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Counterfeit PartsStandards and CertificationsDale K GordonAS&D Accreditation Manager20 JUL 2016

TopicsCounterfeit Parts Standards What’s it all About?Existing StandardsDefinitionsApplicationsCertification Programs AS5553 AS60812

What’s it all about?The U.S. Department of Commerce’sBureau of Industry and Security (BIS)released a study in 2010 that quantifiedthe extent of of counterfeit electronicparts into U.S. defense supply chainsThe BIS study documented a growth inincidents of counterfeit parts across theelectronics industry from 3,300 incidentsin 2005 to more than 8,000 incidents in20083

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ELECTRONIC WASTE IS A CONTRIBUTING FACTOR6. Parts shipped backto the U. S.5. Parts arerepackaged and resold1. E-waste shippedfrom the U.S.2. Received indeveloping country(China)4. Parts are remarkedand refurbished3. Parts removed fromNext Higher Assemblies/ Circuit BoardsSource: SMT CorporationCLIO-67-115UNCLASSIFIEDPage 5

INTERNET IS A CONTRIBUTING FACTORThe growth of internet sales hasyielded unprecedentedopportunities for profiteers to find amarket for counterfeit productsA check, in 2012, of a popular Internet parts search enginefound a glut of counterfeits of an integrated circuit (randomlyselected from an obsolete parts listing) that had beendiscontinued in 1998. In fact, more sources were listed on thissite for parts date coded 2001 or later than during the part’sproduction range of 1998 or earlierPage 6

What’s it all about?Aircraft 11972F-161978RetirementNot determined2040 (maybe)Not determinedNot determinedNot determinedNot determinedObsolescence creates an opportunity / market for Counterfeit7

What’s it all about?In 2012 the U.S. Government enacted laws requiringregulations for contractor responsibilities for detectionand avoidance of the use of counterfeit electronicpartsDFARS 252.246–7007 “Counterfeit Electronic PartDetection and Avoidance System” was issued in 2014The US government is also proposing to expand theabove to include a new clause, Sources of ElectronicParts, whenever procuring— Electronic parts; End items, components, parts, or assembliescontaining electronic parts; or Services, if the contractor will supply electronicparts or components, parts, or assembliescontaining electronic parts as part of the service.8

PREVENTION: RISK MITIGATION PROCESS AND ACTIONSPage 9

Counterfeit PartsStandardsNew and Improved?10

SAE Int’l CP StandardsARP6178 Counterfeit Electronic Parts;Tool for Risk Assessment ofDistributorsAS6171 Test MethodsStandard; CounterfeitAS6496 Authorized Electronic PartsDistributor CounterfeitMitigationAS6081 Counterfeit ElectronicParts Avoidance – IndependentDistributorsAS6301 Fraudulent/Counterfeit ElectronicAS6174 CounterfeitParts: Avoidance, Detection, Mitigation, andMateriel; AssuringDisposition – Independent DistributorsAcquisition of AuthenticVerification Criteriaand Conforming MaterielAS5553 CounterfeitElectronic Parts; Avoidance,Detection, Mitigation, andDispositionAS6462 Verification Criteria forCertification against AS555311

Other CP StandardsIEC/TS 62668-1 Process Management for Avionics –Counterfeit prevention – Avoiding the use of counterfeit,fraudulent and recycled electronic componentsIEC/TS 62668-2 Process Management for Avionics - Counterfeitprevention - Managing electronic components from nonfranchised sourcesU.S. DoD MIL-STD-3018 - Parts ManagementU.S. DoD MIL-STD-11991A - General Standard for Parts,Materials, and ProcessesUK MOD Def Stand 05-135 - Avoidance of CounterfeitMaterielIDEA-STD-1010 Acceptability of Electronic ComponentsDistributed in the Open Market12

Revision Status of Standards SAE AS5553A to B – ballot soon SAE AS6171 not published – ballot soon SAE AS6174A to B – in revision SAE AS6081A to B – in revision SAE AS6301 – Published 2014 SAE AS6496 – Published 2014Revisions for some to incorporate Assessment sheets13

Counterfeit PartsDefinitionsThere are A LOT of them too!14

Counterfeit Part DefinitionsU.S. Defense Federal Acquisition Regulation 202.101Counterfeit electronic part means an unlawful orunauthorized reproduction, substitution, or alterationthat has been knowingly mismarked, misidentified, orotherwise misrepresented to be an authentic, unmodifiedelectronic part from the original manufacturer, or a sourcewith the express written authority of the originalmanufacturer or current design activity, including anauthorized aftermarket manufacturer. Unlawful orunauthorized substitution includes used electronic partsrepresented as new, or the false identification of grade,serial number, lot number, date code, or performancecharacteristics.

Counterfeit Part DefinitionsSAE Int’l AS5553A and AS6081AA fraudulent part that has been confirmed to be a copy,imitation, or substitute that has been represented,identified, or marked as genuine, and/or altered by asource without legal right with intent to mislead, deceive,or defraud.SAE Int’l AS6174AFraudulent materiel that has been confirmed to be a copy,imitation or substitute that has been represented,identified, or marked as genuine, and/or altered by asource without legal right with intent to mislead, deceiveor defraud.

Counterfeit Part DefinitionsThe UK Defence Standard definitionMateriel whose origin, age, composition,configuration, certification status or othercharacteristic (including whether or not the materielhas been used previously) has been falselyrepresented by:a) misleading marking of the materiel, labelling orpackaging;b) misleading documentation; orc) any other means, including failing to discloseinformation;except where it has been demonstrated that themisrepresentation was not the result of dishonesty bya supplier or sub‐supplier within the supply chain.

Counterfeit Part DefinitionsAS5553 Rev. B (proposed)(1) an unauthorized a) copy, b) imitation, c)substitute, or d) modified materiel or EEE part,which is knowingly, recklessly, or negligentlymisrepresented as a specified genuine itemfrom an authorized manufacturer; or(2)a previously used materiel or EEE part whichhas been modified and is knowingly, recklessly,or negligently misrepresented as new withoutdisclosure to the customer that it has beenpreviously used.

Counterfeit Part DefinitionsPROPOSED NEW DEFINITION AS9100An unauthorized copy, imitation, substitute, ormodified part, which is knowingly misrepresented asa specified genuine part of an original or authorizedmanufacturer.Note: Examples of a counterfeit part (e.g., material,part, component) can include, but are not limited to;the false identification of marking or labeling, grade,serial number, date code, documentation orperformance characteristics.Similar to AS5553 B proposal

Counterfeit Parts ControlRequirementsThere are A LOT of them too!20

Requirements in DFAR 252.246.70071.The training of personnel.2.The inspection and testing of electronic parts3.Processes to abolish counterfeit parts proliferation.4.Processes for maintaining electronic part traceability5.Use of suppliers that are the original manufacturer, or[an authorized supplier]6.Reporting and quarantining of counterfeit electronicparts and suspect counterfeit electronic parts7.Methodologies to identify suspect counterfeit parts andto rapidly determine if a suspect counterfeit part is, infact, counterfeit21

Requirements in DFAR 252.246.70078.Design, operation, and maintenance of systemsto detect and avoid counterfeit electronic partsand suspect counterfeit electronic parts9. Flowdown of counterfeit detection andavoidance requirements10. Process for keeping continually informed ofcurrent counterfeiting information and trends11. Process for screening GIDEP reports and othercredible sources of counterfeiting information toavoid the purchase or use of counterfeitelectronic parts.12. Control of obsolete electronic parts22

AS 6174A ‐ Assuring Acquisition ofAuthentic and Conforming MaterielScopePurpose This document standardizes requirements, practices, and methods related to: (a)materiel management, parts management, supply chain management,procurement, inspection, test/evaluation to assure the authenticity andconformance of materiel being acquired, and (b) response strategies when suspector confirmed counterfeit materiel is discovered. This standard was created to provide uniform requirements, practices and methodsto improve the likelihood of only acquiring authentic and conforming materiel ofany type in any industry sector.Applicability Suppliers, processors, and end product organizations.Supply ChainSector Any industry sector.Commodity(s)Covered All materials and parts except electronic, electrical &electromechanical (EEE).23

AS6496‐ Authorized Distribution CPMitigationScopePurposeSupply ChainApplicabilityCommodityCovered Authorized Distributor when performingAuthorized Distribution. Practices to procure, authenticate, trace andminimize risk of CP in authorized supply chain Authorized Distributor Activities AD Customers to understand what to expect from AuthorizedDistribution Electronic parts—electronic components,assemblies, supplies and equipment24

8.1.4 Counterfeit Part Prevention9100 / 9110 / 9120The organization shall plan, implement and control a process,appropriate to the product, that prevents the use of counterfeit orsuspect counterfeit product and their inclusion in product(s) deliveredto the customer.NOTE: Counterfeit product prevention processes should consider: training of appropriate persons in the awareness andprevention of counterfeit product; application of a parts obsolescence monitoring program; procurement requirements for assuring traceability of parts andcomponents to their original authorized manufacturers; verification and test methodologies to detect counterfeitproduct; monitoring of counterfeit product reporting from externalsources; quarantine and reporting of suspect or detected counterfeitproduct.Deliberately modeled after the DFAR 7007 items.

91xx 8.4.2 Control of ExternalProvidersVerification activities of externally providedprocesses, products, and services shall beperformed according to the risks identified bythe organization. These shall includeinspection or periodic testing, as applicable,when there is high risk of nonconformitiesincluding counterfeit parts. Added requirement for inspection or testingwhen there is a risk of counterfeit parts beingprevalent (9100/9120)

91xx 8.4.3 Information to External ProvidersThe need to:(9100) prevent the use of counterfeit parts(see 8.1.4);The need to:(9120) prevent the use of suspectedunapproved, unapproved, andcounterfeit parts (see 8.1.4 & 8.1.5);Nothing for 9110

91xx 8.7 Control of NonconformingOutputsNOTE: The term “nonconforming outputs” includessuspected unapproved, unapproved, counterfeitand nonconforming product or service generatedinternally, received from an external provider, oridentified by a customer. (9120)Counterfeit, or suspect counterfeit, parts shallbe controlled to prevent reentry into the supplychain. (9100/9120)Unsalvageable and counterfeit parts shall beconspicuously and permanently marked, orpositively controlled, until physically renderedunusable to prevent restoration. (9110)

Counterfeit Quarantine Issue Depending on what the counterfeit itemis and where in the supply chain the itemis discovered and affect the quarantineissue. Words crafted to allow for neededflexibility to cover all products. 9100 and other standards always ‘defer’to contractual requirements such asDFAR requirements which would takeprecedence.

Counterfeit PartsCertification ProgramsA work in progress30