Risky Business: How Rules Governing Counterfeit Electronic Parts and Reporting on Nonconformance Have Put Risk at a Premium in the Government’s Supply Chain


Any contractor or subcontractor supplying the government with electronic parts or other items should consider new rules aimed at controlling counterfeit electronic parts and monitoring for nonconformance. In an industry where cybersecurity regulations are on the rise, suppliers risk nonpayment, claims of breach, or worse if they ignore these new rules, which have already been incorporated into the Defense Federal Acquisition Regulation Supplement ("DFARS") and which may soon be incorporated into the Federal Acquisition Regulation ("FAR").

CAS-Compliant Contractors Must Comply With DFARS Rules on Detection and Avoidance of Counterfeit Electronic Parts -

As Venable reported earlier, under a new DFARS clause, contractors subject to the cost accounting standards (“CAS”) who supply the Government with electronic parts will need to develop a counterfeit electronic parts avoidance and detection system featuring the 12 criteria (the top three of which were added in the final rule)...

Please see full update below for more information.

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Topics:  Contractors, Counterfeiting, DFARS, Electronics, FAR, Federal Contractors, Material Suppliers, Risk Mitigation, Subcontractors, Supply Chain, Supply Contracts

Published In: Government Contracting Updates, International Trade Updates

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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