Counterfeit parts and cable assemblies: what actually flows down to you

The two clauses

DFARS 252.246-7007, Contractor Counterfeit Electronic Part Detection and Avoidance System, requires a system of risk-based policies and procedures. It enumerates what that system must cover at a minimum, including training of personnel; inspection and testing, with acceptance and rejection criteria; processes to prevent counterfeit parts proliferating; tracking parts from the original manufacturer to acceptance by the Government; use of approved suppliers; reporting and quarantining suspect parts; methods to determine quickly whether a suspect part really is counterfeit; flow-down of comparable requirements to subcontractors; keeping current with counterfeiting trends; screening GIDEP and other credible sources; and control of obsolete parts.

Failing to maintain an acceptable system is not a paperwork problem. It can lead to disapproval of the purchasing system by the Contracting Officer, withholding of payments, and the cost of counterfeit parts and the rework around them being disallowed.

DFARS 252.246-7008, Sources of Electronic Parts, sets the sourcing order. Parts are obtained first from the original manufacturers, their authorized suppliers, or suppliers who obtain the parts exclusively from those two. Where that is not possible, parts may come from contractor-approved suppliers, provided the contractor applies established counterfeit prevention industry standards and processes — inspection, testing and authentication — and takes responsibility for authenticity. Where parts come from neither, or cannot be confirmed as new and unused, the contracting officer is notified promptly in writing, inspection and authentication are carried out to the applicable standards, and the documentation is kept available to the Government.

The definition that catches harness buyers

Read 252.246-7007's own definition before assuming it covers what you are buying. An electronic part is “an integrated circuit, a discrete electronic component (including, but not limited to, a transistor, capacitor, resistor, or diode), or a circuit assembly”.

A circular connector is not in that list. Neither is a contact, a backshell, a length of M22759 wire or a braided shield. A cable assembly built from those items is, on the face of the clause, largely outside its definition — until the assembly contains a circuit assembly, at which point it is squarely inside.

Three practical consequences follow, and they pull in different directions:

• The clause may still be in your purchase order. Primes flow down whole clause blocks rather than tailoring them per commodity. A clause that does not reach most of your product is still a clause you are expected to answer for.
• The industry standards are broader than the clause. SAE's AS5553 is titled for counterfeit electrical, electronic and electromechanical (EEE) parts — and electromechanical is exactly where connectors live. A contract naming AS5553 reaches further than one naming only the DFARS definition.
• Assemblies with electronics inside are a different conversation. An overmolded assembly carrying a small board, an active cable, or a harness with an inline module crosses into the definition regardless of what the rest of it is made from.

So the useful question at quotation time is not “are you compliant”. It is: which standard, at which revision, applies to which line item on this bill of materials.

The standards, and what each is for

Editions move, and AS6081's removal of its own test methods is the example of why that matters: a purchase order citing the standard without a revision can point at two different sets of obligations depending on when it is read. Cite the revision, or ask which one the contract means.

What to ask a cable assembly supplier

1. Which counterfeit standard does your program follow, at which revision, and who assessed it?
2. For each purchased item on the bill of materials — connectors, contacts, wire, any module — which sourcing tier did it come from: original manufacturer, authorized supplier, or open market?
3. For open-market buys, what inspection, testing and authentication was done, and where is the documentation?
4. How far back does traceability go, and does it reach the original manufacturer or stop at a distributor?
5. How is it carried on the hardware — see marking and identification, where a part number on a label is not a lot record.
6. What happens to a suspect part — who quarantines it, who decides, and who reports it?
7. Are these requirements flowed down to their subcontractors, in writing?

Ask for the evidence rather than the assertion. A supplier that can produce a traceability record for a connector lot on request is telling you something a certificate cannot. See verifying supplier certifications for how to check a claimed credential independently, and the supplier audit checklist for what to look at on site.

Where this fits

Counterfeit avoidance is a sourcing and records discipline, not a test you buy at the end. It sits alongside the RFQ checklist and the workmanship class you specify: a harness can be built perfectly to IPC/WHMA-A-620 Class 3 out of parts whose origin nobody can establish. The build standard and the parts standard answer different questions, and a program needs both.

This guide is general. Clause text, standard revisions and prime-specific requirements change; confirm the current wording against the contract in front of you and the published clause.