AS9100 Cl. 8.7 - Control of Nonconforming Outputs - Counterfeit Parts

jwdjmd

Starting to get Involved
#1
Hi everyone....I'm back!

My question today has to do with this statement: Counterfeit, or suspect counterfeit, parts shall be controlled to prevent reentry into the supply chain".

The company I work for is a raw PWB manufacturer. We do not do assembly here. We purchase raw materials (resin, prepreg, copper etc.) to go into the manufacture of the boards from only OEM or approved suppliers. We provide material specifications to the suppliers and we receive CoCs or CoAs stating that the material meets requirements. We have never to my knowledge have received or even suspected that we've received counterfeit materials.

So how do I demonstrate that I comply with the clause?

Thanks again for all your help!
 
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dsanabria

Quite Involved in Discussions
#3
Hi everyone....I'm back!

My question today has to do with this statement: Counterfeit, or suspect counterfeit, parts shall be controlled to prevent reentry into the supply chain".

The company I work for is a raw PWB manufacturer. We do not do assembly here. We purchase raw materials (resin, prepreg, copper etc.) to go into the manufacture of the boards from only OEM or approved suppliers. We provide material specifications to the suppliers and we receive CoCs or CoAs stating that the material meets requirements. We have never to my knowledge have received or even suspected that we've received counterfeit materials.

So how do I demonstrate that I comply with the clause?



Thanks again for all your help!
GIDEP is the first step but you should also look at AS5553 - Counterfeit Electronic Parts; Avoidance, Detection, Mitigation, and Disposition.

In addition, you should periodically take the raw material and send it to an independent lab to make sure that the composition is accurate.

Now you have developed a counterfeit program.
 

BoardGuy

Quite Involved in Discussions
#4
As a bare board manufacture you would need to develop counterfeit control plan which you could base off of AS6174, Counterfeit Materiel - Assuring Acquisition of Authentic and Conforming Materiel. I would not use AS5553 as you are not purchasing electronic components. Written counterfeit control plans are usually mandated by the customer so just create one and be done with it.

[FONT=&quot]How do you demonstrate compliance? State within your nonconforming control procedure that product suspect as being counterfeit shall be quarantined to prevent reentry into your manufacturing processes with disposition in accordance with your counterfeit control plan. [/FONT]
 
#5
AS5553 has nothing to do with bare board manufacturing. A simple way to address this is to include in your POs to your material suppliers (if they aren't the actual manufacturers) is to state that you want OE materials (Dupont etc) and that substitutions are not permitted.
 

howste

Thaumaturge
Super Moderator
#6
As a bare board manufacture you would need to develop counterfeit control plan which you could base off of AS6174, Counterfeit Materiel - Assuring Acquisition of Authentic and Conforming Materiel. I would not use AS5553 as you are not purchasing electronic components. Written counterfeit control plans are usually mandated by the customer so just create one and be done with it.
I agree that AS6174 is definitely the better way to go. The 38 page standard only has about 2 pages of requirements. The rest of the standard includes informative appendices with guidance and sample contract clauses.
 

dsanabria

Quite Involved in Discussions
#7
As a bare board manufacture you would need to develop counterfeit control plan which you could base off of AS6174, Counterfeit Materiel - Assuring Acquisition of Authentic and Conforming Materiel. I would not use AS5553 as you are not purchasing electronic components. Written counterfeit control plans are usually mandated by the customer so just create one and be done with it.

[FONT=&quot]How do you demonstrate compliance? State within your nonconforming control procedure that product suspect as being counterfeit shall be quarantined to prevent reentry into your manufacturing processes with disposition in accordance with your counterfeit control plan. [/FONT]
Agree - AS6174 is a better choice - sorry brain freeze.

Having said that - please note that a lot of customers are not aware of AS6174 and will quote AS5553 (that's all they know) so gently push back and educate them... :agree1:
 
#8
Your question has to do with prevention re-entry to the supply chain. You simply need to contain the material. You do not return it to the supplier. It is possible that the counterfeit material may need to be investigated for possible prosecution of the supplier. Preventing counterfeit material from entering your process can be a variety of processes based on the risk they pose (8.1.4, 8.4.3)
 
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