AS6081 Counterfeit Avoidance
As a general rule, counterfeit parts enter at the lower end of the supply chain; those who are purchasing after market or component level items and not direct from the Original Component Manufacturers (OCMs) are most at risk.
Around 82% of all counterfeit components within the aerospace sector are electronics and therefore the aerospace community have devised a new standard to bring confidence into the supply chain at the lower end.
Many stockists and distributors are purchasing components from online systems such as ILSMart, Partsbase or others with little understanding of the risks surrounding this. Receiving a certificate of conformity or airworthiness certificates does not necessarily remove the risk of counterfeit parts. It is relatively easy to fake documentation nowadays and what could be easier is to match the serial numbers on parts with some documentation that they managed to obtain.
It is hard to estimate the amount of counterfeit parts in existence or the value of those goods but one electronic component was being made for 2cents and being sold for $35, they sold for $35 as that’s what the real component costs. They don’t sell them for less as that raises suspicions. The volume of this component brought in an estimated $2m gross profit every single month, that’s a lot of money and will just drive counterfeit even more. Money is the aim of the game.
The AS6081 standard is designed specifically for organisations (typically AS9120 but can be applied to AS9100) who are not buying direct from the OEMs/OCMs 100% of the time. In order to apply AS6081 you need to be certified to ISO 9001 or AS9120. You can also implement with AS9100 in place but it is less likely to be needed if you are AS9100.
Although it can be applied as a stand-alone standard, it is designed to be used and audited in conjunction with AS9120. As a high level it is bringing in additional checks into the process to reduce the risk of counterfeit parts entering the supply chain.
Having AS6081 in place can give confidence to your customers that you are performing effective checks and inspections on incoming goods when necessary. If you are purchasing directly from the Original Component Manufacturers or their authorised distributors the risk is low and you do not need to apply the AS6081 rules to those components. You can still become certified and apply the rules if you are purchasing from other sources.
The standard is also not intended for the authorised aftermarket manufacturers when supplying parts obtained directly from the OCM or their authorised distributors.
As the standard is complimentary to AS9120 it can be assessed during the same audit using specially qualified auditors for both standards, the standard time for an AS9120 audit would be used along with some time to cover the additional requirements.
Terms and Definitions
Although the standard doesn’t necessarily bring in any new terms or definitions that you may not already be aware of, it’s important to understand some of the key terms as there is some confusion out there.
There is a difference between having a suspected part and an actual counterfeit part, just because something is deemed suspect doesn’t mean it will be counterfeit. All counterfeit parts are fraudulent, but not all fraudulent parts are counterfeit
Suspect Part: a part in which there is an indication that it may have been misrepresented by the supplier or manufacturer and mat meet the definition of a fraudulent part of counterfeit part.
Fraudulent Part: any suspect part misrepresented to the customer as meeting the customer’s requirements.
Counterfeit Part: a fraudulent part that has been confirmed to be a copy, imitation, or substitute that has been represented, identified, or marked as genuine, and/or altered by a source without legal right with intent to mislead, deceive, or defraud.
Aftermarket Manufacturer: a manufacturer that meets one or more of the following criteria:
The manufacturer is authorised by the OCM to produce and sell replacement parts, usually due to an OCM decision to discontinue production of a part. Parts supplied are produced from materials that have been:
Transferred from the OCM to the Aftermarket Manufacturer, or
Produced by the Aftermarket Manufacturer using OCM tooling and intellectual property (IP)
The manufacturer produces parts using semiconductor dice or wafers, manufactured by and traceable to an CM, that have been properly stored until use and are subsequently assembled, tested, and qualified using processes that meet technical specifications without violating the OCM’s intellectual property and intellectual property rights.
The manufacturer produces parts though emulation, reverse-engineering, or redesign, that match the OCM’s specifications and satisfy customer needs without violating the OCM’s intellectual property and intellectual property rights.
In any case, the aftermarket manufacturer must label or otherwise identify its parts to ensure that the “as shipped” aftermarket manufactured part should not be mistaken for the part made by the OCM.
Approved Supplier: Suppliers that are assessed and determined to provide acceptable fraudulent/counterfeit parts risk mitigation processes.
Authorised (Franchised) Distributor: Distributor who is authorised by the OCM through a legally binding contract.
Authorised Supplier: Aftermarket Manufacturers, as defined above, and OCM-authorised sources of supply for a part (i.e., Franchised Distribution).
Broker: In the independent distribution market, Brokers are professionally referred to and independent Distributors. Brokers will search the industry and locate parts the meet the target price and other customer requirements. No contractual agreements in place.
Certificate of Conformance (C of C, CoC): A document provided by a supplier formally declaring that all buyer purchase order requirements have been met. The document may include information such as manufacturer, distributor, quantity, lot and/or date code, inspection date, etc., and is signed by a responsible party for the supplier.
Certificate of Conformance and Supply Chain Traceability (CoCT): A certificate of conformance required by certain military specifications which requires documented supply chain traceability from the qualified parts list/qualified manufacturers list (QPL/QML) manufacturer through delivery to a government agency if the material is not procured directly from the approved manufacturer.
There are many others within the standard itself but they are not essential for understanding this article.
Fraudulent/Counterfeit Parts Mitigation Policy
Just like other management system standards, you need to have in place a policy which is defined by top management. With this standard your policy needs to focus on preventing the purchase, acceptance and distribution of fraudulent/counterfeit parts. You will also be expected to define the reporting and disposition of said parts.
One of the main requirements introduced to this standard is the need for a Fraudulent/Counterfeit Parts control plan that documents its processes used for risk mitigation, disposition and reporting. The control plan needs to go into detail about what is going to be done and how the requirements are flowed to relevant parties.
The sales process needs to be more robust and there are certain stipulations put into the requirements such as a minimum of 1 years warranty. This won’t be an issue for most organisations to deal with.
One of the areas that might take some change is that individual quotations need to be issued in writing and include the source of supply along with some additional information. You are also bound by responding to requests for a quote within 5 days which I don’t think is unreasonable.
As you may imagine, this section is requiring more control. These are not necessarily in addition to what you are already doing for AS9120 but it is raising the bar and expecting things to be a little bit tighter.
There is a lot of reference to checking of the parts and suppliers against known counterfeit databases such as GIDEP and ERAI.
The evaluation of suppliers needs to be more in-depth with consideration weighted against the risks of the supply.
The purchase orders also need to be more detailed with some additional contract requirements and most importantly; ensuring information is flowed down to other suppliers which is weak in a number of cases.
There is more emphasis on supply chain traceability including the documentation that is received. If the chain of custody back to source is not there you would possibly need to reject the goods.
Most of the emphasis of the standard is on testing of the products upon receipt. There are minimum areas to test and then some optional areas as determined by the customer.
In any case with the testing, the OCM should be contacted to assist in the verification process, you should get the information from the OCM that can be used to determine the authenticity of the parts. This could be markings, locations, photographs etc.
Not every organisation is going to have the facility to perform the required tests; these are allowed to be contracted out to an approved supplier.
Documentation and Packaging
Documentation and Packaging Inspection
External Visual Inspection
Remarking & Resurfacing
Solvent Test for Remarking
Solvent Test for Resurfacing
Radiological (X-Ray) Inspection
Lead Finish Evaluation (XRF or EDS/EDX)
XRF (non-destructive) or EDS/EDX
Delid/Decapsulation Internal Analysis
Additional Tests (as agreed between Customer and Organization):
Remarking & Resurfacing
Scanning Electron Microscope
Quantitative Surface Analysis
Thermal Cycling Test
Burn-In (Pre & Post)
Hermeticity Verification (Fine and Gross Leak)
Scanning Acoustic Microscopy (SAM)
The important thing to remember with this clause is the control of counterfeit or suspected counterfeit product. It is important to segregate and do not allow the product to be returned to market.
Under no circumstances should product be shipped back to the supplier and authorities should be informed.
Authored by: Michael Venner, NQA Aerospace Director