An Assessment of the Proposed DFARS Rule on Detection and Avoidance of Counterfeit Electronic Parts (DFARS Case 2012-D055)

The Department of Defense (DoD) is proposing to revise the Defense Federal Acquisition Regulation Supplement (DFARS) to implement, in part, the counterfeit electronic parts prevention requirements described in Section 818 of the National Defense Authorization Act for Fiscal Year 2012 (NDAA2012 §818). While definitive countermeasures can be applied by contractors to manage this problem more effectively, the global nature of the supply chain and current U.S. Government policies, including requirements and exemptions described within the proposed rule, continue to present significant barriers to eliminating counterfeit products from the supply chain altogether. The proposed DFARS rule on “Detection and Avoidance of Counterfeit Electronic Parts” places responsibility for detecting and avoiding the use or inclusion of counterfeit or suspect counterfeit electronic parts almost exclusively upon large contractors. The proposed rule, however, does not address important issues and leaves a number of gaps unresolved. The following paper discusses each of these issues and offers recommendations to address them:

H. Livingston, “An Assessment of the Proposed DFARS Rule on Detection and Avoidance of Counterfeit Electronic Parts (DFARS Case 2012-D055)”, June 2013.

 

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One thought on “An Assessment of the Proposed DFARS Rule on Detection and Avoidance of Counterfeit Electronic Parts (DFARS Case 2012-D055)

  1. Owen Peters says:

    Henry, You’ve done it again. An incredible job. Thank you.

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