New FAR Makes Previously Voluntary Screening and Reporting, Now Mandatory

A new Federal Acquisition Regulation provision and clause effective on December 23, 2019, requires, in short, federal contractors to report counterfeit or suspect counterfeit parts and major/critical nonconformances to their Contracting Officer and to GIDEP. The new FAR provision (48 C.F.R. § 46.317) and clause (FAR 52.246-26) applies to civilian and defense contracts over $150K for electronic parts or end items, components, parts or assemblies containing electronic (excluding COTS) parts.

  • Covered parts must be screened against GIDEP reports
  • Contracting Officer notification and GIDEP report submittal within 60 days
  • Reporting is no longer voluntary for government contractors and subs

In light of the new requirements, Seyfarth Shaw LLP concludes in this article, "Contractors need to further scrutinize their supply chains to identify vulnerabilities, especially as it relates to product testing and certification."

Although compliance to these new rules falls squarely on contractors (who may not only be barred from government contracting and held criminally liable if failing to do so), these parts are primarily sourced through independent distributors who perform or subcontract authenticity inspection and testing. With this in mind, it may be wise to take a closer look at some of the companies on your AVL in early 2020.

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