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1 GE Title or job number
05/03/2023
Anti-counterfeit standards summary July 2015 Prepared by: Jo VannIEC TC107 WG3 ‘Counterfeit electronic parts; avoidance, detection, mitigation, and disposition in avionics applications’ convener , see http://www.iec.ch/dyn/www/f?p=103:14:0::::FSP_ORG_ID,FSP_LANG_ID:5736,25Member of SAE: G19A, G19AD, G19C, G19CI, AMPC, IAQG
2 GE Title or job number
05/03/20232
The Avionics Supply Chain
1. Parts & Materials Suppliers
2. Board Assemblers
3. Avionics OEMs,
Logistics, Maintenance
and Repair
4. Platform Integrators
5. Operators & Regulators
Parts
Boards
Contract Mfg.
Suppliers CustomersSolder etc. SuppliersCustomers
15 - 40 yrLifecycle
3 - 6 yrLifecycle
IEC/TS 62668-1/SAE AS5553A Anti-counterfeit and IEC/TS 62239-1
ECMP
Most life cyclecosts are incurred here and managed by ECMP
Global Supply ChainSAE AS5553A counterfeit avoidance
Requirements flow-down vs.
products flow-up process is
disrupted here
Aerospace Captive
To build products that must meet mil-aero requirements
(what we must control)
Using COTS components targeted for other markets (what we cannot control)
Aerospace Electronics• Depends on
materials and components developed for other industries
• Vastly different lifecycle applications
3 GE Title or job number
05/03/2023
What is the problem? • In 2010/2011 the USA DoD identified upwards of a million counterfeit
components in their Military supply chain. This resulted in the 2012 NDAA section 818 anti-counterfeit clause which
was published May 2014 as DFAR 252.247.7007 • Researcher IHS analysed electronics industry data in 2013 concerning
counterfeit parts that were reported from 2001 until early 2012: More than 12 million counterfeit parts have been reported over
the last five years to 2013 57% of counterfeit part reports involved obsolete or end of life
parts. Nearly 37% of counterfeit parts involve components still being
produced by manufacturers. A single incident of a counterfeit part can cause up to 64 weeks of
production line downtime and cost up to $2.1 million to resolve. Counterfeit parts are mostly sold on the open market.
4 GE Title or job number
05/03/2023
Recycling - typically occurs in China
5 GE Title or job number
05/03/2023
International anti-counterfeit standards SA
E IEC
IEC/TC10
7 WG3
G-14 AAQS
C
IEC/TS62668-2
G19A
IEC/TS62668-1
G19AD G19C
AS6171 Test Metho
ds
AS6496 Franchis
ed distribut
or
AS6301,AS6462audit
checklists
G19CI
AS5553
electronic compone
nts
G21
AS6174
materiels
AS9100 Rev D
for publicati
on 2016/17
6 GE Title or job number
05/03/2023
Military Supply Chains and contract flow-down
USA Militar
y
UK Militar
y
DFARS in
contracts
DEF STAN 05-135
anti-counterfe
it
DFAR 252.246.
7007 electrica
l anti-counterf
eit
OEM
SAE AS5553
flow-down to supplier
s
OEM supplier
s
SAE AS6496
Franchised
distributors
ARP 6178 non-
franchised
distributor
SAE AS6171 Material
s
7 GE Title or job number
05/03/2023
Anti-counterfeit standards summaryStandard Market
sectorDescription Comments
AS/EN/JISQ9100
Avionics OEMS
General Quality Management System
All Avionics OEMs are expected to operate to this standard which is currently at rev C. Next revision (rev D) for publication in 2016/2017 will include anti-counterfeit management requirements for material, mechanical and electrical components
SAE AS5553 General industry but mainly used by Avionics OEMs
Set of 11 mandatory detailed requirements for how to buy, manage, and dispose of electronic components with reporting mechanisms when counterfeits are found
Currently at revision A. Can be used to satisfy AS9100 rev D electrical component anti-counterfeit requirements. Next revision is in process to align it better with DFAR 252.246.7007. Mandated by most USA Prime Contractors.
SAE AS6174 General industry but mainly used by Avionics OEMs
Similar to SAE AS5553 for the procurement, management and disposal of electronic components but modified for material and mechanical components
Can be used to satisfy AS9100 rev D anti-counterfeit requirements. Use rev A. It is recognised this is a WIP as many appendices are not yet complete. Please join the committee if you have concerns contact Robert Tipton, [email protected]
USA DFAR 252.246.7007
Military US supply chain OEMs
Set of 12 mandatory detailed requirements for how to buy, manage, and dispose of electronic components with reporting mechanisms when counterfeits are found
Used in US Military contracts. Set of mandatory rules for covering how to buy and dispose of electronics components with reporting rules when counterfeits are suspected or found. Exceptions not allowed. Can use SAE AS5553 and /or IEC/TS 62668-1 and IEC/TS 62668-2 to comply
8 GE Title or job number
05/03/2023
Anti-counterfeit standards summaryStandard Market
sectorDescription Comments
UK Defence Standard 05-135
UK Military supply chain OEMs
General overall anti-counterfeit requirements
Used in UK Military contracts. Part of the UK Counterfeit Avoidance Maturity model which is used to assess how ‘counterfeit aware’ suppliers are. Can use SAE AS5553 and /or IEC/TS 62668-1 and IEC/TS 62668-2 to comply
IEC/TS 62668-1
Avionics OEMs Anti-counterfeit requirements for the purchase and management of electrical components, management of the products IP and control of spares and repairs
Allows the use of SAE AS5553 plans for components coming into a business and will allow the use of AS/EN/JISQ anti-counterfeit plans. Considered to provide a more ‘holistic’ approach to anti-counterfeit and recycling component management . Preferred by European Prime contractors and suppliers who do not want to work to SAE AS5553.
IEC/TS 62668-2
Avionics OEMs Risk assessment of electrical components purchased from non-franchised sources
Complements SAE AS5553 which has no risk assessment process for non-franchised purchases and IEC/TS 62668-1.
9 GE Title or job number
05/03/2023
Anti-counterfeit standards summaryStandard Market
sectorDescription Comments
SAE AS6496 Franchised distributor for high reliability, Aerospace and Defence market
Fraudulent/Counterfeit Electronics parts: Avoidance, Detection, Mitigation and Disposition- Authorised/Franchised Distribution
Released 2014
SAE AS6171 Component Test Houses for any market
Test Methods Standards; Counterfeit Electronic Parts
WIP- several individual test methods are ready for release: Test method I – External visual, Test method II- XRF .Debate about risk mitigation method and whether it should be part of SAE AS5553B.
AS6081 Non-franchised distributors
Fraudulent/Counterfeit Electronics parts: Avoidance, Detection, Mitigation and Disposition- Distributors; Counterfeit Electronic Parts: Avoidance Protocol, Distributors
Parts are offered by non-franchised distributors with some basic testing which Avionics OEMs need to review in their application risk assessment process. Considered an input into SAE AS5553 or IEC/TS 62668-2 risk assessment
ARP 6178 Non-franchised distributors
Fraudulent/Counterfeit Electronic Parts: Tool for Risk Assessment of Distributors
Very useful Excel spread-sheet with macro to remotely audit non-franchised distributors. Considered an input into SAE AS5553 or IEC/TS 62668-2 risk assessment
10 GE Title or job number
05/03/2023
Anti-counterfeit standards summaryStandard Market
sectorDescription Comments
AS6462A Auditing bodies and OEMS
AS5553A Counterfeit Electronic Parts: Avoidance, Detection, Mitigation and Disposition Verification Criteria
Audit checklist for SAE AS5553A for use by OEMs and Third party auditing bodies.
AS6301 Auditing bodies and OEMS
AS6081 Fraudulent/Counterfeit Electronics parts: Avoidance, Detection, Mitigation and Disposition- Distributors Verification criteria
Issued in 2014
AIR6273 For everyone using other SAE anti-counterfeit standards
Terms and Definitions- Fraudulent/Counterfeit Electronic parts
Draft – still WIP
11 GE Title or job number
05/03/2023
2015 anti-counterfeit supply chain
12 GE Title or job number
05/03/2023
• Personal liability for employees of companies under the new charge of trafficking in counterfeit military goods: Fines and imprisoned (up to 20 years if claim ‘not guilty’ and later found
guilty). Impacts countries with weak extradition laws to the USA, e.g. the UK.
• Potential DFAR implementation issues: ‘Traceability back to the original component manufacturer’ clause :
Prime contractors i.e. air-framers are finding this clause a massive challenge and are seeking to limit this to just the traceability to the first assembly of a LRU. This has been agreed.
A revision to SAE AS5553 rev A was started last year to incorporate any many DFAR requirements as possible. The draft was also streamlined significantly. However this failed an SAE ballot in November. Further discussions with the DoD have been held with a way forward. The G19 committee has just started up again working to create SAE AS5553 rev B with an optimistic target publication date of December 2014.
• DFAR definition of counterfeit (same in SAE AS5553A), also includes fraudulent components in addition to fraudulent recycled components and is unique to the USA.
USA Military DFAR rule 252.246.7007 includes:
13 GE Title or job number
05/03/2023
USA prosecutions in 2014• Vision Tech in Florida in 2010, discussed last year• June 2014 Massachusetts-based distributor Peter Picone of
Epic International Electronics Inc., pleaded guilty to trafficking in falsified ICs that had been resurfaced to change the date code and to affixing counterfeit marks destined for military equipment. The counterfeit parts bore the trademarks of legitimate companies such as Xilinx, National Semiconductor and Motorola. He faces 46 months in jail after pleading guilty.
This is the second prosecution on the new charge of trafficking in counterfeit military goods, see http://www.law.cornell.edu/uscode/text/18/2320
The court has taken the unprecedented step of publishing all the components Mr. Picone ever sold to the US Navy and it implicates nearly all the non-franchised distributors in the USA.
• The DFAR resulted from the 2012 Section 818 National Defence Authorization Act (NDAA) signed by President Obama on Dec 31st 2011. Some parts of this legislation are still outstanding
14 GE Title or job number
05/03/2023
NDAA section 818 DFARS For US Military Programs
The latest open DFAR Cases register is located at http://www.acq.osd.mil/dpap/dars/opencases/dfarscasenum/dfars.pdf which contains several impending DFAR cases related to section 818 legislation approved by President Obama As of June 0th 2015 the following are pending:
2015-D020 , DoD use of Trusted Suppliers for Electronic parts. Status report due data extended to 6/24/2015
2014-D005, ‘Detection and Avoidance of Counterfeit Electronic Parts-Further Implementation’, requiring that electronic parts be obtained from ‘trusted suppliers’: The Case manager has forwarded a draft final DFARS rule to the processing manager.
2014-D021, Item Unique Identification (IUID) Prescription Correction, to modify DFAR 252.211-7003, as some wording was lost. Report due extended to 6/3/2015.
Audit activities are part of the Purchasing Systems evaluation see DFAR 252.244.7001 where it is thought that DCMA may develop a new counterfeit detection and detection systems checklist
15 GE Title or job number
05/03/2023
UK Defence Standard 05-135 – Avoidance of counterfeit material, published July 2014 • High level language requiring a clear requirement to manage the
risk in supply chains depending on the criticality of the material in relation to performance and safety where the supplier is aware of the final use of the materiel.
• The supplier shall be able to demonstrate the materiel meets the original qualification requirements and the safety and performance of the deliverable materiel and ensure it is not degraded.
An anti-counterfeit policy Flow-down to suppliers Appointment of a management representative Training Purchasing controls Test and verification Control of non-conforming product Reporting
16 GE Title or job number
05/03/2023
IEC committee TC107 WG3 Counterfeit electronic parts• see http://www.iec.ch/dyn/www/f?p=103:14:0::::FSP_ORG_ID,FSP_LANG_ID:5736,25
• Published a revision in 2014, explaining when recycled components become fraudulent recycled components for the Chinese National Committee.
IEC/TS 62668-1, ‘PROCESS MANAGEMENT FOR AVIONICS – COUNTERFEIT PREVENTION – Part 1: Avoiding the use of counterfeit, fraudulent and recycled electronic components
Allows the use of SAE AS5553A plans for components coming into the business.
Enables OEMs to have one overall plan for SAE AS5553A and IEC/TS 62668-1 Discusses when recycled components become fraudulent components and
why the Avionics industry cannot use them. A revision is on-going in 2015 to add in references to the DFAR, Defence
Standard, AS9100 rev D and remove the Chinese RECS scheme which is not being maintained.
Refers to the now published IEC/TS 62668-2 ‘PROCESS MANAGEMENT FOR AVIONICS – COUNTERFEIT PREVENTION – Part 2: Managing electronic components from non-franchised sources.
Used as the IEC/TS 62668-1 non franchised distributor risk assessment process.
Can also be used as a risk assessment process for the following: o SAE AS5553A, o DFAR rule 252.246.7007 o DEF STANDARD 05-135
17 GE Title or job number
05/03/2023
SAE International Anti-counterfeit Specifications • SAE AS5553A for Electronic components• See http://www.sae.org/
• G-19 committee has active membership mainly from the USA and UK • SAE AS5553A was published in January 2013 superseding SAE AS5553
which has misleading definitions.• Manages components coming into a business only.• Targeted at general industry and AS9100 requirement is not
mandatory.• Revision B was started to incorporate DFAR 252.246.7007 to the
extent that general industry will allow, but recent ballot of Nov 2014 failed. Further meetings are planned with the DOD in Washington DC in March.
• The SAE has no Third Party auditing activities and is only publishing standards and auditing checklists.
• Was endorsed for use by the DoD for USA Military supply chains in 2013 but there is dispute about whether the new revision B will be adequate.
• The audit checklist for SAE AS5553A is published as SAE AS6462A.
• IECQ WG06 has started to create the administration documents for SAE AS5553 auditing
18 GE Title or job number
05/03/2023
How oneanti-counterfeit plan can address:
DEF STD 05-135DFAR 252.246.7007 SAE AS5553A IEC/TS 62668-1
using the non-franchised risk assessment processfrom: IEC/TS 62668-2
19 GE Title or job number
05/03/2023
Key elements for an anti-counterfeit plan Publish a plan addressing each requirement of the external standard and/or
provide a cross reference matrix . This protects your business in legal court cases. Establish company standard Purchase Order notes which state unambiguously that ‘
no counterfeits or recycled components are allowed’. Orders shall be placed for traceable components from OCMs or franchised
distributors or franchised aftermarket distributors. Traceability can be demonstrated by the C of C’s , packing slips, shipping label
information, part marking information ( lot date codes etc.) and are required for each part of the supply chain back to the original manufacturer.
Accurate part numbers on the PO to the internal component database information or BOM to that on the received C of C or Packing slip are required to prove traceability. Each part of the supply chain has to provide this level of traceability back to the original component manufacturer. Distributors who automatically default to their internal part number and ship against this, loose supply chain traceability and cannot be used.
Accurate, clear Shipment labelling, C of Cs, packing slip details are required from the Distributors.
Transcription errors, truncated part numbers, bad handwriting, unexplained quantities or quantities that do not add up after a stock split will results in parts being identified as ‘suspect’ when they are possibly just badly labelled.
Supply chain anti-counterfeit audits have started. Non-franchised distributors require a risk assessment and every order placed
may need anti-counterfeit testing for example to IEC/TS 62668-2 or SAE AS7171 or SAE AS6081 . Special test specifications will be required. Approval from customers may be required.
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Overview
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Anti-counterfeit summary 2012
Contact information: Jo Vann, TC107 WG3 Anti-counterfeit convenor, CEO- Component Technology , GE Aviation Systems Ltd., T +44 (0)1242 632927F +44 (0)1242 661151E [email protected]/aviation