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ERAI Blog

Clarifications and Additions to United States Trade Representative Section 301 China Tariffs

Anne-Liese Heinichen
08/09/2018

As a response to China’s “unfair” trade practices related to the transfer of American intellectual property and technology, a 25% tariff went into effect on July 6, 2018. The tariff covers 818 product types, as defined by their corresponding Harmonized Tariff Schedule (“HTS”) codes, manufactured in China and imported into the United States. This article aims to clarify how the tariff is assessed and applied by US Customs and Border Patrol (CBP) and provides sample scenarios and additional information in a question and answer format.

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SAE Releases "A" Revision to AS6171 Slash Sheet 2

07/11/2018

On October 30, 2016, SAE International released aerospace standard AS6171 in order to standardize "inspection and test procedures, workmanship criteria, and minimum training and certification requirements to detect Suspect/Counterfeit (SC) Electrical, Electronic, and Electromechanical (EEE) parts." The standard is intended to be implemented on parts that do not have traceability to the Original Component Manufacturer, on parts that have been purchased from brokers or independent distributors, or parts where the end user is concerned about the potential of suspect counterfeit parts.

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The Battle Continues Against Unregulated E-Waste

Kristal Snider
06/18/2018

In the Q2-2016 edition of INSIGHT, readers were encouraged to become familiar with and support H.R. 5579, the Secure-E-waste Export Recycling Act (SEERA), a bill that was introduced to control the export of electronic waste in order to ensure that such waste does not become a source of counterfeit goods that may reenter military and civilian electronics supply chains. Along with two previous bipartisan bills, H.R. 2284 and H.R. 2791, Responsible Electronics Recycling Act, H.R. 5579 fell short of becoming a law or “died” in the 114th Congress. A bill must be passed by both the House and Senate in identical form and then be signed by the President to become law. Legislation not enacted by the end of a Congress is cleared from the books. On February 7, 2017 H.R. 917: Secure E-Waste Export and Recycling Act, picked up where H.R. 5579 left off and was introduced into the 115th Congress where it was referred to the House Committee on Foreign Affairs.

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2017 ERAI Reported Parts Analysis

Damir Akhoundov
06/14/2018

ERAI reported a total of 771 suspect counterfeit and nonconforming parts in 2017, which shows a marked decline from the last several years, despite an increase in global semiconductor sales. The decline, while interesting in itself, cannot be considered a change in the overall trend without taking into consideration data from future years. Factors that could cause this decline include better anti-counterfeiting procedures taken by organizations during the procurement process, more counterfeit parts being prevented from entering the supply chain through customs seizures and detentions, lack of enforcement of industry and government reporting requirements, and perhaps, some counterfeiters have reduced their activities due to improved and new counterfeit detection techniques. On the other hand, it may also indicate that more sophisticated counterfeiting techniques are resulting in fewer counterfeit parts being detected and, therefore, reported to ERAI. It will be interesting to see if this trend persists through 2018 or whether the decline was only temporary.

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New InterCEPT Classes Launched

Kristal Snider
05/02/2018

InterCEPT has launched two new classes to supplement your organization’s training requirements. Each class features handouts of the course material, quizzes, a final exam, and a certificate of completion that can easily be verified by an auditor or customer on ERAI’s website.

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Is Your Organization Prepared for a Supply Disruption?

Anne-Liese Heinichen
02/19/2018

In March 2011, the Fukushima disaster resulted in global supply disruptions of silicon wafers, automotive parts and other electronic assemblies. In February 2015, a structural fire destroyed the main plant at a GE Aviation facility located in Dowty in the UK. The facility was the sole manufacturer of propellers for Lockheed Martin’s C-130J aircraft. While we have all heard the saying “don’t put all of your eggs in one basket”, has your organization identified, documented, analyzed and prepared for a supply interruption, especially for parts from a single source of supply?

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Use Caution to Avoid Counterfeit Nichia Laser Diode Products

Kristal Snider
02/14/2018

Nichia Corporation published a press release alerting customers a “large number” of counterfeit Nichia laser diode products have entered the supply chain.

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Do Cloned Parts Exist in the Market?

Mark Snider & Anne-Liese Heinichen
02/09/2018

Let’s start with the definition of a cloned part. SAE Aerospace Standard AS6171 Test Methods Standard; General Requirements, Suspect/Counterfeit, Electrical, Electronic, and Electromechanical Parts defines cloned parts as one of seven counterfeit part types:

A reproduction of a part produced by an unauthorized manufacturer without approval or design authority that replicates the authorized manufacturer’s part. NOTE: Cloning eliminates the large development cost of a part. Cloning can be done in two ways: by reverse engineering or by obtaining design information and/or technical data inappropriately (such as by unauthorized knowledge transfer from a person with access to the part design).

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Florida Distributors to be Imprisoned for IEEPA Violations

Anne-Liese Heinichen
12/20/2017

In October of 2016, Ali Caby, Arash Caby and Marjan Caby were charged with exporting prohibited articles to Syria. Through their Miami-based company, AW-Tronics, LLC, the defendants allegedly devised a scheme to export dual-use goods with both civilian and military applications by listing the destination of the products as “USA” while then exporting the devices to their Bulgaria office where they were forwarded to Syrian Arab Airlines, an government-run airline allegedly transporting weapons and ammunition to Hezbollah and the Iranian Revolutionary Guards.

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Enhancing Your Supplier Verification Process

Anne-Liese Heinichen
12/04/2017

With the release of DFARS 252.246.7008, supplier qualification requirements remain front and center in the US Government’s efforts to prevent counterfeit parts from entering the military supply chain. Of importance, not only to government contractors, is the topic of supplier assessment as a key element in every organization’s documented mitigation program/control plan.

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