ERAI Recommended Best Practices for Material Control

Suspect/fraudulent/counterfeit parts have no value and pose a serious threat; therefore, these types of parts should be controlled to prevent their re-entry into the supply chain. Organizations should maintain a written material control plan and should include terms and conditions in their purchase order contract that detail how suspect/fraudulent/counterfeit parts will be handled, if encountered.

Under no circumstances should suspect/fraudulent/counterfeit parts be returned to the supplier. The quarantined parts should be in an access-restricted, secure location and should be clearly marked. Labeling should be kept intact and should not be covered or altered. Upon the end of the quarantine period, the parts and their packaging should be destroyed and a certificate of destruction should be kept on file.

Guidance

For detailed guidance organizations are encouraged to reference SAE Aerospace Standards AS5553 and/or AS6081.

The Defense Industrial Base Assessment titled Counterfeit Electronics prepared by U.S. Department of Commerce, Bureau of Industry and Security, Office of Technology Evaluation states that in order to curtail the flow of counterfeit parts into the U.S. defense and industrial supply chains organizations should "ensure physical destruction of all defective, damaged, and substandard parts".¹

SAE Aerospace Standard AS5553D further requires organizations to "assure all production EEE part inventories affected by the suspect counterfeit or counterfeit EEE parts are contained for disposition."²

SAE Aerospace Standard AS6081 prohibits the sale of suspect/counterfeit parts for "use-as-is"³ and does not permit the removal of suspect/counterfeit parts from quarantine "quarantine except for independent verification testing in accordance with 3.4.6 or for final disposition." ⁴

The National Defense Authorization Act for Fiscal Year 2012 [H.R. 1540 Sec. 818] called for "policies and procedures to eliminate counterfeit electronic parts from the defense supply chain" and that these policies shall include "the reporting and quarantining of counterfeit electronic parts and suspect counterfeit electronic parts".⁵

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¹ U.S. Department of Commerce, Bureau of Industry and Security, Office of Technology Evaluation

² SAE Aerospace Standard AS5553 Revision D. Counterfeit Electrical, Electronic, and Electromechanical (EEE) Parts; Avoidance, Detection, Mitigation, and Disposition

³ SAE Aerospace Standard AS6081 Revision A: Counterfeit Electrical, Electronic, and Electromechanical (EEE) Parts: Avoidance, Detection, Mitigation, and Disposition - Independent Distribution

⁴ SAE Aerospace Standard AS6081 Revision A: Counterfeit Electrical, Electronic, and Electromechanical (EEE) Parts: Avoidance, Detection, Mitigation, and Disposition - Independent Distribution

⁵ National Defense Authorization Act for Fiscal Year 2012: H.R. 1540 Sec. 818 Detection and Avoidance of Counterfeit Electronic Parts- page.199 (2) Elements (A) (vi) the reporting and quarantining of counterfeit electronic parts and suspect counterfeit electronic parts