On September 21, the Department of Defense published proposed amendments to the Defense Federal Acquisition Regulation Supplement regarding the detection and avoidance of counterfeit electronic parts. The Electronic Components Industry Association, which represents manufacturers and distributors of electronic components, has urged members to comment on the proposed changes, which largely address definitions and traceability of electronic components, as well as coverage issues. Members can comment by contacting ECIA directly; comments are due by November 20, 2015.
Key changes to definitions include revising the definition of the term electronic part by removing references to embedded software and firmware, and adding the terms original manufacturer, authorized dealer, and trusted supplier to the rules governing the purchase of electronic components by government contractors.
In regard to traceability issues, the proposal would require contractors to use risk-based processes that consider the failure of electronic parts. This would involve tracing the part from original manufacturer through to acceptance by the government. It would also require evaluations that include testing and inspection and the consideration of alternative parts, if traceability cannot be established.
When it comes to expanded coverage, the proposal directs contractors to flow down all requirements to all tiers of the supply chain and extends coverage to COTS (commercial, off-the-shelf) parts.