The U.S. Department of Defense has taken a step towards establishing counterfeit prevention requirements for contractors. Late last month the DOD released a document which details who within the department has what specific responsibilities for counterfeit prevention. From undersecretaries of defense on down, Department of Defense Instruction Number 4140.67, spells out various tasks and oversight in the effort to prevent counterfeit parts from entering the DOD supply chain. The document, issued April 26, 2013, also talks about responsibilities for properly flagging parts which are considered possibly counterfeit.
It is worth noting that this document is not limited to discussing counterfeit electronic components. Rather, it talks about counterfeit components in general. Although counterfeit electronic components still represent the largest area of concern, a wide range of parts sold to the DOD can be targets of counterfeiting.
The main purpose of this document is to define areas of responsibility, an important step in creating a comprehensive risk mitigation plan. In defining those areas, Instruction 41460.67 gives some of the boundaries of the counterfeit protection system the DOD is mandated to establish.
What is a counterfeit component? This document defines it as: “an item that is an unauthorized copy or substitute that has been identified, marked, or altered by a source other than the item’s legally authorized source, and has been misrepresented to be an authorized item of the legally authorized source.”
Instruction 4140.67 also specifies that the DOD will use GIDEP to report counterfeit components. Further, the document states the DOD should avoid establishing DoD-unique anti-counterfeiting procedures, a hopeful sign that DOD requirements will co-exist well with emerging industry standards.
Based on reviewing the DOD Instruction No: 4140.67, I am eagerly looking forward to seeing how the Section 818 “Parts Regulations” will address having all contractors report all occurrences of suspect or confirmed counterfeit parts to GIDEP.
I am interested in how it will address counterfeit materials broadly rather than being limited to the counterfeit parts addressed in section 818. Another area of interest is what is planned for the strict requirement designation to both critical and susceptible to counterfeiting items being traceable back to the manufacturer through a unique item identifier.