The purpose of this policy is to prevent, detect, mitigate, and control the introduction of counterfeit, suspect counterfeit, or fraudulent parts into the company’s supply chain, production processes, and delivered products. This policy ensures compliance with applicable industry standards, including SAE AS5553, AS6081, AS6174, ISO 9001:2015, and AS6496, and establishes responsibilities for employees, suppliers, and partners.
Scope
This policy applies to:
All employees, contractors, sub-contractors, and suppliers involved in procurement, inspection, handling, and management of materials or parts.
All products throughout their life cycle, from sourcing, receiving, storage, production, delivery, returns, and disposal.
Materials, electronic components, assemblies, and equipment procured from authorized or alternative sources.
Definitions
Counterfeit Part/Material: Any unauthorized copy, imitation, substitution, or altered product misrepresented as genuine with intent to defraud.
Suspect Part: A part with characteristics inconsistent with legitimate parts and/or failing authentication or verification tests.
Authorized Supplier/Source: Manufacturer, franchised distributor, or verified source approved by original manufacturer.
Certificate of Conformance (CoC): Documentation confirming that a part meets specified authenticity and quality requirements.
Policy Statements
Commitment: Senior management is fully committed to preventing counterfeit parts and materials from entering the supply chain.
Procurement Controls:
- Prefer procurement directly from manufacturer or authorized distributors.
- Evaluate and approve suppliers based on historical performance, risk assessment, and certification status.
- Require CoC and traceability documentation for all purchased parts.
Inspection and Verification:
- Implement incoming inspection and risk-based sampling to detect nonconforming or suspect parts.
- Use visual inspection, electrical testing, X-ray, destructive physical analysis (DPA), plating, and mechanical verification where appropriate.
- Any suspect part is quarantined and investigated before use.
Traceability: Maintain complete records from supplier to end-use, including supply chain intermediaries, lot numbers, date codes, and purchase orders.
Quarantine and Disposal:
- Suspect or confirmed counterfeit parts are segregated, labeled (e.g., Red Tag), and quarantined.
- Confirmed counterfeit items shall be destroyed securely and irreversibly; no restocking or reuse is permitted.
Supplier Responsibilities:
- Implement a counterfeit prevention plan consistent with AS5553/AS6081.
- Ensure sub-suppliers comply with this policy and train personnel accordingly.
- Actively cooperate with audits and traceability requirements.
Training and Awareness:
- All personnel involved with procurement, production, and quality management receive training on counterfeit part recognition, reporting, and mitigation.
- Specialized training for high-risk roles.
Auditing and Compliance:
- Conduct periodic internal audits to ensure compliance with policy, standards, and supplier performance.
- Maintain records of inspections, audits, and corrective actions.
Reporting:
Reporting:
- All occurrences of suspected or confirmed counterfeit parts must be reported internally and to applicable regulatory authorities or industry databases (e.g., GIDEP, ERAI, FAA, or other relevant agencies).
Documentation and Control
- Maintain all associated documentation, CoC, traceability records, and audit reports according to the company’s record retention policy.
- Ensure all updates to the counterfeit control plan are communicated to employees and suppliers.
Continuous Improvement
- Regularly review and update the plan to address evolving counterfeiting techniques and supply chain risks.
- Incorporate lessons learned from incidents, inspections, and industry alerts to enhance process effectiveness.
References
- SAE AS5553: Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition
- SAE AS6081: Counterfeit Electronic Components; Avoidance, Detection, Mitigation, and Disposition
- SAE AS6174: Counterfeit Materiel; Avoidance and Control
- ISO 9001:2015: Quality Management Systems
- AS6496: Counterfeit Part Avoidance Accreditation Program
- ANSI/ESD-S20.20: Electrostatic Discharge Control
This policy establishes a structured and comprehensive approach to prevent counterfeit components from entering the company’s supply chain, ensures conformance to industry best practices, and protects product integrity and customer trust.
