1986 – China's quest began for admission to the World Trade Organization (WTO)
1995 - The Internet was commercialized
1995 (March 1) – Yahoo incorporated
1995 - Electronic Resellers Association Inc. (ERA) founded
- Information Sharing
Most Common Complaint types:
- Cancelled Purchase Orders
- Past Due Invoices
- NSF Checks
1998 – Google incorporated as a privately held company
The company's mission statement: "To organize the world's information and make it universally accessible and
1998 - Electronic Resellers Association International Inc. (ERAI)
Name changed to reflect ERA had become an internationally recognized organization.
Google made the world a much smaller place.
International trade became readily available for everyone; not just large corporations.
2001 (November) – China Admitted to the WTO
"A monumental change to the world trading system."
"An event of historic proportions for the world trading system."
- Kofi Annan, UN Secretary General
"I believe that as this century unfolds and people look back on this day, they will conclude that in admitting China to the
we took a decisive step in strengthening the global economic trading system."
- Robert Zoellick, US Trade Representative
"Just like every member of the WTO, China will have to deliver on its commitments, and we will be watching this very
-Pascal Lamy, EU trade commissioner
2001 (November 29) – ERAI receives first nonconforming part complaint against a China-based distributor
3A Century aka Gold Advanced aka JXJ
Part number: TCM3105DW
Description of the product nonconformance:
Parts arrived in Samsung tubes (ordered TI parts). Numerous mixed date codes arrived in a single tube. Solder splash present on part leads.
were 'wash marks' and smears on the upper surface of the chip.
Within a few months, Chinese distributors began refurbishing and remarking parts to have consistent date and lot codes in order to pass used parts
off as new.
2002 (January) – ERAI Launches High Risk / Suspect Counterfeit Part Database
2002 (April 19) - ERAI Industry Advisory Committee formed; we saw it coming...
- Ethical standards in the industry
- Counterfeit/Substandard parts
- ERAI’s role now and in the future
- Negative advertising campaigns launched by AGMA & NEDA
2003 (March 1) – IDEA Public Launch
ERAI Executive Conference, Las Vegas, NV
- Promote the independent distribution industry through a media advocacy campaign.
- Improve the quality of products and services through a quality certification program, educational seminars and conferences.
- Promote the study, development and implementation of techniques and methods designed to improve the business of independent
2003 (March 31) – GIDEP Alert number CE9-A-03-02 issued by Texas Instruments
"Texas Instruments has received notice of counterfeit devices bearing the TI trademark and part number being sold through various brokers who are not
authorized TI distributors.
In this specific case, the devices are marked as 5962-8961405QXCA and SMJ27C010A-15JM, date code 9939A1, and country of origin as Singapore. TI production
Singapore was terminated prior to this date. The devices in question contain SGS-Thompson die and will not program correctly using the TI part number.
Note that Austin Semiconductor Incorporated acquired the TI military memory product line and currently supplies product under the ASI trademark. Per ASI,
ASI 27C256 devices are manufactured using authentic TI die."
2003 (April 15) – GIDEP Alert number B8-A-03-01 issued by Textron Systems
"Textron Systems has experience a high failure rate of parts marked LT1097S8 with a date code of 0103 and a Linear Technology Corp. logo. Four parts
were returned to Linear Technology Corp (LTC) for failure analysis. LTC has informed Textron Systems that the parts are counterfeit. Textron Systems had
purchased the parts through a distributor that was not franchised by LTC.
LTC electrically tested the parts and confirmed the failures as catastrophic. LTC performed visual and DPA analysis. They discovered that the top of the
parts appeared to have been sanded down and remarked. The back-marks on the part indicate the units were manufactured over eight years ago and are
inconsistent with the year 2001 date code on top of the parts. DPA revealed that the bond and probe metallization had been severely corroded."
2004 (January) – ERAI travels to China
2004 (January 27) – Secretary of Defense releases Memo for Service Acquisition Executives
Subject: Encouraging Industry Participation in the Trusted Foundry Pilot Program
Back door threats realized….counterfeits not the only problem!
2006 (October) - IDEA releases IDEA-STD-1010-A-Acceptability of Electronic Components Distributed in the Open Market
Standard specifically written to identify nonconforming/suspect counterfeit parts
"Counterfeits have a name and a face!"
2006 (November 29) – Counterfeit Components Detection & Prevention Symposium hosted by Component Technology Institute (CTI)
(attended by Phil Zulueta who later becomes SAE Aerospace G-19 Committee Chairman.)
2006 (December) – ERAI’s Second Investigative Trip to China
Investigation specific to the handling of OEM excess by Chinese based OEMs and CMs.
2007 (May) – Electronic Resellers Association International Inc. is renamed ERAI Inc. (the term “resellers” removed as ERAI
moves to share services with the entire supply chain). Membership no longer restricted to distributors only. Database opened to OEMs, CMs, US Government
Agencies, law enforcement, etc.
2007 (June) - the U.S. Department of the Navy, Naval Air Systems Command (NAVAIR) asked the Bureau of Industry and Security’s
(BIS) Office of Technology Evaluation (OTE) to conduct a defense industrial base assessment of counterfeit electronics. NAVAIR suspected that an increasing
number of counterfeit/defective electronics were infiltrating the DOD supply chain and affecting weapon system reliability.
The committee was tasked with developing a document that would standardize requirements, practices and methods related to counterfeit
parts risk mitigation.
2007 (September) - The L-3 Counterfeit Parts Team was established to define and provide guidelines for managing and
the risks associated with counterfeit parts.
OEMs ramping up awareness and avoidance efforts
- U.S. and European customs launched “Operation
” resulting in the seizure of over 360,000 counterfeit
ICs that were destined for U.S. and European markets.
Enforcement is engaged
AIA Counterfeit Parts IPT Plan of Action
To address the challenges of today’s supply chain environment, AIA has established a Counterfeit Parts Integrated Project Team (IPT). The AIA Counterfeit
Parts IPT is working in concert with government agencies, original manufacturers, industry associations and independent distributors.
Objectives of the IPT are to:
1. Engage the U.S. government in discussions concerning acquisition and procurement policies to avoid introducing counterfeit parts and materials into
aerospace, space and defense products
2. Create a set of standards for government and industry to ensure that the risk of introducing counterfeit parts and materials is minimized, is consistent
with risks accepted by the customer and implementable without sacrificing the benefits of buying commercially available products
3. Engage the U.S. government in discussions concerning enforcement of policies to avoid the introduction of counterfeit products into the U.S.
Significance = National & International Media Coverage
2009 (April) – SAE AS5553 Published
2009 (August) – SAE AS5553 adopted by the DOD
2009 (October 9)
– Mustafa Aljaff – MVP Micro /Indictment
2009 (November) – Counterfeit electronics survey initiated by the U.S. Dept. of Commerce, the Bureau of Industry and Security
(BIS), and the Office of Technology Evaluation (OTE).
Counterfeit electronics report was released by the U.S. Dept. of Commerce, the Bureau of Industry and Security (BIS) and the Office
Technology Evaluation (OTE).
The veil was fully lifted.
Purpose: The purpose of this study is to provide statistics on the extent of the infiltration of counterfeits into U.S. defense and industrial
chains, to provide an understanding of industry and government practices that contribute to the problem, and to identify best practices and recommendations
for handling and preventing counterfeit electronics.
- The 2010 Joint
Strategic Plan on Intellectual Property Enforcement
submitted to the President of the United States and Congress states the U.S. Government shall:
"establish a government-wide working group tasked with studying how to reduce the risk of the procurement of counterfeit parts by the U.S.Government." The
Administration also called for increased criminal penalties for such offenses.
2010 (September 14)
- Shannon Wren and Stephanie McCloskey (VisionTech) Press Release / Indictment
– Supply & Demand Chain Executive Special Edition - Supply Chain RISK
2011 (March) - Senators Levin & McCain announced a Senate Armed Service Committee (SASC) investigation into counterfeit
electronic parts and the risks they pose to the Department of Defense (DOD) supply chain.
Counterfeit parts impact 40% of Pentagon’s Supply Chain according to U.S. Commerce Dept study.
Senator Brown (OH) recommends DOD cancel supplier contracts when counterfeits are found in their supply chain.
2011 (July) - The UK Ministry of Defence formed a Counterfeit Awareness Working Group (CAWG) to assess whether or not counterfeit components had been incorporated in aircraft or military equipment manufactured in the United Kingdom.
2011 (November 29) - The Whitehouse measure was amended to the McCain / Levin Bill and then unanimously approved by the
It moved to the House for discussion.
2011 (December 20)
– SAE ARP6178
Electronic Parts; Tool for Risk Assessment of Distributors was published.
2011 (December 31) – Measure signed by President Obama - 2012 National Defense Authorization Act (Sec. 818) Detection and
Avoidance of Counterfeit Electronic Parts.
– SAE G-19T – AIR6273
Terms and Definitions
subcommittee was formed: Terms and Definitions - Fraudulent/Counterfeit Electronic Parts
2012 (November 7)
- Fraudulent/Counterfeit Electronic
Parts: Avoidance, Detection, Mitigation, and Disposition -
Distributors released by SAE Aerospace
2013 (January 1)
– H.R. 4310 National Defense Authorization Act for Fiscal Year 2013
signed into law (Public Law No: 112-239).
(Sec. 833) Amends the NDAA for Fiscal Year 2012 to provide an exception, in limited circumstances, to the prohibition as allowable contractor costs the cost of counterfeit and suspected counterfeit electronic parts and rework or corrective action with respect to such parts.
- SAE G-19-AD subcommittee formed
Fraudulent/Counterfeit Electronic Parts: Avoidance, Detection, Mitigation, and Disposition - Authorized/Franchised Distribution
2013 (May 22)
– U.S. Customs and Border Protection successfully completes "Operation Core Systems"
- 480 shipments of
potentially harmful counterfeit electronic components seized
2013 (June 12)
- United States of America v. Hao Yang (MS
– First individual to be indicted under the relatively new charge of trafficking in counterfeit military goods, a federal crime enacted
as part of the National Defense Authorization Act of 2011 (Conspiracy to Traffic in Counterfeit Goods and Counterfeit Military Goods, 18 U.S.C. 2320).
2013 (August 25)
- The National Institue of Standards and Technology (NIST) proposes a new cybersecurity control overlay for federal agency supply chain risk management in NIST Special Publication 800-161
2013 (December 11)
- Xilinx, Inc. v. Flextronics
Xilinx Inc. filed a lawsuit in a California court against Flextronics International Ltd., alleging the contract manufacturer resold
chips it purchased from the semiconductor vendor at a premium to other customers. The FPGA manufacturer also charged Flextronics with dealing in "gray
market and counterfeit" Xilinx products, according to the filing with the Superior Court of California, County of Santa Clara.
2013 (December 26)
- H.R. 3304 National Defense Authorization Act for Fiscal Year 2014
signed into law (Public Law No: 113-66).
(Sec. 803) Directs the Secretary to implement a process for the expedited identification and replacement of obsolete electronic parts included in DOD acquisition programs.
- National Aeronautics and Space Administration Authorization Act of 2014- SEC. 712. Detection and Avoidance of
Counterfeit Electronic Parts - The House of Representatives passed new NASA counterfeit parts legislation. If passed by Congress and the President, Section 712 of the NASA Authorization Act of 2014
would require that the
NASA Supplement to the FAR be revised to address the detection and avoidance of counterfeit electronic parts.
2014 (June 10)
– DoD, GSA, and NASA published a proposed rule at 79 FR 33164
in the Federal Register to implement sections 818(c)(4) and (c)(5) of the National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2012 (Pub. L. 112-81, 10 U.S.C. 2302 Note) which required DoD contractors and subcontractors to report counterfeit or suspect counterfeit electronic parts purchased by or for DoD to the Government-Industry Data Exchange Program (GIDEP).
2014 (July 7)
- The Office of the Under Secretary of Defense for Acquisition, Technology, and Logistics releases the Assured Microelectronics Policy
report in response to Senate Report 113-85, page 179, accompanying S. 1429, the Department of Defense Appropriations Bill, 2014, SAC-D which, "provides a strategy for acquisition programs to integrate robust systems engineering, supply chain risk management (SCRM), security, counterintelligence (CI), intelligence, information assurance, software assurance, and hardware assurance (with an emphasis on microelectronics) for managing risks to system integrity and trust."
2014 (July 10)
- The UK MOD releases Defence Standard 05-135
– Avoidance of Counterfeit Materiel Issue 1. This Defence Standard defines the arrangements that a supplier is required to establish to demonstrate that they are actively planning and managing the risk of counterfeit materiel in their supply chain to prevent delivery of such materiel to the MOD.
2014 (July 30)
- SAE publishes AS6174A
– Counterfeit Materiel; Assuring Acquisition of Authentic and Conforming Materiel.
2014 (August 20)
- SAE publishes AS6496
– Fraudulent/Counterfeit Electronic Parts: Avoidance, Detection, Mitigation, and Disposition – Authorized/Franchised Distribution.
2014 (November 13)
- The US Nuclear Regulatory Commission (NRC) officially launched its Counterfeit, Fraudulent, and Suspect Items (CFSI)
public webpage. The site is intended to help all interested parties quickly locate counterfeit, fraudulent, and suspect items (CFSI) information relating to NRC regulated activities spanning a period of approximately 30 years.
2014 (December 4)
- H.R.5793 - Cyber Supply Chain Management and Transparency Act of 2014
(H.R.5793 — 113th Congress (2013-2014)) is introduced to require the Office of Management and Budget (OMB) to issue guidelines for agencies that contract to acquire software, firmware, or products containing a third party or open source binary component.
2014 (December 12)
– Jeffrey Warga pleads guilty to one count of conspiracy to commit wire fraud
. Warga and others engaged in a scheme to defraud their business customers, including a Connecticut company, by falsely representing that the electronic parts they sold were not from Asia when, in fact, the parts had been purchased from companies located in Asia; were new parts from the original manufacturer when, in fact, the parts were used; and were authentic parts when, in fact, Warga and his co-conspirators knew the parts were counterfeit parts.
2015 (January 7)
- The Defense Department’s top acquisitions official releases a new version of the acquisitions corps’ guiding document: Department of Defense Instruction 5000.02
, Operation of the Defense Acquisition System, which emphasizes that acquisitions programs should be tailored to the product being acquired.
2015 (April 22)
- The Secretary of the Navy issues SECNAV Instruction 4855.20
to establish Department of the Navy (DON) policy to prevent the introduction of counterfeit materiel into DON systems. It applies to all phases of life cycle management, from identifying an operational requirement, introducing an item into the supply chain, system operations and maintenance, through phase out and retirement.
2015 (July 3)
- In order to support consistent interpretation of UK Defence Standard 05-135, the UK MOD Counterfeit Avoidance Working Group (CAWG) issues the Counterfeit Avoidance Maturity Model version 1.0
support document for auditors assessing compliance with the requirements of the Standard.
2015 (July 6)
- In compliance with DoDI 4140.67, "DoD Counterfeit Prevention Policy" (Reference (b)) and Section 818, Public Law 112-81 of the “National Defense Authorization Act (NDAA) for Fiscal Year (FY) 2012” (Reference (d)), DCMA develops DCMA-INST 1205 – Counterfeit Mitigation Instruction
to enhance surveillance activities.
2015 (November 25)
- S.1356 National Defense Authorization Act for Fiscal Year 2016
signed into law (Public Law 114-92).
(Sec. 238) Requires DOD to conduct a hardware assurance study to assess the presence, scope, and effect on DOD operations of counterfeit electronic parts that have passed through the Department supply chain and into fielded systems.
(Sec. 885) Expands the eligibility for contractors to include costs for rework and corrective action related to counterfeit electronic parts as allowable costs under DOD contracts. Permits DOD to approve industry-selected trusted suppliers.
2015 (December 11)
- Jeff Krantz sentenced
to three years’ probation, fined $100,000 and ordered to pay $402,650.00 in restitution for supplying the U.S. military with mislabeled microchips.
2016 (January 21)
- Jeffrey Warga was sentenced
to three years of probation and was ordered to pay a $10,000 fine for supplying customers and the US military with falsely remarked microprocessor chips.
2016 (February 16)
- GAO report GAO-16-236
recommends that DOD oversee its defense agencies’ reporting efforts, develop standard processes for when to report a part as suspect counterfeit, establish guidance for when to limit access tor GIDEP reports, and clarify criteria to contractors for their detection systems.
2016 (March 18)
- JEDEC, an international standards body, publishes JESD243
which identifies the best commercial practices for mitigating and/or avoiding counterfeit products by all manufacturers of electronic parts.
2016 (October 1)
– IPC publishes IPC-1782
: Standard for Manufacturing and Supply Chain Traceability of Electronic Products to help establish minimum requirements for manufacturing and supply chain traceability based on perceived risk as agreed between user and supplier
2016 (October 30)
- SAE AS6171
is published. This SAE Aerospace Standard (AS) standardizes inspection and test procedures, workmanship criteria, and minimum training and certification requirements to detect Suspect/Counterfeit (SC) Electrical, Electronic, and Electromechanical (EEE) parts.
2016 (December 23)
- S.2943 National Defense Authorization Act for Fiscal Year 2017
signed into law (Public Law No: 114-328). (Sec. 815) Revises requirements for the detection and avoidance of counterfeit electronic parts to require contractors and DOD to meet certain requirements using "suppliers that meet anticounterfeiting requirements" rather than "trusted suppliers."
2017 (January 13)
- U.S. Customs and Border Protection (CBP) and U.S. Immigration and Customs Enforcement (ICE) seized a record number of shipments
containing goods that violated Intellectual Property Rights (IPR) in FY2016.
2017 (February 7)
- The Secure E-Waste Export and Recycling Act (SEERA)
was reintroduced as H.R. 917 by Representatives Republican Paul Cook and Democrat Gene Green. If passed and signed into law by President Trump, the bill will ensure electronic waste does not become a source of counterfeit electronic parts which then re-enter the supply chain.
- The Defense Science Board, an advisory committee established to provide advice to the Secretary of Defense, releases a Report of the Defense Science Board, Task Force on Cyber Supply Chain
providing a critical analysis and 25 recommendations to address cyber vulnerabilities in the DoD’s weapon systems supply chain and sustainment programs.
2017 (June 26)
- ERAI launches InterCEPT
, a web-based counterfeit avoidance training program designed exclusively for professionals with roles in manufacturing, management, procurement, logistics, distribution, or otherwise serving or engaged with the electronics industry.
2017 (September 28)
- The Government Accountability Office (GAO) releases a report entitled, "Defense Supply Chain – DOD Needs Complete Information on Single Sources of Supply to Proactively Manage the Risks
". The GAO examined DOD’s report per Senate Report 114-49 which instructed DOD to provide a report which, "identifies major defense acquisition programs with operational implications, a list of critical components of such major defense acquisition programs provided by single-source and/or single-provider suppliers, the severity of the operational impact of the loss of such suppliers, and risk management actions with associated implementation plans and timelines the Department will take to prevent negative operational impact in the event of such loss." The GAO report found that the DOD’s October 2016 report addressed two of four elements required by the Senate, partially addressed one element and did not address a fourth element.
2017 (October 2)
- The United States Department of Defense (DoD) Defense Contract Management Agency (DCMA) released its latest update of the Contractor Purchasing System Review (CPSR) Guidebook
. The CPSR Guidebook, "provides guidance and procedures to Government personnel for evaluating contractor’s purchasing systems and preparing the CPSR reports".
2017 (December 12)
- H.R. 2810 National Defense Authorization Act for Fiscal Year 2018
is enacted as Public Law 115-91. Section 217 authorizes the Secretary of Defense to establish expedited access to university technical expertise to address acquisition, management, and operational challenges covering several mission areas including cybersecurity and trusted electronics. Section 846 establishes a program to procure commercial products through commercial e-commerce portals to be implemented in phases with the objective of enabling government-wide use of such portals. Section 1670 requires the Secretary of Defense to provide certification that an assured capability to produce or acquire strategic radiation hardened trusted microelectronics is operational and available to supply necessary microelectronic components for necessary radiation environments involved with the acquisition of delivery systems for nuclear weapons.
2018 (January 30)
- The Government Accountability Office (GAO) was asked to analyze the enforcement efforts made by U.S. Customs and Border Protection (CBP) and U.S. Immigration and Customs Enforcement (ICE) of counterfeit goods entering the United States with regard to the enforcement of intellectual property rights and the extent of the agencies’ collaborative efforts be-tween themselves and the private sector. The results, contained in a report entitled, "Intellectual Property – Agencies Can Improve Efforts to Address Risks Posed by Changing Counterfeits Market
", were released in January of 2018.
2018 (April 6)
- United States Department of Veterans Affairs (VA) proposes to amend and update its VA Acquisition Regulation (VAAR)
to require that contractor purchasing system reviews focus special attention on whether the contractor has implemented a counterfeit electronic part detection and avoidance system to ensure that counterfeit electronic parts do not enter the supply chain.
2018 (May 1)
- The owner of PRB Logics Corporation, an Orange County-based seller of electronic components, was arrested on federal charges alleging he sold counterfeit integrated circuits, some of which could have been used in military applications. Rogelio Vasquez is charged in a 30-count indictment
that alleges he acquired old, used and/or discarded integrated circuits from Chinese suppliers that had been repainted and remarked with counterfeit logos.
2018 (June 15)
- President Trump announced the implementation of a 25% import tax against a list of over 1,000 products
imported from China. Included in the list are certain capacitors, materiel for airplanes, batteries, transistors, LEDs, industrial machinery and other electrical, electronic and electromechanical components.
2018 (August 13)
- President Trump authorized the 2019 National Defense Authorization Act
, or NDAA, which provides a budget of $717 billion for U.S. national defense. A few notable points relative to the electronics industry are: Section 843 Pilot program to test machine-vision technologies to determine the authenticity and security of microelectronic parts in weapons systems; Section 845 Report on defense electronics industrial base; Section 1261 United States strategy on China; Section 1653 Study and report on reserve component cyber civil support teams and Section 1765 Annual report to Congress.
2018 (September 11)
- Applied DNA Sciences announced the signing of a new contract
with the Defense Logistics Agency’s (DLA) Land and Maritime’s Product Test Center (PTC). The contract extends Applied DNA’s services for an additional two years with a one-year optional extension at DLA’s discretion. The services include the supplies and services for unique DNA marks in various inks and quality assurance authentication testing and training specific to FSC 5962 microcircuits.
2018 (October 4)
- Bloomberg published a report entitled "The Big Hack: How China Used a Tiny Chip to Infiltrate U.S. Companies
" that described how nearly 30 American companies stored data on servers that contained chips which had allegedly been secretly inserted during the manufacturing process in China by members of the People’s Liberation Army. Among the allegedly affected companies were Apple, a large unnamed banking institution, Department of Defense contractors and Amazon, who the report states, discovered an intrusion while performing a security audit on video compression servers that had been assembled by Super Micro Computer Inc. during a build of a secure cloud for the CIA.
2018 (October 9)
- US Government Accountability Office released a report
in early October 2018 analyzing the state of the Department of Defense’s weapon systems cybersecurity. While the report identified mission-critical vulnerabilities, the GAO did not provide any recommendations to the DoD.
2019 (January 17)
- Rogelio Vasquez, the owner of PRB Logics Corporation, an Orange County-based seller of electronic components, pleaded guilty
to one count of trafficking in counterfeit military goods, two counts of trafficking in counterfeit goods, and one count of wire fraud.
2019 (April 3)
- President Donald Trump signs a memorandum
addressing the trafficking of counterfeit goods through online marketplaces. The order requires Homeland Security to provide recommendations on how to improve monitoring and enforcement.
2019 (November 22)
- DoD, GSA, and NASA issued a final rule
amending the Federal Acquisition Regulation (FAR) to require contractors and subcontractors to report to the Government-Industry Data Exchange Program certain counterfeit or suspect counterfeit parts and certain major or critical nonconformances.
2019 (December 20)
- H.R. 2500 National Defense Authorization Act for Fiscal Year 2020
is enacted as Public Law 116-92. Section 230 requires the Secretary of Defense to establish trusted supply chain and operational security standards for the purchase of microelectronics products and services by the Department. Section 254 increases funding for anti-tampering heterogenous integrated microelectronics by $5,000,000. Section 255 requires the Under Secretary of Defense for Research and Engineering to provide a briefing on the potential use of distributed ledger technology for defense purposes to improve cybersecurity, reduce single points of failure in emergency and catastrophe decision-making, improve the efficiency of defense logistics and supply chain operations, enhance the transparency of procurement auditing and allow innovations to be adapted by the private sector for ancillary uses. Section 855 amends the process for enhanced supply chain scrutiny by inserting a new paragraph, "Development of tools for implementing supply chain risk management policies during the generation of requirements for a contract."
2020 (January 7)
- NASA proposes to amend the NASA Federal Acquisition Regulation Supplement (NFS)
to add new text that requires covered contractors and subcontractors at all tiers to use electronic parts that are currently in production and purchased from the original manufacturers of the parts, their authorized dealers, or suppliers who obtain such parts exclusively from the original manufacturers of the parts or their authorized dealers. If the contractor does not purchase electronic parts as described above, they must purchase the parts from a NASA identified supplier or contractor-approved supplier. The contractor will then assume responsibility and be required to inspect, test and validate authentication of the parts. The contractor will also be required to obtain traceability information and provide this information to the contracting officer upon request. The selection of contractor-approved suppliers is subject to review and audit by the contracting officer.