ALPHARETTA, GA -- Saying most contractors to the US Department of Defense would be subject to mandatory reporting under a new proposed amendment to the DoD's anti-counterfeiting measures, the Electronic Components Industry Association is calling for more clarity on the requirements. 

In a statement on its website, ECIA said FAR Case 2013-002 proposes to expand government and contractor requirements for reporting “nonconforming items.” If the proposed FAR amendments are adopted, counterfeit items would be considered nonconforming items. This expansion of coverage would apply to existing FAR quality assurance requirements and to most, if not all, items sold to the US government, ECIA said.

 ECIA, which represents authorized component distributors, says the June 10 amendment could result in a "flood" of nonconformance reports. "One distributor noted that the company typically processes 25 to 30 failure analysis requests per week for nonconforming parts, of which 90 to 95% are shown to be "no defect found. Another distributor receiving hundreds of receiving rejections per month and would be unable to process that volume of GIDEP reports, most of which were due to manufacturers sending the wrong parts."

GIDEP is the Government-Industry Data Exchange Program, a cooperative program intended to streamline   research, design and production among companies supplying to the US or Canadian DoD.

The proposed amendment was released by the DoD, the General Services Administration (GSA) and the National Aeronautics and Space Administration (NASA).

ECIA said the electronics industry should note that this proposal extends anti-counterfeit efforts to businesses of all sizes – no exceptions for small and non-CAS covered businesses. Commercial-off-the-shelf (COTS) items are also included. "While the rule would apply to government contractors, it is likely that many in the industry could be subject to the mandatory GIDEP reporting requirements," ECIA said.

The trade group asserts industry should also expect contractors to flow-down the requirements. Contractors would be required to use GIDEP for two purposes:

• Screening GIDEP reports to avoid the use and delivery of items that are counterfeit or suspect counterfeit or that contain major or critical nonconformance.
• Reporting to GIDEP an item purchased by or for the government that is counterfeit or suspect counterfeit; or contains a major or critical nonconformance that is a “common item” and constitutes a “quality escape” that has resulted in the release of like nonconforming items to more than one customer.