Client Alerts & Newsletters

With More to Come, DoD Expands Reach of Detection and Avoidance of Counterfeit Parts Requirements

August 2, 2016

Today, DoD published a final rule further – but still only partially – implementing the FY12 DoD Authorization Act requirement (since amended) for detection and avoidance of counterfeit electronic parts by imposing on all contractors and subcontractors, including small businesses and suppliers of COTS products and commercial items, traceability obligations and procedures for identifying “contractor approved sources” when electronic parts are unavailable from the original manufacturer or other source identified in the new clause (DFARS 252.246-7008). The new clause also provides for specific procedures to be followed, including notifying DoD and performing authentication, inspection, and testing to industry standards when electrical parts are obtained from subcontractors that refuse flowdown of the clause or from sources other than those expressly authorized under the clause.

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Alan W. H. Gourley
Partner – Washington, D.C.
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Email: agourley@crowell.com

Peter Eyre
Partner – Washington, D.C.
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Email: peyre@crowell.com

Adelicia R. Cliffe
Partner – Washington, D.C.
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Email: acliffe@crowell.com

Olivia Lynch
Partner – Washington, D.C.
Phone: +1.202.624.2654
Email: olynch@crowell.com

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