Final DFARS rule on Detection and Avoidance of Counterfeit Electronic Parts (Section 818)

The rule requires that CAS-covered contractors take steps to prevent, detect, report and correct suspect or actual counterfeits in the Defense Supply Chain. To do so, “[t]he contractor is responsible for establishing a risk-based (see our past blog posts!!) counterfeit detection and avoidance system with the amount of risk based on the potential for receipt of counterfeit parts from different types of sources.” 79 Fed. Reg. 26096. The system must address the 12 criteria set forth in 252.246- 7007:

  1. Training of personnel.
  2. Inspection and testing of electronic parts, including criteria for acceptance and rejection.
  3. Process to abolish counterfeit parts proliferation.
  4. Processes for maintaining electronic part traceability that enable tracking of the supply chain back to the original manufacturer and that include certification and traceability documentation, identification of supply chain intermediaries from manufacturer to the direct product source to the seller, and, if available, the manufacturer’s batch identification for the parts such as date codes, lot codes or serial numbers.
  5. Purchase of electronic parts from the original manufacturer or sources with express written authority of the original manufacturer or current design activity, including authorized aftermarket manufacturers or suppliers, or, where parts are out of production and no longer available from these sources, use of suppliers that meet applicable counterfeit detection and avoidance system criteria.
  6. Reporting and quarantining of counterfeit electronic parts and suspect counterfeit electronic parts.
  7. Methodologies to identify suspect counterfeit parts and to rapidly determine if a suspect counterfeit part is in fact counterfeit.
  8. Design, operation and maintenance of systems to detect and avoid counterfeit electronic parts and suspect counterfeit electronic parts.
  9. Flow down of counterfeit detection and avoidance requirements, including applicable system criteria provided in the rule, “to subcontractors at all levels in the supply chain that are responsible for buying or selling electronic parts or assemblies containing electronic parts, or for performing authentication testing.”
  10. Process for keeping continually informed of current counterfeiting information and trends and using such for “continuously upgrading internal processes.”
  11. Process for screening GIDEP reports and other credible sources to avoid purchasing or use of counterfeit electronic parts.
  12. Control of obsolete electronic parts in order to maximize availability and use of authentic, originally designed and qualified electronic parts throughout the product’s life cycle.

Click here for the full register.



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