ROCHESTER ROCHESTER4

Counterfeit Electronic Components
in the U.S. Supply Chain
Summary of a report by
The Office of Technology Evaluation,
Bureau of Industry and Security,
U.S. Department of Commerce.
®
a ROCHESTER ELECTRONICS REPORT & ANALYSIS SUMMARY
SUMMARY
ANALYSIS
&
REPORT
ELECTRONICS
ROCHESTER
Counterfeit Electronic Components
in the U.S. Supply Chain
This report summary has been prepared by Rochester Electronics, LLC,
an authorized distributor of semiconductors.
Rochester offers a complete Extension-of-LifeTM solution: manufacture, supply,
distribution, replication and re-creation, testing and certification, procurement and storage.
We extend life. And, every Rochester product and service is 100% guaranteed.
The U.S. Department of the Navy is challenged to procure trusted electronic components that can
keep weapon systems and platforms in top working order even when they have outlived their original
end-of-life projections. More and more, these procurement efforts have succeeded in putting counterfeit
parts into the supply chain. And counterfeit components can cost lives.
As a result, Naval Air Systems Command (NAVAIR) requested that the U.S. Department of Commerce
Bureau of Industry and Security’s (BIS) Office of Technology Evaluation (OTE) conduct a survey to assess
the situation – in commercial, industrial, and defense supply chains. This survey is documented in Defense
Industrial Base Assessment: Counterfeit Electronics / November 2009. All quotes in this summary are taken
from this report.
General Survey Findings: Counterfeit Parts in the U.S. Supply Chain
“The number of counterfeit incidents for all electronic part types climbed dramatically from 3,868 cases
in 2005 to 9,356 cases in 2008.” (page 69)
“The proliferation of counterfeit parts is … increasingly present at every level of the supply chain.” (page 164)
“Data suggests that the incident rates reported by survey participants do not fully reflect the size and scope
of the counterfeit parts problem.” (page 78)
“The rise of counterfeit parts in the supply chain is exacerbated by demonstrated weaknesses in inventory
management, procurement procedures, record-keeping, reporting practices, inspection and testing protocols,
and communication within and across all industry and government organizations.” (page ii)
The survey reveals that little is being done to avoid the infiltration of counterfeit parts into
the U.S. supply chain:
• All segments of the supply chain have been impacted by counterfeit parts
• Organizations in the U.S. supply chain do not communicate with one another
• Organizations and companies simply assume someone else is checking for counterfeiting
• There is a common lack of traceability of parts throughout the supply chain
• Organizations do not establish a sufficient chain of accountability
• Only a limited number of organizations keep records about counterfeit incidents
• Most organizations do not know which government agencies to contact to report counterfeit incidents
• Few organizations are aware of legal requirements and liabilities related to counterfeits
• Testing protocols and quality control practices are generally insufficient
Counterfeit parts cause loss of revenue through manufacturing downtime as well as product failure.
In the most regrettable scenario, counterfeit parts can cause personal injury or death. Throughout the
supply chain, organizations are “unaware of the legal requirements and liabilities related to counterfeits,”
unaware of “the requirements for management and disposal of counterfeit product,” and unaware of
“liabilities related to the distribution, storage, and disposal of counterfeits.” (page 187) Counterfeiting
has been criminalized by the U.S. Government. (page 194)
Page 1
Rochester Electronics, LLC
www.rocelec.com
Counterfeit Electronic Components
in the U.S. Supply Chain [ continued ]
Best Industry Practices to Stop Counterfeits
To curtail the flow of counterfeit parts into U.S. supply chains, OTE developed the following best
practices for organizations in all industry segments that deal with electronic components. See how
Rochester Electronics instituted these best practices thirty years ago, and continues to build
on them today.
OTE-Recommended
Industry Best Practices for Companies that
Deal with Electronic Parts
How Rochester Electronics’ Long-Time
Standing as an Authorized Distributor
Assures You Security
Implement “institutionalized policies and
procedures … on how … to avoid purchasing
counterfeit parts; test, handle, and track incoming
and outgoing parts; and manage and dispose of
suspected counterfeit components.” (page 193))
Rochester guarantees every product and service
100%. We can do that because our policies
provide for prudent purchasing, incoming and
outgoing inspections, thorough tracking for
100% traceability, and state-of-the-art storage
conditions. Documentation establishes correct
procedures for the disposal of counterfeit
components.
Train all personnel who handle electronic
components (purchasing, quality assurance,
and receiving) on how to inspect parts and
identify possible counterfeits. (page 194)
Provide “clear, written guidance on what steps to
take if they suspect a part is counterfeit.” (page 206)
Written procedures for handling and inspecting
parts as well as dealing with possible counterfeits
are provided to all relevant Rochester employees.
Report all suspect and confirmed counterfeit
components to federal authorities and industry
associations. “Communication within and between
industry segments is inconsistent.” (page 183)
In 2008, only 3 percent of all incidents recorded
by survey respondents were reported to the
government. (page 184) This is mostly due to
the fact that “organizations do not know which
authorities to notify.” (page 186) (Note: See the
end of this summary for more information.)
Rochester works with federal authorities and
industry associations every time a counterfeit
incident occurs. Rochester partnered with the
Semiconductor Industry Association (SIA) to
create the Anti-Counterfeiting Task Force.
Rochester has also created the Official
Manufacturers’ Distributor Authorization
Reference Manual, a free service that lists
authorized distributors by manufacturer.
(www.authorizedcomponents.com)
In addition, Rochester received the Chinese
Reliable Electronic Component Supplier’s
Classification (RECS) by China’s Ministry of
Industry, a joint administrated program by the
China Electronic Purchasing Association (CEPA)
and the China Quality Association for the
Electronics Industry (CQAE).
Maintain an internal database of suspected and
confirmed counterfeit parts.
Rochester has always maintained a database of
suspected and confirmed counterfeit incidents.
[ Continued on page 3 ]
Page 2
Rochester Electronics, LLC
www.rocelec.com
Counterfeit Electronic Components
in the U.S. Supply Chain [ continued ]
“Buy parts directly from OCMs and authorized
distributors, rather than from parts brokers,
independent distributors, or the gray market.”
(page 198) This policy may not be practical for
organizations “that work on systems that require
out-of-production or obsolete parts.” (page 198)
Rochester purchases directly from original
component manufacturers. All of Rochester’s
stock is 100% traceable. And Rochester is an
authorized dealer – authorized by more than 50
original manufacturers.
Require suppliers to trace parts back to OCMs –
certificate of conformance.
Every Rochester component is 100% traceable
back to the original manufacturer.
Establish a list of trusted suppliers – use the
following criteria: (page 200)
• Number of years in business
• References from past/present customers
• Counterfeit screening, tracking, and testing
procedures
• Adherence to industry and government
standards
• Membership in industry associations
• Previous problems recorded
• Quality of warehouse/storage facilities
• Existing counterfeit avoidance policies
As an authorized dealer, Rochester belongs on
everyone’s list of trusted suppliers:
• 30 years in the semiconductor business
• Satisfied past and present customers
• Procedures and equipment screen, track, and
test for counterfeit components
• Rochester adheres to all standards and works
to improve them
• Active member of SIA*
• Rochester reports all counterfeit incidents
• Rochester’s facilities are all state of the art
• Rochester’s counterfeit avoidance policies are
aggressive
* Semiconductor Industry Association
Use a third-party escrow service to hold payment
while parts are tested for authenticity.
Because all of Rochester’s products and services
are 100% guaranteed, escrow service is not often
requested; however, we willingly work with any
customer’s requirements.
Ensure that procurement schedules are realistic.
Rochester has developed a number of proven,
customizable programs that help customers plan
for future component needs.
Establish contracts with suppliers that include
improved notices for final life-time part purchase
opportunities and of termination when electronic
components will no longer be manufactured.
“Organizations should also have proactive
obsolescence management plans when parts
go out of production.” (page 200)
Rochester’s Bill of Materials (BOM) program
analyzes customers’ requirement lists and
provides a report on products that have delivery
or EOL issues. Customers can then quickly develop
a plan for the continuing supply of needed parts,
greatly reducing the risk of non-availability and
increased costs.
Physically destroy all defective, damaged, and
substandard parts.
Rochester ensures that all suspect parts are
reported to authorities and the original
manufacturer and then are properly disposed
of by a bonded recycling facility so they can’t
re-enter the supply chain.
[ Continued on page 4 ]
Page 3
Rochester Electronics, LLC
www.rocelec.com
Counterfeit Electronic Components
in the U.S. Supply Chain [ continued ]
Increase the use of authentication technologies
by part manufacturers and/or their distributors.
“Organizations trust the integrity of the supply
chain and the products that flow through it.”
(page 182) Therefore, no one is checking!
Rochester’ 30,000-square-foot, state-of-the-art
facility is staffed by experienced engineers who
provide electrical, environmental, and burn-in
testing. At Rochester, we’re always checking!
Before placing components into inventory, screen
and test them for authenticity (especially returns
and buy backs): surface testing, X-ray analysis,
destructive physical analysis, electrical testing,
temperature or thermal cycling, burn-in.
“Organizations should establish internal testing
capabilities.” (page 205)
Rochester is proud to promise a 100% guarantee.
The only way to maintain that promise is to
consistently, appropriately, and thoroughly
inspect and test all components, whether
purchased for distribution or manufactured.
Employ testing protocols that conform to the
latest industry standards.
Rochester uses original test programs and
equipment when they are available, or develops
new programs using the most recent technical
information. Testing is performed to 100% of
the original manufacturer’s specifications.
Verify the integrity of test results from contract
testing houses.
At Rochester, we rely on the test results from
our own superior in-house testing facilities.
Perform supplier site audits; evaluate product
return, buy back, and inventory control practices,
and quality processes. “Inventory should be kept
under strict control. Parts for different customers
should be kept separate… Parts purchased from
different suppliers should not be co-mingled.”
No other company has passed as many stringent
audits as Rochester has – performed by original
manufacturers, government agencies, audit
specialists, and customers.
(page 205)
In addition, OTE proposed recommendations that the U.S. Government should institute to inhibit the
circulation of counterfeit electronics.
Not All “Authorized Distributors” Are the Same!
While OTE’s report recommends that the best defense against counterfeit parts is to buy from the
original manufacturer or an authorized dealer, their investigation also revealed that “authorized
distributors” operate under varying sets of standards; therefore, not all “authorized distributors”
can be trusted to provide product that is 100% guaranteed.
Less-than-desirable Practices of “Authorized”
Distributors
Why Rochester Electronics’ is an Authorized
Distributor You Can Trust
“51 percent of authorized distributors … said
that they restock or re-circulate returns and
buy backs. Only a small number of these
distributors … require these parts to undergo
quality control and screening before they are
re-circulated.” (page 55)
Rochester consistently, appropriately, and
thoroughly inspects and tests all components,
whether purchased for distribution or
manufactured. Rochester is proud to promise a
100% guarantee of all products and services.
[ Continued on page 5 ]
Page 4
Rochester Electronics, LLC
www.rocelec.com
Counterfeit Electronic Components
in the U.S. Supply Chain [ continued ]
“The low levels of testing by authorized distributors
are surprising considering industry concerns about
the reliability of parts supplied by brokers and
independent distributors.” (page 57)
Experienced engineers in Rochester’s
30,000-square-foot, state-of-the-art facility
provide electrical, environmental, and burn-in
testing using the most recent technical
information available. Testing is performed to
100% of the original manufacturer’s
specifications.
“Many [authorized distributors] do not have
any protocols for identifying counterfeits
beyond packaging and documentation.” (page 72)
Rochester employees are provided with the
inspection and testing protocols, training, and
equipment necessary to expose any counterfeit
product.
“Only 29 percent of authorized distributors …
conduct inventory audits specifically to check
for counterfeits.” (page 59)
Rochester inventory is guaranteed 100%
traceable and authentic. Any counterfeit devices
are detected in the screening process before
they reenter stock.
“Authorized distributors ordered considerably
less testing than unauthorized distributors in
2008 … Even fewer authorized distributors
ordered more comprehensive electrical or
physical [destructive] testing.” (page 61)
At Rochester’s in-house testing facilities,
specialized engineers conduct state-of-the-art
electrical, environmental, and burn-in testing.
All of Rochester’s products and services are
100% guaranteed.
“36 percent of authorized distributors do
not take any steps after being notified of a
counterfeit incident [i.e., that they have
shipped counterfeit parts].” (page 64)
Rochester’s policies and procedures guarantee
that no counterfeit part is ever shipped to a
customer.
“Only 29 percent of authorized distributors …
notify industry associations about counterfeits.
Rochester continually works with industry
associations to combat the counterfeit problem.
Rochester partnered with the Semiconductor
Industry Association (SIA) to create the
Anti-Counterfeiting Task Force.
“Only 36 percent of authorized distributors …
check at least one database for counterfeits
information.” [in an ongoing effort to keep
abreast of current information] (page 66)
Rochester stays on top of all information
available about counterfeits. In addition,
Rochester has been a leader in encouraging
consumers and government agencies worldwide
to establish practices and laws that will eliminate
counterfeit electronics from the supply chain.
(page 65)
“Authorized distributors do not have any
information sharing networks or industry
associations exclusive to their segment of
the industry for counterfeit electronics.”
(page 67)
Rochester, working with SIA, has created
Official Manufacturers’ Distributor Authorization
Reference Manual which lists authorized
distributors by manufacturer.
(www.authorizedcomponents.com)
[ continued on page 6 ]
Page 5
Rochester Electronics, LLC
www.rocelec.com
Counterfeit Electronic Components
in the U.S. Supply Chain [ continued ]
Overview of the Survey Purpose and Method
The purpose of the survey was three-fold:
• To discover the extent of counterfeit infiltration into the U.S. military and industrial supply chains
• To understand how government and industry practices enable the counterfeit problem
• To establish best practices and recommendations for handling and preventing counterfeit electronics
OTE conducted independent research, field interviews, and surveyed five segments of the U.S. supply
chain (387 companies and organizations participated):
• original component manufacturers (OCMs)
• distributors and brokers
• circuit board assemblers
• prime contractors and subcontractors
• Department of Defense agencies
Each industry segment was asked to provide information on the following topics for the period from
2005 to 2008:
• How many suspected/confirmed counterfeit parts are making their way into inventory?
• What types of devices are being counterfeited?
• What procurement and management practices are employed?
• What record-keeping and reporting practices are in place to track counterfeit components?
• What techniques are used to determine if parts are counterfeit?
• What best practices can be employed to prevent counterfeit parts from entering the supply chain?
Where to Report Suspected and Confirmed Counterfeit Incidents
Defense-related counterfeits: Defense Criminal Investigative Service (DCIS)
(800-424-9098 — http://www.dodig.mil/hotline).
Aviation counterfeits: FAA Suspected Unapproved Parts Program
(800-255-1111 — [email protected])
Commercial counterfeits: FBI
(find your local FBI office at http://www.fbi.gov/contact/fo/fo.htm)
Also, visit Cybercrime.gov to learn more on reporting counterfeit incidents.
Page 6
Rochester Electronics, LLC
®
www.rocelec.com
16 Malcolm Hoyt Drive . Newburyport, Massachusetts 01950 USA
phone
978.462.9332 . fax 978.462.9512 . email [email protected]