The final rule under DFARS Case 2012-D055, Detection and Avoidance of Counterfeit Electronic Parts , includes requirements for “electronic part traceability”. During the 16 June public meeting to discuss further implementation of counterfeit electronic part detection and avoidance requirements, industry presenters requested clarification and offered recommendations to address electronic part traceability expectations.  This specific requirement is one of the more controversial areas within the final rule, and where interpretations and expectations vary significantly. 
In my personal view, some interpretations wander significantly from the theme that government and industry counterfeit avoidance subject matter experts have described for the better part of a decade. As a ‘founding member’ of the SAE International G19 Committee and a major contributor to the original version of AS5553, I suggest that the origins of traceability for counterfeit electronic part avoidance derived from the fact that counterfeit parts tend to enter the supply chain through the open market. If one could acquire ‘unconsumed’ parts from authorized part suppliers or trace the hand offs of ‘unconsumed’ parts to the original component manufacturer (OCM) implied by marking on the device, packaging, CoCs, pack lists, or other artifacts, then the purchase and use of counterfeit parts would be avoided. I further suggest that the thinking of the original authors of AS5553 was that if one could not confirm this traceability at the ‘point of purchase’, then alternatives were to be considered to avoid the purchase; if the alternatives were not viable, then the lack of traceability called for tests and inspections intended to avoid counterfeits.
I do not recall any of the ‘founding members’ of SAE G19 suggesting that this part traceability requirement was intended to carry through to the delivery of weapon systems or equipment containing electronic parts. I do not recall establishing an expectation that, for example, a prime contractor must trace a part from its original production and unconsumed state, to a specific position in a reel containing thousands of parts, to a specific location on a specific assembly where the part is installed, to the specific next higher assembly, and so on. The organization’s processes met the expectations of AS5553 if the organization established part procurement and acceptance processes that (a) assured parts procurement from authorized sources; or (b), assured traceability to the OCM for parts procured from other suppliers when parts are not available from authorized sources; or (c), in the absence of traceability to the OCM, conducted inspections, tests and other methods designed to intercept and avoid the use counterfeits.  Taking a cue from government and industry subject matter experts, Congress included this expectation in the original legislation that initiated the final rule under DFARS Case 2012-D055. 
During several recent discussions with US Government representatives about electronic part traceability expectations, none of these representatives suggested that a more expansive requirement is implied by the proposed or the final rule under DFARS Case 2012-D055 or that strict requirements should be more broadly applied. In some these discussions, US Government representatives have expressed a general desire for industry to establish mechanisms to track a non-conforming part back to its origin or its ‘point of purchase’. At the same time, however, these representatives acknowledged that the cost to apply strict and expansive requirements for all applications would not substantiate the benefits.
From my experience, strict traceability requirements have typically been reserved for critical applications where opportunities to maintain or repair equipment generally do not exist (e.g. space flight equipment). For the vast majority of other projects, defense contractors and subcontractors have been able to identify, with reasonable accuracy, those products that may contain non-conforming parts without implementing strict and expansive traceability mechanisms. If the lack of strict electronic part traceability had caused significant, systemic and widespread issues for contractors, their customers and end users, I suspect that regulations for strict traceability requirements would have been established long ago and systems broadly established to support these requirements. Did the lack of strict part level traceability hamper the Senate Armed Services Committee’s investigation into how counterfeit parts enter the DoD supply chain?  Did it hamper the ability of US Government organizations to pursue the suspension and debarment of suppliers or criminal investigations associated with the entry of counterfeit parts into the DoD supply chain?
I suggest that universally strict and expansive part level traceability requirements are neither appropriate nor necessary. The objective here is to avoid the purchase of counterfeit electronic parts. It is not to establish traceability mechanisms for all parts from birth to retirement.
 Federal Register Vol. 79, No. 87 at p.26108, 252.246–7007(c)(4) Processes for maintaining electronic part traceability
 Federal Register Vol. 79, No. 90 at p. 26725
 “Detection and Avoidance of Counterfeit Electronic Parts-Further Implementation”,
(accessed 7 Oct 2014)
 SAE International Standard AS5553, http://standards.sae.org/as5553a/, (accessed 7 Oct 2014)
 H.R.1540: National Defense Authorization Act for Fiscal Year 2012, Sec. 818. Detection and Avoidance of Counterfeit Electronic Parts
 “Report of the Inquiry into Counterfeit Electronic Parts in the Department of Defense Supply Chain“, Senate Armed Services Committee, May 21, 2012 (112th Congress, 2nd Session, Senate Report 112–167)