Companies supplying electronic parts or assemblies into the DoD supply chain can encounter specialized counterfeit-part requirements. These obligations can reach lower tiers and can apply even where a business would otherwise think of its product as commercial.
Before accepting the flowdown, determine what the company actually buys, sells, tests, or incorporates—and whether its supplier controls can produce the records the clause expects.
DFARS 252.246-7007 reaches lower tiers
DFARS 252.246-7007 requires covered contractors to maintain a counterfeit electronic part detection and avoidance system with specified process elements. Its subcontract paragraph requires the substance of the clause in subcontracts, including subcontracts for commercial products, for electronic parts or assemblies containing electronic parts.
Official source: DFARS 252.246-7007 — Counterfeit Electronic Part Detection and Avoidance System.
The system is broader than visual inspection
- Training personnel involved in counterfeit-part prevention.
- Inspection and testing processes appropriate to the risk.
- Traceability of parts to suppliers.
- Use and qualification of trusted suppliers.
- Reporting and quarantining suspect or counterfeit parts.
- Flowing appropriate requirements to lower-tier suppliers and authentication testers.
- Monitoring current counterfeit information and obsolete-part risk.
Map the supply chain before signing
A reseller, integrator, repair provider, or service contractor that furnishes electronics may need a different control model than a manufacturer. Identify which suppliers can provide traceability, where brokers are used, who performs authentication, and how suspect parts are isolated and reported.
Do not accept an undefined prime-specific system by reference
If the prime adds its own approved-vendor list, testing standard, portal, or reporting procedure, obtain those documents before pricing compliance. A generic promise to follow all current and future prime counterfeit-part policies can create an unpriced moving target.