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    Is DFARS 252.246-7007 Counterfeit Electronic Part Detection and Avoidance System used on both FAR 15 and FAR 12 contracts? Or is SAE-AS5553 Counterfeit Electronic Parts; Avoidance, Detection, Mitigation and Disposition used in place of DFARS 252.246-7007 on commercial contracts?


    On May 6, 2014, the new rules and clauses, dealing with Counterfeit Electronic Part Detection and Avoidance was published in the Federal Register, Volume 79, No 87.   There is a long discussion beginning on page 26099 explaining the applicability of the clause.  I have attached the Federal Register, where you can read the detailed explanation provided by the Defense Acquisition Regulation Council.  Very specifically, DFARS 252.246-7007 does not apply to the commercial prime contractors.   In order to require application to the acquisition of commercial items, it would be necessary to list the clauses at DFARS 212.301. But the clause does apply to CAS covered prime contractors and any of their subcontractors, regardless if those subcontractors are commercial suppliers. Therefore, any electronic part procured by a CAS-covered prime contractor is subject to the restrictions concerning counterfeit and suspect counterfeit parts without regard to whether the purchased part is a commercial or COTS item. 

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