New DFAR Regulation on Counterfeit Avoidance Released - Lintech Components is Fully Compliant

In May 2014 the U.S. Government released DFAR Part 252.246-7007 Contractor Counterfeit Electronic Part Detection and Avoidance Systems. Lintech Components is fully compliant with this new contractual obligation faced by many of the company’s customers.

The new DFAR requirement specifies the controls and processes required for all government contractors in order to protect the military against the deleterious consequences of undetected counterfeit components. It requires “The inspection and testing of electronic parts, including criteria for acceptance and rejection. Tests and inspections shall be performed in accordance with accepted government- and industry-recognized techniques.” For the record, DFAR Part 252.246-7007 is very much in line with both the AS6081 and AS5553 standards, to which Lintech complies.

Lintech Components has always been ahead of the curve in the battle against counterfeit electronic parts and its multi-tiered CAPP program meets the new DFAR requirement in all respects. The company instituted its CAPP program five years ago in anticipation of the government’s response to the counterfeit parts problem plaguing the industry. Over the years, Lintech has invested heavily in equipment, training and practices to avoid and eliminate counterfeit product from the supply chain. Lintech’s incoming and outgoing procedures include comprehensive visual, dimensional and marking permanency inspections and Lintech possesses an extensive OCM die database.

DFAR Part 252.246-7007 does not require testing and inspection of all electronic parts; it allows contractors to make risk-based decisions based on supply chain assurance measures. Determinations of risk must be based on (1) the assessed probability of receiving a counterfeit electronic part; (2) the probability that the inspection or test selected will detect a counterfeit electronic part; and (3) the potential negative consequences of a counterfeit electronic part being installed where such consequences are made known to the contractor. 

To learn more about DFAR Part 252.246-7007, read this online posting by the international law firm of Crowell & Moring overviewing the rule—and providing some key insights into what it all means to suppliers—or view or download the entire requirement on Justia.com.

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