To support this process, the following training requirement shall be imposed upon indicated personnel:

This policy will be the basis for a Counterfeit Electronic Component Awareness Training program to be developed and administered by GTRI, in conjunction with the Office of Sponsored Programs (OSP).

Project Directors (PDs) and Principal Investigator (PIs) are required to determine who within the project team should complete the training.

Personnel responsible for the specification and/or procurement of purchased components for prototypes, as well as personnel who physically handle electronic components or assemblies containing electronic components, are recommended to complete Counterfeit Electronic Component Awareness Training.

The GIT training for this policy can be found here. To access the training module, GIT employees will need to login to the employee training portal and search the course catalog for “Counterfeit Electronic Part Detection and Avoidance Policy Overview”.

It is the responsibility of all personnel who handle electronic components or assemblies containing electronic components at any point in the inspection, assembly, and test flow to be aware of and to report any attribute, feature, or performance parameter that may indicate that the part is not genuine.

GIT procurement sourcing controls are designed to minimize risk of receipt of counterfeit electronic parts. However, there is a possibility that such parts may make their way into department or laboratory storage spaces. To support this policy, GIT will adhere to the following:

1. Assembly or test personnel shall report any visual or functional anomaly to the PD or PI for counterfeit assessment at any point during receipt of parts. Cosmetic anomalies may or may not be indicative of counterfeit production, but must be investigated as such.
2. GIT PDs, PIs, and Program Managers (PMs) shall work with the supplier to verify counterfeit determination and shall issue a Government-Industry Data Exchange Program (GIDEP) Advisory (suspect counterfeit part, but confirmed genuine) or GIDEP Alert (confirmed as counterfeit). Such reports are to be issued within 30 days of the initial escalation. For access to GIDEP, please direct any inquiries to the PMO.

Upon receiving an item, a visual inspection must be conducted. If an item is purchased from Category 1 or Category 2, a visual inspection and acceptance will need to be completed. If an item is purchased from Category 3, it will need to be sent to a testing facility as identified on the CASL.

The physical/environmental/electrical/inspection test sequences required for Category 3 electronic parts is dependent on a risk assessment to determine the recommended level of testing to mitigate risk associated with obtaining the parts from an unauthorized supplier. SAE-AS6171 provides a method for establishing risk and appropriate test sequences, and shall be utilized and documented for GT and GTRI for procured Category 3 electronic parts.

Refer to Section 5.5 for supplier category and CASL information.

Refer to Section 5.6 for quarantine procedures if a suspected counterfeit part is identified.

All GIT orders for electronic components from any supplier shall request that the total quantity of any individual part be from a single manufacturing lot or date code. In addition to minimizing variation in performance, it is less likely that a single manufacturing lot or date code across the total quantity represents parts from an unauthorized market source.

This policy shall be imposed on GIT subcontractors as described in Section 5.9.

GIT PDs, PIs, and PMs are required to add traceability documentation provided by vendors into the document repository of the PD's choice (Box, Sharepoint, etc) upon receipt of components to maintain supply chain traceability. PDs, PIs, and PMs must be aware that the selection of non-approved suppliers are subject to review and audit by the appropriate U.S. Government representative.

When sourcing an electronic part from a supplier, the following requirements apply:

1. Any order for electronic components from any supplier requires a certificate of origin (C of O), attesting that the supplier acquired those parts directly from the original manufacturer, and that those parts are not returns, nor were they sourced from a non-Category 1, 2, or 3 supplier. This requirement for a C of O must be included on the original PO.
2. Any order for electronic components from any supplier shall request that the total quantity of any individual part be from a single manufacturing lot or date code.

GIT is not certified to test suspected counterfeit parts; therefore, GIT shall follow the following guidelines in order to avoid the receipt of counterfeit parts.

GIT will be in compliance with DFARS 252.246 by obtaining electronic parts from one of three categories listed below in sequential order:

1. Category 1:  GIT PDs, PIs, and PMs will obtain electronic parts that are in production by the original component manufacturer (OCM) or an authorized aftermarket manufacturer (AAM). If parts are not in production, obtain from currently available stock in the following order:

a.  OCM of the parts;

b.  OCM-authorized suppliers of the parts; or

c. Suppliers that obtain such parts exclusively from the OCM of the parts or their authorized suppliers.

OCM authorized suppliers shall be verified using one of these methods:

a. Verification of OCM authorized supplier legitimacy prior to purchase shall be documented. OCM websites include the suppliers that are authorized to distribute their components. A screenshot from the OCM website designating authorized suppliers or an email from an OCM verifying an authorized supplier is acceptable verification.

b. The Electronic Components Industry Association (ECIA) maintains a database (https://www.eciaauthorized.com/en) of verified authorized suppliers. The ECIA database is an alternative source for verifying authorized suppliers and shall be archived with purchase documentation.

A supplier’s website should never be solely relied on as a source for OCM authorization to distribute.

2. Category 2:  If electronic parts are not available as provided in Category 1, GIT will obtain electronic parts that are not in production by the OCM or an AAM from suppliers identified by the CASL. The CASL is derived from the DLA certified vendor list, which is included in the workflow attached to this policy. The following three conditions apply to this source of electronic parts:

a.  GIT will comply with GT Procurement processes to identify and approve CASs who adhere to established counterfeit prevention industry standards as mentioned in Section 10;

b. CAS assumes responsibility for the authenticity of parts provided to GIT; and

c. CASL is subject to review and audit by the government CO.

3. Category 3:  If GIT (i) obtains an electronic part from a source other than those identified in Categories 1 and 2 because of nonavailability or from a subcontractor other than the OCM that refuses to accept the flow down of DFARS clause 252.246-7008; or (ii) cannot confirm that an electronic part is new or previously unused and that it has not been comingled in supplier new production or stock with used, refurbished, reclaimed, or returned parts, then the contractor must adhere to the following:

a.  Promptly notify the sponsor CO in writing;

b.  Be responsible for inspection, testing, and authentication by selecting a test resource from the CASL; and

c. Log documentation of inspection, testing, and authentication to make available to the government upon request.

When one becomes aware of, or has reason to suspect that any electronic part, component, or assembly containing electronic parts purchased contains counterfeit electronic parts or suspect counterfeit electronic parts, reporting is required to the Government CO and to the GIDEP.

Per standard AS5553C, control suspect counterfeit EEE parts to preclude their use or reentry in to the supply chain by physically identifying and segregating the suspect counterfeit EEE parts from acceptable non-suspect EEE parts and placing in quarantine until dispositioned. Quarantine shall consist of a controlled access space.

PMO can provide guidance about any of these processes in this policy. Please direct any inquiries to PMO.

Electronic parts purchased from Category 1 or Category 2 suppliers do not require individual component testing.  However, when purchasing parts from a Category 3 supplier, GIT will rely on the identification of suspect counterfeit electronic parts through the use of CASL Testers for inspection and counterfeit testing. 

Refer to the policy workflow attachment for the CASL.

GIT is committed to the detection and avoidance of counterfeit electronic components in the government supply chain. GIT supports the procurement of electronic components through Categories 1 and 2, and to follow a thorough selection process when vetting Category 3 suppliers.

All GIT orders for electronic components from any supplier shall request that the total quantity of any individual part be from a single manufacturing lot or date code. In addition to minimizing variation in performance, it is less likely that a single manufacturing lot or date code across the total quantity represents parts from an unauthorized market source.

Subcontractor Flow Down

A subcontractor is defined as any supplier, distributor, vendor, or firm that furnishes supplies or services to or for GIT.

Subcontractors participating in GIT projects at all levels in the supply chain that are responsible for buying and selling electronic parts or assemblies containing electronic parts, or that perform authentication testing are required to comply with the notification, inspection, testing, and authentication requirements as listed in this policy. GIT shall be responsible for ensuring that these requirements are flowed down to subcontractors.

The subcontractor is required to meet one of the two options listed below:

1. Independent verification of electronic parts used in a subcontracted assembly will consist of a GIT review of the parts list and part sources to confirm that the latter are purchased from Category 1, 2, or 3 suppliers.  In a competitive bid situation, an estimate of the cost to GIT of such a review may be applied to the bids of those subcontractors that lack such a system for source selection purposes.
2. Confirmation of a subcontractor counterfeit electronic parts control plan that satisfies the requirements of this policy will consist of a review of said plan at the subcontractor’s location, including evidence of its implementation. The subcontractor is to be provided a copy of this policy prior to the review meeting.

In all cases, GIT will work proactively with the subcontractor to ensure a smooth and expeditious resolution that is in the interests of both parties.

Purchase Order Flow Down

For COTS products and non-recurring engineering (NRE) initiated through a purchase order (PO), GIT will flow down this policy to ensure counterfeit avoidance compliance.

When sourcing an electronic part from a supplier, the following requirements apply:

1. Any order for electronic components from any supplier requires a CO, attesting that the supplier acquired those parts directly from the original manufacturer, and that those parts are not returns, nor were they sourced from a non-Category 1, 2, or 3 supplier. This requirement for a C of O must be included on the original PO.
2. Any order for electronic components from any supplier shall request that the total quantity of any individual part be from a single manufacturing lot or date code.

GIT will require periodic training of counterfeit parts avoidance trends for applicable employees via online training and conferences.

GIT has access to the GIDEP and other credible sources for information pertaining to updated counterfeit parts advisories.

For access to these reports, please direct any inquiries to PMSO.

GIT shall avoid the use of obsolete parts on new designs. All parts lacking traceability shall be considered as obsolete parts.