Coming not long after the issuance of its new internal policy guidance on counterfeit materiel, the U.S. Department of Defense (DOD) published on May 16, 2013 its first set of proposed regulations that would impose specific anti-counterfeiting obligations on defense contractors. These proposed regulations represent a partial implementation of Section 818 of the fiscal year (FY) 2012 National Defense Authorization Act (NDAA), which directed DOD to issue regulations making certain “covered” defense contractors responsible for detecting and avoiding the use or inclusion of counterfeit electronic parts in the products they supply to DOD. Defense contractors and their suppliers have been anxiously awaiting the proposed regulations, anticipating that DOD’s regulations would begin to provide useful guidance regarding the types of processes and procedures contractors would need to adopt in order to have an “approved” counterfeit electronic parts avoidance and detection system.