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Guidance on Counterfeit

  • Definitions of “counterfeit” and “suspect counterfeit.” The first step in formulating a counterfeit detection and prevention system is determining how to define an item as counterfeit. DODI 4140.67 defines the term “counterfeit materiel” as “an item that is an unauthorized copy or substitute that has been identified, marked, or altered by a source other than the item’s legally authorized source, and has been misrepresented to be an authorized item of the legally authorized source.” The instruction also includes a definition of “suspect counterfeit” materiel — an important concept given that steps must be taken to isolate and prevent introduction of parts that are suspected of being counterfeit even while efforts are ongoing to confirm their status as counterfeit. A suspect counterfeit item, materiel, or product is one “in which there is an indication by visual inspection, testing, or other information that it may meet the definition of counterfeit materiel.”

  • Definition of “authentic materiel.” The instruction also includes a definition of “authentic materiel,” in contrast to counterfeit materiel. Authentic materiel is “made from the proper materials using the proper processes with required testing.” Interestingly, while the definition of counterfeit materiel discusses actions taken by other than an item’s “legally authorized source,” the definition of authentic materiel says nothing about the processes needing to have been performed by an authorized source.

What You Should Know

Some examples, from real court decisions, of situations where the court said the distributor should have been tipped off that parts were counterfeit:

- Purchase are outside the usual distribution network of the manufacturer.

- The goods are sold without authenticating documentation or with altered documentation.

- The quality of the purchased goods differs dramatically from the quality expected.

- The price you paid was dramatically below the reasonable or suggested price

- Billing slips use mysterious or cryptic codes to describe the products purchased.

Counterfeit Prevention

The prevention of counterfeit components starts with suppliers. We keep a detailed list of approved sources by utilizing ISO certifications and surveys, Industry news groups, and order history to determine reliability. All suppliers must be qualified.

Methods of Prevention

When parts are received they are subjected to the processes below:

  • Complete Visual inspection.

  • Data sheet verification.

  • Device marking tests.

  • Component surface analysis.

  • Extensive use of high powered microscopy and digital photography.

    • If any discrepancy is noted further testing is completed: (Will also complete stage 2 testing by customer request)

  • X-Ray analysis, including in-tape reel-to-reel and in-tray inspections.

  • X-Ray Fluorescence Spectroscopy (XRF) testing.

  • Mechanical and Chemical De-capsulation, with microscopic die inspection.

  • Solderability testing.

  • Electrical testing.

  • Component blank check, erasing, and programming.