I have been involved in counterfeit mitigation since early 2009. I’ve had hundreds of interesting conversations with peers and industry experts. Yesterday it dawned on me what was happening to the commercial off the shelf (COTS) market for parts. Defense contractors and the DOD are trying hard to make the COTS industry conform to QPL or military conformance. Whether it is a conscious effort or not, is yet to be seen. The problem is the COTS industry has not done this in the past and now has problems complying. It’s not that the COTS industry doesn’t want to do it, it’s just the infrastructure and specific records required don’t exist.
The biggest example of this is the requirement for MFG Certificates of Conformance. It’s well known in authorized distribution that COTS generally do not come with MFG Certificate of Conformance. What we do get is a commercial pack list from the MFG. It may or may not have a Certificate of Conformance; it may or may not be signed. Some are of poor quality. But these are the documents of product origin that we will keep for 10 or more years. AS5553 talks about this in Appendix C.2.1. What’s available on COTS, paraphrased as “commercially acceptable packing list…not supplied to the end customer.” The writers of AS5553 knew what you could get on COTS and they wrote it down.
Chuck Amsden is the former Vice President of Quality at Mouser Electronics. Amsden joined Mouser in 2003 and helped lead the company to obtain ANS9120A/ISO9001:2008 and ANSI/ESD S20.202007 certifications. Amsden was a contributing member of three SAE G-19 committees, working on standards for mitigating counterfeits in the electronic components supply chain. He also chaired a committee in the Electronic Components Industry Association (ECIA) that developed methods of traceability within authorized distribution and served on the ECIA Certification Task Force focused on mitigating counterfeits.