The electronic components manufacturing industry has promoted for many years what is now accepted as the keystone to counterfeit avoidance practices – the procurement of parts from the Original Component Manufacturer (OCM) or its ‘authorized distributors’. Congress has also embraced this practice as a core element of a ‘trusted supplier’ approach designed to prevent counterfeit electronic parts from entering the DoD supply chain (see FY2012 NDAA Sec. 818(c)(3)(A)(i)).
Though the electronic components manufacturing industry has deployed resources to help identify ‘authorized distributors’, it has not, to my knowledge, (1) formally defined the term ‘authorized distributor’, or (2) established a program to certify distributors as ‘authorized’.
I am aware of two standards providing a definition for the term ‘authorized distributor’ (or ‘franchised distributor’), both were developed by the A&D electronic equipment producer and user community:
- SAE International Aerospace Standard AS5553, Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition
- TechAmerica Technical Bulletin TechAmerica-TB-0003: Counterfeit Parts & Materials Risk Mitigation
The semiconductor manufacturing industry developed a standard that, though it does not define the term, includes key requirements that are generally associated with an ‘authorized distributor’ of semiconductor components:
- JEDEC Standard JESD31, General Requirements for Distributors of Commercial and Military Semiconductor Devices
I encourage A&D companies and industry associations, such as AIA and TechAmerica, to engage organizations such SIA and ECIA to discuss the need for standards that define the term ‘authorized distributor’ and describe specific requirements for an ‘authorized distributor’. Here are my own thoughts about what should be considered to meet the needs of A&D companies and DoD organizations to help manage the counterfeit parts threat:
- Develop a definition and criteria that covers electronic parts commodities at large (not just semiconductor products)
- Develop a definition that clearly states that when a distributor does not provide products based on defined criteria, the distributor is to be considered an Independent Distributor.
- Develop criteria that adopts the key tenets described in JESD31 (e.g. product integrity via proper handling, storage and shipping procedures; traceability; certificates of conformance; documentation to be supplied)
- Develop criteria that adopts key tenets associated with formal agreements between OCMs and the authorized distributor (e.g. extension of manufacturers warrantee, technical support coverage, inventory and product return controls)
- Establish a formal, centralized, readily accessible and well managed directory of authorized distributors
- Explore the feasibility of establishing a program to formally certify distributors as ‘authorized’.