Anti counterfeit and risk mitigation documents and procedures are becoming too common. Unfortunately it’s because of the growing number of counterfeit electronic parts. This is especially troublesome in the areas of defense.
Terms that you should be familiar with:
- DOD – Department of Defense
- DODI – Department of Defense Instruction
- DFARS – The Defense Federal Acquisition Regulation Supplement
- GIDEP – Government-Industry Data Exchange Program
- DARPA – The U.S. Defense Advanced Research Projects Agency
- SHIELD – Supply Chain Hardware Integrity for Electronics Defense
In an article written in 2013 – The Department of Defense (DOD) has issued a new instruction that establishes internal DOD policies for detecting, avoiding, and re-mediating counterfeit parts in the DOD supply chain, and allocates responsibility among various DOD offices and functions for administering or developing those counterfeit prevention policies. Department of Defense Instruction (DODI) 4140.67, titled “DoD Counterfeit Prevention Policy,” was issued on April 26, 2013, and it represents the next step in the federal government’s efforts to deal with the epidemic of counterfeit parts that led to the inclusion of a provision specifically targeted at counterfeit electronic parts in the fiscal year 2012 National Defense Authorization Act (NDAA). That statutory provision — Section 818 of the 2012 NDAA — requires DOD to adopt regulations that would impose far-reaching counterfeit prevention obligations on defense contractors, including provisions that would describe how contractors are to establish or validate so-called “trusted suppliers.”
Key provisions of the DODI include:
- Definitions of “counterfeit” and “suspect counterfeit”
- Definition of “authentic material”
- Counterfeit prevention policies encompass all parts, not just electronic parts, and include software and information technology
- Absence of reference to “covered contractors”
- Stated goal of avoiding “DOD-unique” counterfeit prevention procedures
- DOD intention to issue “standardized guidelines” for contractors to use in their quality systems to detect and avoid counterfeit parts
- DOD intention to establish counterfeit-related “qualification criteria” for suppliers
- DOD will use GIDEP as the system for reporting suspect and confirmed counterfeit material
- Emphasis on restitution for discovery of counterfeit parts in delivered items
- “Risk-based approach” to DOD’s internal counterfeit prevention policies
Click here to read the full article.
Additional articles and policies related to anti counterfeit and risk mitigation –
- Allied Electronics – Counterfeit product mitigation
- Digi-Key – 5 do’s and don’ts of procurement risk mitigation
- Mouser Electronics – Anti-Counterfeit parts Risk Mitigation
- TTI – DOD’s Anti-Counterfeiting Battle Plan; DARPA Seeks a Tech Solution
- Quest Components – Counterfeit mitigation policy
- SBA (Small Business Administration) – Prevention and Guidance
- Counterfeiting: The Rising Threat to Electronics Manufacturers