present or derivable from outputs like G-code. While G-code itself may not explicitly be CUI, if it can be reverse-engineered to reveal controlled technical specifications, it may fall under CUI, or in many cases, under ITAR. Assessors will evaluate whether final parts or digital files contain embedded or inferable CUI. It’s essential to treat any potentially re-constructable data with caution and apply full CMMC controls as needed.

Can we use third-party vendors like heat treatment or plating shops without violating CMMC?

Potentially, but it depends on what they access. If these vendors are exposed to drawings, specs, or part numbers that qualify as CUI, they fall in scope under your CMMC obligations. Even if they only perform services like heat treating, the flow of controlled data must be considered. If CUI is shared, the vendor must either be part of your CMMC enclave or independently certified at the appropriate level. Supply chain risk management and flow-down enforcement are critical.

What’s the best way to scope an Enterprise Resource Planning (ERP) system used in manufacturing?

ERP systems are only out of scope if they truly don’t process, store, or transmit CUI. If the ERP links to CUI documents but does not hold them, it may be excluded. However, if it contains technical data (e.g., part specs or export-controlled details), even if not explicitly labeled, it is considered in scope. Misclassifying ERP systems is a common pitfall, and assessors will scrutinize these connections. Always validate with a proper CUI scoping engagement before excluding systems.

How can we protect sensitive drawings and specifications shared with subcontractors?

You must enforce strict control of all CUI shared externally. This includes encrypting files in transit and at rest, using Federal Risk and Authorization Management Program (FedRAMP)-authorized platforms, and ensuring access is limited to U.S. persons if ITAR applies. Additionally, you must include CMMC flow-down language in contracts, verify your subcontractors’ compliance posture, and maintain records of what data was shared and when. Without proper control, even a well-meaning subcontractor can create significant compliance risk.

Does GCC High support the types of Computer-Aided Design (CAD) and Cyber Asset Management (CAM) software we use?

Most CAD/CAM workflows can be supported in a GCC High environment, but third-party integrations may be limited. Microsoft GCC High is FedRAMP High and ITAR compliant, but not all commercial plug-ins or automation tools will work as expected. Careful planning is needed to ensure compatibility. File storage, version control, and identity management are handled securely, but native support for high-end CAD collaboration tools should be tested and validated early.

Can we achieve CMMC Level 2 certification while still using legacy machines or software?

Yes, but you’ll need to implement compensating controls. Legacy systems often lack native support for modern logging, access control, or patching. You’ll need to isolate them within the enclave, restrict network access, monitor their activity with external tools, and document any gaps along with how they’re mitigated. Simply having older systems doesn’t disqualify you, but assessors will expect a clear plan for securing and monitoring them under National Institute of Standards and Technology (NIST) SP 800-171.

What’s the best enclave design approach for small manufacturers?

Start with a narrow, scoped enclave that only includes systems and personnel who handle CUI. This allows you to protect critical data without overhauling your entire infrastructure. Summit 7 specializes in building these right-sized enclaves, often using Microsoft GCC High or Azure GovCloud environments to create isolated and compliant workspaces. Proper scoping prevents overinvestment and ensures clarity during assessments.

How does using a Private Equity (PE) firm affect our compliance status?

If the PE firm, or its employees, access your CUI systems or influence security decisions, they are considered External Service Providers (ESPs) and must meet compliance requirements. This was highlighted in a $1.75 million False Claims Act settlement, where a PE firm was penalized for providing access to foreign nationals without proper authorization. Even passive oversight can carry risk if it includes system visibility, data access, or policy influence.

Do ITAR and CMMC both apply to manufacturing, and how do they overlap?

Yes, frequently. ITAR governs the control of defense-related technical data, and that data is almost always classified as CUI. If you handle ITAR-controlled content, you must comply with both ITAR personnel restrictions (U.S. persons only) and CMMC Level 2 requirements for handling CUI. ITAR violations carry severe penalties, including criminal charges; so your CMMC strategy must be aligned with export control compliance from day one.

How can we future-proof our compliance posture without overhauling all systems?

Start by implementing Organization-Defined Parameters (ODPs) and updated practices from NIST SP 800-171 Rev 3, even though it’s not required yet. Focus on building your enclave architecture, documenting inherited controls from providers like Summit 7, and assigning internal responsibility for each control. Using GCC High or Azure GovCloud gives you a scalable platform, and a phased approach with strong documentation ensures that as requirements evolve, you’re already aligned.

Featured Case Study

RIB U.S. Cost Gains CMMC Confidence with Summit 7’s Managed GRC, Commander

“The Commander team worked closely with my cybersecurity analysts to make sure we had the policies and procedures in place to meet CMMC requirements.”

– Suzanne Moltzen, CEO of RIB U.S. Cost

Read the Story

Testimonials

When I tell big-name defense contractors we’re working with Summit 7, there’s a sigh of relief. That’s a huge advantage.

Matt GustafsonPresident, Clinkenbeard

I have been working with these guys since years now! With lots of hard work and timely communication they made sure they delivered the best to me. Highly recommended!

John DoeCompany Name

When I tell big-name defense contractors we’re working with Summit 7, there’s a sigh of relief. That’s a huge advantage.

Matt GustafsonPresident, Clinkenbeard

When I tell big-name defense contractors we’re working with Summit 7, there’s a sigh of relief. That’s a huge advantage.

Matt GustafsonPresident, Clinkenbeard

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CMMC Compliance for Manufacturers

Choose Your Industry

Manufacturing

Top CMMC Pain Points in Manufacturing

Export-Controlled Data

Legacy Equipment

Subcontractors

Shared Teams

Scoped Size or Teams

Speak with an Expert

CMMC Solutions for Manufacturing

All-In

CUI Enclave

Frequently Asked Questions

RIB U.S. Cost Gains CMMC Confidence with Summit 7’s Managed GRC, Commander

Testimonials

Speak With Our Team