Can CoCs be used on test or pre-production items?
Are CDRLs ever required for a contractor to provide a CoC?
Here are some thoughts that you may want to discuss with your contracting officer.
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If you are following the procedures of FAR Part 12, you've determined your tool kits are commercial items. That means there is no contractual distinction between development, pre-production, or production; you are buying end items.
Contracts for commercial items will have this inspection/acceptance criteria: "The Contractor shall only tender for acceptance those items that conform to the requirements of this contract. The Government reserves the right to inspect or test any supplies or services that have been tendered for acceptance. The Government may require repair or replacement of nonconforming supplies or reperformance of nonconforming services at no increase in contract price. If repair/replacement or reperformance will not correct the defects or is not possible, the government may seek an equitable price reduction or adequate consideration for acceptance of nonconforming supplies or services."
FAR Parts 12 and 46 tell us "Contracts for commercial items shall rely on a contractor’s existing quality assurance system as a substitute for compliance with Government inspection and testing before tender for acceptance unless customary market practices for the commercial item being acquired permit in-process inspection (41 U.S.C. 3307)." This means, unless it is commercial practice, we do no inspection or testing prior to delivery of the end item.
The clause at 52.246-15 "Certificate of Conformance" requires that "the Contractor shall ship with a Certificate of Conformance any supplies for which the contract would otherwise require inspection at source". This means the CoC would not be provided prior to shipping or delivery. Inspect at source may not be standard commercial practice so a CoC may not be appropriate.
We hope this points you in a helpful direction. We also understand that there may be additional information of which we're unaware that may make other considerations more appropriate.