Every day, SMTC performs its due diligence to prevent the purchase and use of counterfeit parts. Our team works hard to meet the requirements of the AS5553 Standard for Counterfeit Electronic Parts Avoidance, Detection, Mitigation and Disposition.
Performing our preventative process of avoidance, detection and mitigation ensures that we:
- Maximize availability of authentic parts
- Procure parts from reliable sources
- Assure authenticity and conformance of procured parts.
- Control parts identified as counterfeit.
- Report counterfeit parts to other potential users and Government Investigative authorities.
The following is a comprehensive look at how, as a company, SMTC works every day to control the integrity of parts used in our manufacturing processes.
The scope of this document applies to purchasing/procurement activities at SMTC.
AS9100:2016 Quality Systems Certification
ISO 9001:2015 Quality Systems Certification
All of these systems have a requirement for verification of purchased products including but not limited to chemical and physical properties of raw material, used only of approved vendors, detecting and reporting suspected unapproved (counterfeit) parts, and control of inventory and records to provide positive identification and procedures to comply with the emerging industry requirements to detect and report counterfeit parts in order to prevent their release and propagation.
In the case of a conflict between the supplier and SMTC, SMTC requirements take precedence and include the following:
- AS9100:2016 Quality Management Systems Requirements
- AS5553, Counterfeit Electronic Parts: Avoidance, Detection, Mitigation, and Disposition
- ISO 9001:2015 Quality Management Systems Requirements
- FAA requirements
- Medical Systems Requirements.
Suspect Part (AS5553)
A part in which there is an indication by visual inspection, testing, or other information indicating the item may have been misrepresented by the Supplier or Manufacturer and may in turn meet the definition of a Counterfeit Part.
Suspected Unapproved Part (SUP) (FAA)
A part, component, or material that is suspected of not meeting the requirements of an approved part. A part that, for any reason, a person believes is not approved. Reasons may include findings such as different finish, size, color, improper or lack of identification, incomplete or altered paperwork, or any other questionable indication.
Counterfeit Part (AS5553)
A suspect part identified as copy or substitute without legal right or authority to do so or a part whose material, performance, or characteristics are knowingly misrepresented by a Supplier in the Supply Chain. The Counterfeit Parts include but are not limited to:
- Parts not containing the proper internal construction (die, manufacturer, wire bonding, etc.) consistent with the ordered part.
- Used, refurbished, or reclaimed parts represented as new products.
- Parts with a different package style, type, or surface plating/finish that the required or ordered product.
- Parts not successfully completing the full production and or test flow of the Original Component Manufacturer that are represented as completed product.
- Parts sold or delivered as up-screened product that have not successfully completed the up-screening process.
- Parts sold or delivered with modified labeling or markings intended to misrepresent the form, fit, function, or grade of the intended product. NOTE: Refinished, upscreened, or updated parts identified accordingly are not considered counterfeit product.
Counterfeit Part (FAA)
A part made or altered to imitate or resemble an approved part without authority or right, and with the intent to mislead or defraud by passing original or genuine.
A manufacturer meeting one or more of these criteria:
- A manufacturer authorized by the OEM to produce or provide replacement parts. The parts supplied originate from the OEM to the aftermarket manufacturer or an aftermarket manufacturer using OEM tooling or intellectual property produces the parts.
- The manufacturer produces parts using tooling or equipment manufactured by and traceable to an OEM that was properly stored until use. The parts are subsequently assembled, tested and qualified using processes that meeting the technical specification without violating the IP rights, patents, or copyrights.
- The manufacturer produces parts by emulation, reverse engineering, or redesign using processes matching the OEM specification. The parts must meet the Customers' needs without violating OEM IP rights, patents, or copyrights.
NOTE: The aftermarket Manufacturer must label or otherwise identify a part to ensure the "As Shipped" product is not mistaken for the product manufactured by the OEM.
Supplier who are formally assessed and determined to have a low risk of providing Counterfeit products.
Aftermarket manufacturer and OEM authorized sources of supply for specific parts.
In the independent distribution market, brokers are professionally referred to as independent Distributors.
A distributor with which the OEM has a contractual agreement to buy, stock, repackage, sell and distribute its product lines. When a distributor does not provide products in this manner, for the purposes of AS5553, the distributor is considered an independent distributor for those products. Franchised distributors normally offer the product for sale with fully manufacturer's flow-through warranty. Franchised contracts may include clauses that provide for the OEM marketing and technical support inclusive of, but not limited to, failure analysis and corrective action, exclusivity of inventory, and competitive limiters.
A distributor that purchases new parts with the intention to sell and redistribute them back into the market. Purchased parts may be obtained from the original equipment manufacturer (OEM) or contract manufacturers (Typically from excess inventories), or from other independent distributors. Re-sale of the purchased parts (re-distribution) may be to OEM's, contract manufacturers, or other independent distributors. Independent distributors do not have contractual agreements or obligations with OEMs.
Certificate of Conformance (C of C)
A document provided by the supplier formally declaring the purchase order requirements are met. The document may include information relative to the manufacturer, distributor, quantity, date code, inspection date that is signed by a responsible associate for the supplier.
Certificate of Conformance and Traceability (C of CT)
A certificate of conformance applicable to some military specifications requiring documented traceability of the product from the Qualified Parts List / Qualified Materials manufacturer through the product delivery to the Government.
A privately held global trade associates who monitors, investigates, reports, and mediates issues effecting the global supply chain of electronics including the supply of counterfeit and substandard parts.
A cooperative actively between the Government and Industry participants seeking to reduce or eliminate expenditures of resources by sharing technical information essential during research, design, development, production and operational phases of the life cycle of systems, facilities and equipment.
Component packaging refers to the manner in which individual or grouped parts are packaged in preparation for distribution and use.
Using a plating process method after manufacture to alter the original plating composition on a parts lead or lead wire.
Subjecting parts to a process method after manufacture to brighten, polish, renovate the item in an effort to restore the item to a "like new" condition. Refurbished electronic parts may have the leads realigned and tinned.
Additional part testing performed to produce parts verified beyond the specification parameters of the manufacturer.
Electrically charged parts removed from a prior application. Parts should be examined for nonstandard packaging, mixed lots/date, parts from various sites, scratches, bends, test dots, faded marking, chemical residue, or other signs of use. Used parts may be sold with limited warranty. Programmable products may still contain partial or complete programming capability that may affect part functionality. Used parts marketed as such should be declared accordingly.
The Quality Manager is responsible for implementation, oversight and training related to implementing an SMTC Counterfeit Parts avoidance and detection system in accordance with the SMTC Quality System.
Purchasing is responsible to procure the correct part/material using the applicable drawing, specification, description, or other information to ensure the product meets the customers Build of Material as intended to use. Purchasing is also responsible for including terms and conditions of purchase orders to include C of C containing the following information:
MPM, where the part was manufactured, LOT or Date Code, the mandatory use of "New UNUSED Stock" and that the parts comply with the OEM part specifications.
Receiving and Inspection is responsible to examine, inspect, and/or control the pats to identify or mitigate the receipt and /or use of counterfeit parts.
This process maximizes availability of authentic, originally designed and/or qualified parts throughout the product's life cycle, including management of parts obsolescence.
Purchasing must examine a potential source of supply to assess the risk of receiving counterfeit parts. Assessment may be a survey, audit, product alert review, and a review of supplier quality data to verify past performance. The goal is to ensure that approved sources of supply are maintaining effective processes for mitigating the risks of supplying counterfeit parts.
Purchasing must also maintain a list of approved suppliers along with their scope of approval in order to minimize the risk associated with the supply and /or receipt of counterfeit parts.
Finally purchasing places a priority on obtaining parts directly from the OEM, approved distributor, authorized resell organization or franchised aftermarket supplier. These companies are reviewed and approved by the original component manufacturer as well as monitored by SMTC vendor approval process.
Purchasing may reference the supply chain traceability in accordance with the AS9100:2016. At a minimum, the OEM, distributor or aftermarket manufacturer will be required to provide certificates of conformance and acquisition traceability. These certifications requirements must be clearly identified on the Purchase Order document as deliverable data.
In general, product with electronic components destined for Government or Military use requires a manufacturer certification.
Specific requirement for the product may be identified from a review of the Customer purchase order, specification, or flow down requirements. It is always prudent for purchasing to request certification and traceability data as a deliverable item even if not specifically required by the customer.
Purchasing must specify the flow down requirements from the Counterfeit Parts Procedure applicable to the supplier or subcontractor. Purchasing must perform some level of risk assessment if the supplier or subcontractor does not maintain a documented counterfeit part control plan compliant to the SMTC A5553, in accordance with AS9100:2016.
The Purchase Order must specify to the supplier the applicable requirements of the Counterfeit Part Procedures. In order to minimize the risk of procuring counterfeit parts the Purchase Order will include requirements to ensure conforming, original, and authentic parts are provided. The Purchase Order may list requirements for Certification and Traceability; deliverable record of test and/or inspection results; and quality management system requirements for the supplier.
Persons receiving, inspecting, or processing parts/materials must examine the product to ensure the drawing, specification, type, class, style, part number, manufacturer, Certificate of Conformance or other related information is present to detect or identify suspect or counterfeit parts. Suspect or counterfeit parts are recorded on SMTC Non-Conforming Material Report so the items may be identified and segregated in accordance with SMTC Quality Procedure for Nonconformance Control.
Quality Manager- will initiate an investigation and will ensure that all occurrences of counterfeit parts are reported, as appropriate, to internal organizations, customers, Government reporting organizations (i.e. GIDEP, FAA), industry supported reporting programs (i.e. ERAI), and criminal investigative authorities. This reporting guidelines are outlined in AS5553.
SMTC considers the due diligence applied to a material purchase successful when this procedure is followed and when finished product meets the test or inspection requirements identified for the product by the Customer or accepted industry standards established for the product. Failure of a component or other nonconformance does not necessarily mean the instance was caused by a counterfeit part. SMTC Quality Assurance will investigate and verify the cause of the nonconformance and determine the appropriate disposition the defect in accordance with SMTC policies.