I have been involved in counterfeit mitigation since early 2009. I’ve had hundreds of interesting conversations with peers and industry experts. Yesterday it dawned on me what was happening to the commercial off the shelf (COTS) market for parts. Defense contractors and the DOD are trying hard to make the COTS industry conform to QPL or military conformance. Whether it is a conscious effort or not, is yet to be seen. The problem is the COTS industry has not done this in the past and now has problems complying. It’s not that the COTS industry doesn’t want to do it, it’s just the infrastructure and specific records required don’t exist.
The biggest example of this is the requirement for MFG Certificates of Conformance. It’s well known in authorized distribution that COTS generally do not come with MFG Certificate of Conformance. What we do get is a commercial pack list from the MFG. It may or may not have a Certificate of Conformance; it may or may not be signed. Some are of poor quality. But these are the documents of product origin that we will keep for 10 or more years. AS5553 talks about this in Appendix C.2.1. What’s available on COTS, paraphrased as “commercially acceptable packing list…not supplied to the end customer.” The writers of AS5553 knew what you could get on COTS and they wrote it down.
Chuck is the Vice President of Quality at Mouser Electronics. He has been with Mouser 14 years. In Quality Management 30 years. He serves on three SAE G-19 Committees for AS5553, AS6081 and AS6496. In addition to Quality Management, Chuck also manages Environmental, Export Compliance, Legal and Contract Review. His hobby is his 1969 Roadrunner and Trail Running.
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