‘Contractor Counterfeit Electronic Part Detection and Avoidance Systems’ … Part 6

Flowdown of Counterfeit Detection and Avoidance Requirements

Contractors and subcontractors should include counterfeit detection and avoidance requirements in subcontracts and purchase orders.[1] DFARS 252.246–7007 specifically requires the contractor to include the substance of the requirements for a “Contractor Counterfeit Electronic Part Detection and Avoidance System” in subcontracts. The expectation of DFARS 252.246–7007 is that counterfeit detection and avoidance requirements flow down at all levels in the supply chain that are responsible for buying or selling electronic parts or assemblies containing electronic parts, or for performing authentication testing.

Counterfeit avoidance and detection requirements should be context sensitive and relevant for the type of supplier and their role within the supply chain. For example, requirements directed to an upper tier subcontractor furnishing systems that contain electronic parts would differ from requirements directed to an electronic part distributor. In the case of an upper tier subcontractor, the flow down would include the substance of the requirements in DFARS 252.246–7007 that define a “Contractor Counterfeit Electronic Part Detection and Avoidance System”. In the case of an electronic part distributor, appropriate requirements would be for the distributor to supply only product for which it is an authorized supplier or to supply products acquired from a supplier that is an authorized supplier. Counterfeit avoidance and detection requirements should include an expectation of the supplier to flow down the requirements to its suppliers.

Henry Livingston


[1] DFARS 252.246–7007 (c) (9) Flowdown of counterfeit detection and avoidance requirements …

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