Counterfeit Parts Prevention Plan Template
AS9100D clause 8.1.4 requires a process for preventing counterfeit parts from entering the product, and defense primes flow down similar requirements. This template gives you a complete plan structure you can adapt and put under document control.
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Counterfeit Parts Prevention Plan Template
Counterfeit Parts Prevention Plan
Company: Acme Precision Aerospace Inc. Document: QP-0812 Revision: B Effective: 2026-10-20 Plan owner: Director of Quality Reference: SAE AS5553 and AS6174, AS9100D clause 8.1.4 and applicable contract clauses
1. Purpose and scope
This plan defines how Acme Precision Aerospace Inc. prevents, detects, mitigates and reports counterfeit and suspect counterfeit parts so that they are not delivered to customers.
Scope: All purchased electronic parts, raw material, fasteners, hardware and finished components used in or delivered with aerospace and defense products.
2. Definitions
Counterfeit part: an unauthorized copy, imitation, substitute or modified part that is knowingly misrepresented as a specified genuine part of an original or authorized manufacturer.
Suspect counterfeit part: a part for which visual inspection, testing or other information provides reason to believe it may be counterfeit.
Use the definition in the customer contract where it differs.
3. Responsibilities
| Role | Responsibility |
|---|---|
| Director of Quality | Owns this plan, approves exceptions, makes external reports |
| Purchasing | Buys only under the source policy, flows down requirements, keeps source records |
| Receiving inspection | Verifies documentation and packaging, performs inspection, quarantines suspect items |
| Quality engineering | Defines test requirements, investigates suspects, controls disposition |
| Training coordinator | Trains affected staff and keeps training records |
4. Source selection and purchasing controls
Source policy: Original manufacturer or authorized distributor only.
Parts are bought from the original component manufacturer, original equipment manufacturer or their authorized distributors wherever possible. Purchase orders carry the counterfeit avoidance flowdown, require a certificate of conformance with traceability to the manufacturer, and prohibit substitution without written approval. Any purchase outside the source policy requires documented approval by Director of Quality and the customer where the contract requires it, and a defined test plan before use.
5. Receiving and inspection
Receiving verifies the purchase order, packaging, labels, date and lot codes, manufacturer markings, certificates and any anti-counterfeit features. Inspection depth is set by risk: part criticality, source, obsolescence status and past history. Where the source policy is not met, additional inspection and testing by Approved third-party lab holding ISO/IEC 17025 accreditation for the test methods used is required before release.
6. Risk-based verification
| Risk level | Typical trigger | Minimum verification |
|---|---|---|
| Low | Manufacturer direct, full traceability | Documentation and visual check |
| Medium | Authorized distributor, long lead obsolescence | Documentation, enhanced visual, sample verification |
| High | Independent distributor or broker, obsolete part | Documentation, external visual, electrical or material test by Approved third-party lab holding ISO/IEC 17025 accreditation for the test methods used |
7. Suspect and confirmed counterfeit parts
Suspect parts are tagged, quarantined and recorded as nonconforming. They are not returned to the supplier, scrapped or reworked until quality has completed its investigation and, where required, evidence is preserved. Confirmed counterfeit parts are removed from the supply chain, reported to the customer and, where applicable, to GIDEP and the relevant government authorities as the contract requires. Disposition records are retained.
8. Training
Purchasing, receiving, quality and stores personnel complete counterfeit awareness training on hire and at least annually. Training records are held by the training coordinator.
9. Flowdown to suppliers
Requirements of this plan are flowed to suppliers that furnish parts, material or assemblies. Suppliers must maintain their own controls proportionate to the risk, notify Acme Precision Aerospace Inc. of any suspect parts, and must not change source without notice.
10. Records
Source records, certificates, inspection results, test reports, training logs and reports are retained for: 10 years from final delivery, or longer if required by the contract.
11. Review of this plan
The plan is reviewed at least annually and after any confirmed incident or contract change.
This is a starting point, not legal advice or a compliance certification. Government contracts may require a specific system under DFARS 252.246-7007 and 252.246-7008 and reporting under FAR 52.246-26; check your contract clauses and have counsel or your prime review the final plan.
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How to use the template
Fill in the field panel, then read each generated section and edit it to match what you actually do. A plan that promises third-party testing on every lot when you do not do it creates findings. Choose the source policy that you can really enforce: buying only from manufacturers and authorized distributors is the simplest control and the one auditors expect to see first. Export to Word to adopt the text into your quality system with your own header and document control format.
The standards and clauses behind it
SAE AS5553 covers counterfeit electronic parts avoidance, detection, mitigation and disposition. SAE AS6174 extends the approach to materiel such as fasteners and raw material. AS6081 addresses distributors and AS6171 gives test methods for suspect electronic parts. For government work, DFARS 252.246-7007 and 252.246-7008 address detection systems and sources of electronic parts, and FAR 52.246-26 covers reporting of nonconforming items. This template references them structurally and does not reproduce their text.
- AS9100D 8.1.4: prevention of counterfeit parts
- AS5553: electronic parts, AS6174: materiel
- AS6081 and AS6171: distributors and test methods
- DFARS and FAR clauses depend on the contract
Making the plan work in practice
A plan is only as good as the controls behind it. Purchasing needs an approved source list that distinguishes authorized from independent sources. Receiving needs a defined inspection method per risk level and a quarantine location. Quality needs a way to record a suspect part so it is not accidentally returned and re-sold. In the ERP, a flag on the item master for counterfeit risk and a purchasing block on non-approved vendors does much of the work automatically.
Common mistakes
Frequent gaps include a plan that exists but is not flowed down in purchase orders, receiving staff who have never been trained, brokers used for obsolete parts with no test plan, and suspect parts returned to the vendor without preserving evidence. Another is treating counterfeit prevention as an electronics-only issue when fasteners and raw material have their own history of fraud. Review your plan against your real purchases once a year.
Frequently Asked Questions
Is a counterfeit prevention plan mandatory?
AS9100D requires a process under clause 8.1.4, and many defense contracts require a documented system. Whether you need a stand-alone plan depends on your customer flowdowns, but a written plan is the clearest way to show the process exists.
Can I buy from independent distributors at all?
Where contracts and customers allow it, yes, but treat it as an exception with enhanced verification and testing. Electronic parts for defense work face specific source rules under DFARS 252.246-7008, so check your clauses before buying outside authorized channels.
Who do I report a suspected counterfeit part to?
Your contract and customer procedures define it. Common routes are the customer, the GIDEP program where you are a participant, and government authorities when a clause requires it. Preserve the evidence and involve your compliance contact before disposing of anything.
How often should the plan be reviewed?
At least annually, and after any incident, audit finding, customer clause change or major change in your supplier base. Record the review so you can show the plan is current.
If you want purchasing blocks, vendor flags and receiving holds enforced in your ERP instead of a document alone, we can help design and build that.
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