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  • Question

    When clause 52.246-15(b) applies, can the prime contractor submit the COC submitted by its first tier supplier or does the prime contractor need to generate its own COC and sign it as the prime?


    Answer

    First, I have never seen 52.246-15 broken down to apply only certain sections as you have indicated in your question.  You indicate only b applies.  For a contractor to use 52.246-15 they must first get authorization in writing from the CMO as stated in the FAR "When authorized in writing by the cognizant Contract Administration Office (CAO), the Contractor shall ship with a Certificate of Conformance any supplies for which the contract would otherwise require inspection at source."  Simply having the FAR in the contract does not in and of itself authorize shipment via CoC.  The FAR gives the authority to authorize the CoC shipment to the CMO who will in turn give the contractor authorization in writing.  Next the contract is with the prime contractor, not the sub so the CoC would need to come from the prime contractor and be in accordance with the instructions called out in 52.246-15.


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