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Strategies to Eliminate Counterfeit

1. Avoidance in acquiring counterfeit components

(i) Procuring directly from the Original Component or Equipment manufacturer


(OCM/OEM) should be the first preference.
(ii) OCM Authorized Distributors should be chosen only if OCM/OEM is not available for
supply of the components.
(iii) OCM Authorized distributors should have documented agreements with a
manufacturer to sell their items. Authorized distributor status should be verified with
the manufacturer.
(iv) Purchase orders terms and conditions should mention that suppliers use OCMs or
their authorized sources for products and provide the OCM/OEM traceability
documentation when requested which could include

–OCM/Authorized supplier certificates of conformance


–OCM/Authorized supplier shipping and receiving documents
–OCM/Authorized supplier packing slips.

(v) Anticipate obsolescence issues in time to initiate actions such as redesign or lifetime
buys.
(vi) Provide training to the personnel involved in this process.

2. Detection of counterfeit components before use

During placement of order following points to be kept considered:

(i) Items coming from source other than the OCM or authorized sources from suspect
locations.
(ii) Price too low/significantly different from history
(iii) Scarce items becomes suddenly available
(iv) Chain of ownership unverifiable.
(v) Obsolete items
(vi) Unknown supplier.

Visually examine and verify the component and related documents to ensure the absence of
following:

(i) Non-homogeneous lot.


(ii) No certificate of conformance.
(iii) CoC traceability not leading to OEM
(iv) Prohibited materials present.
(v) Item marking issues:
 Does not match similar items
 Alterations/resurfacing
 Incomplete
 Wrong size/location/methods
 Difference in quality of appearance.
 Lot number/date code issue.
(vi) Package/construction issues
 Size/shape/color/finish/materials
 Evidence of rework/repair/refinishing/resurfacing
 Poor quality.
3. Mitigation of issues due to counterfeit components

If supplier is not part of the OCM authorized supply chain following actions should be
initiated:

– Standard PO terms and conditions include requirements for notification and written
approval to utilize a non-authorized source.

– This notification must occur before the procurement takes place (with the Independent
Distributor or Broker).

– Review contract with end customer to determine reporting requirements, if any.

– Review criticality information that may require specific authenticity or detection testing
be completed in order to prove its authenticity/genuineness.

– Ensuring that processes are in place to quarantine parts that require testing and
verification until they are verified as authentic - treat them as suspect until evidence
proves otherwise.

4. Disposition of counterfeit components

- Maintaining counterfeit parts or materials in quarantine, clearly identified as non-


conforming/counterfeit product, pending a review.

- Counterfeit parts should not be returned to the supplier in such a way that they could be
re-introduced into the system of supply chain and to be re-sold again to another victim.

- Legal authorities may be contacted to initiate an investigation into the counterfeiting


activity. If an investigation is initiated, parts may be required as evidence.

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