Counterfeit parts prevention procedure for avoiding, detecting, mitigating, and disposition of counterfeit electronic parts
A part in which there is an indication by visual inspection, testing, or other information, that it
may have been misrepresented by the supplier or manufacturer and may meet the definition of
A suspect part that is a copy or substitute without legal right or authority to do so or one whose
material, performance, or characteristics are knowingly misrepresented by a supplier in the
Examples of counterfeit parts include, but are not limited to:
- Parts which do not contain the proper internal construction consistent with the ordered
- Parts which have been used, refurbished or reclaimed, but represented as new product.
- Parts which have different package style or surface plating/finish than the ordered parts.
- Parts which have not successfully completed the OCM's full production and test flow,
but are represented as completed product.
- Parts sold as upscreened parts, which have not successfully completed upscreening.
- Parts sold with modified labeling or markings intended to misrepresent the part's form,
fit, function or grade.
- Parts which have been refinished, upscreened, or uprated, and have been identified as
such, are not considered counterfeit.
Original equipment manufacturer.
Authorized distributors only.
The international organization for standardization
The suppliers of material or services are evaluated and selected based on (a) their ability to
supply product or services that (a) meets requirements and (b) their risk of supplying counterfeit
parts. Parts are always purchased directly from OCMs or from manufacturer's authorized
suppliers for Pentek's ADO customers. For non ADO customers, independent distributors are
used only after consideration of alternate parts and a reasonable search for material from
franchised/authorized sources has been conducted and approval has been obtained from the
quality manager and supply chain manager.
Pentek's supply chain maintains a listing of approved suppliers within its system.
Procurement assurance processes for avoiding counterfeit product begins when the customer
requests a quotation for a product. In this way Pentek is alerted to a customer's ADO
Pentek investigates through reporting sources such as ERAI (erai.com) for alerts of suspect
counterfeiting incidents. When independent distributors are used for non ADO customers,
special precautions are taken. These precautions are approved by the Pentek quality manager
and include, but not limited to:
- Marking inspection
- Verify engraving or silk-screening type
- Check for component wear
- Component is compared to a photo of the approved component
- If a ball grid array (BGA) component then inspection with a microscope
Supplier's approval and source selection considerations include:
- The supplier is ISO certified.
- The supplier is on the customers list of approved vendors for the specific material -
- Length of time the supplier has been in business- consideration.
- The sources demonstrated adherence to applicable provisions of AS5553- consideration.
- Membership in associations with rigorous business, ethical, and quality standards
intended to avoid acquiring and reselling counterfeit goods.
Purchasing may place a trial order. Purchasing orders the material or item, receiving inspects the
material. If the results are not acceptable, the product is controlled according to nonconforming
Supply chain and quality management evaluates suppliers to assure that approved/ongoing
sources of supply are maintaining effective processes for mitigating the risks of supplying
counterfeit electronic parts and to evaluate overall performance using the following criteria:
- Meeting specifications
- On time delivery
- Correct quantity
- Quality and condition (including absence of counterfeit evidence)
- Competitive pricing
When a product or service provided does not meet the requirements of the order, purchasing or
quality may initiate a supplier corrective action request.
Purchasing documents specify contract/purchase order requirements to minimize the risk of
being provided counterfeit parts. These documents may contain, where or when appropriate:
- Requirements for approval of product, procedures, processes, services, and equipment.
- Pentek quality management system requirements.
- If applicable, requirements for design, test, examination, inspection and related
instructions for acceptance by the company.
- Requirements for the supplier to notify the company of changes in product or process
definition, and to obtain approval where required.
- Product traceability, when applicable.
Purchasing staff reviews the information to make sure it is complete, and reviews the approved
supplier list to make sure the specified supplier has been evaluated and accepted. If not
evaluated and accepted, the supplier cannot be used unless the supply chain manager decides to
initiate a trial order pursuant to the above section.
Verification of Purchased Product
Purchased product is verified before use to assure detection of counterfeit parts prior to formal
acceptance. The rigor of the verification process shall be commensurate with product risk.
Product risk is determined by the criticality of the part and the assessed likelihood of receiving a
counterfeit part. Receiving checks the order against purchasing documents to verify the
identification, quantity and condition of the items in the order.
Verification may include:
- Obtaining objective evidence of the quality of the product from suppliers through
documentation, certificate of conformity, test reports etc.
- Inspection or audit at the supplier's premises.
- Review of required documentation.
- Visual inspection of products upon receipt.
- X-ray, non-destructive evaluation and destructive testing.
If material is identified to be counterfeit, Pentek will contact the supplier/vendor furnishing the
material and provide any Pentek data supporting the counterfeit nature of the material. Pentek
will discuss options with the supplier for disposition of the affected material in order to prevent
re-entry into the supply chain. This may include:
- Upon mutual agreement, destruction of the material by Pentek to render it unusable in
any form and documentary evidence provided to the supplier.
- Return material to the supplier and request evidence of disposition to prevent re-entry
into the supply chain.
- Reporting the incident to any agencies/bodies about the incident in order that other users
at large may become aware of the existence of the material in question and review their
own supply chain for any risks as applicable.