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Unregulated E-Waste Keeps the Counterfeiters’ Funnel Full

Kristal Snider
07/18/2016

It is 2016: fifteen years since China was admitted to the WTO and the first counterfeit part was reported to ERAI; a decade since ERAI’s President made a second trip to China to see firsthand how e-waste was being used to fuel what has been referred to as a counterfeit epidemic; and nine years since I wrote ...

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DOD Needs to Improve Reporting and Oversight to Reduce Supply Chain Risk

Anne-Liese Heinichen
02/12/2016

This report by the United States Government Accountability Office (GAO) examines the use and effectiveness of GIDEP with regard to counterfeit part reporting, DOD’s efforts in the detection of counterfeit parts and DOD’s reliance on contractors’ implementation of counterfeit avoidance systems.


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Avoiding Counterfeit Electronic Parts. How DoD’s Proposed Rule May Affect You

Robert S. Metzger, Rogers Joseph O’Donnell, PC
12/28/2015

On September 21, 2015, DoD published a Proposed Rule to modify its existing regulations on detection and avoidance of counterfeit electronic parts. 80 Fed. Reg. 56939. DoD held a public meeting to get input on the proposed rule on November 13, 2015. By action taken on October 21, 2015, DoD extended the comment period until December 11, 2015. 80 Fed. Reg. 63735. For information on how to submit comments, see http://www.gpo.gov/fdsys/pkg/FR-2015-10-21/pdf/2015-26749.pdf.

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Avoiding Counterfeit Electronic Parts- How DoD’s Proposed Rule May Affect You

Robert S. Metzger
11/20/2015

On September 21, 2015, DoD published a Proposed Rule to modify its existing regulations on detection and avoidance of counterfeit electronic parts. 80 Fed. Reg. 56939. DoD held a public meeting to get input on the proposed rule on November 13, 2015. By action taken on October 21, 2015, DoD extended the comment period until December 11, 2015. 80 Fed. Reg. 63735. For information on how to submit comments, see http://www.gpo.gov/fdsys/pkg/FR-2015-10-21/pdf/2015-26749.pdf.

For smaller companies, the most important changes in the Proposed Rule are in a new contract clause, presently named DFARS 252.246-70XX (“Sources of Electronic Parts”), that Department of Defense purchasing activities are to use in solicitations and contracts, including solicitations and contracts using FAR part 12 procedures for the acquisition of commercial items, when procuring— (1) Electronic parts; (2) End items, components, parts, or assemblies containing electronic parts; or (3) Services, if the contractor will supply electronic parts or components, parts, or assemblies containing electronic parts as part of the service. Small business set-asides are subject to the rule.


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