Practical guidance on preventing counterfeit parts by applying AS9100 Rev D

In AS9100 Rev D, the new requirements for understanding and implementing processes for preventing the use of counterfeit parts within your aerospace Quality Management System (QMS) reflects a growing concern within the aerospace industry of the use of parts that are not what they claim to be. If this applies to you, a process to address these requirements can be critical to your business.

Here are some ideas of what might be required from you for these processes – this article is an excerpt from chapter 9 of my book Applying AS9100 Rev D: The hassle-free approach to implementing an aerospace QMS for small business.

The purpose

There has been an ever-growing trend in the electronics industry to find cheaper sources of components. Unfortunately, this has led some companies to cheat the system by manufacturing counterfeit parts. Counterfeiting can take many forms; from producing a part with known inferior materials, producing parts with unapproved processes, or even re-labeling old or inferior parts to a higher quality label.

A memory circuit that is supposed to be 64GB, but is actually a 32GB memory circuit, may work in the short term, but could be problematic later in the lifetime of the assembly. It is this problematic situation in the aerospace industry that has led to the requirement for a process to prevent the use of counterfeit parts and materials.

Inputs, options and decisions

 There are many things that you can do in your program to prevent the use of counterfeit parts. What you choose to do depends on the risks that you have. For instance, if you have a program in place to manage your suppliers, many of the risks presented by counterfeit parts may be handled for smaller organizations (for instance, you only buy from verified dealers). On the other hand, you can use the same program from your own facility (such as testing of materials when they arrive) to ensure that mistakes have not been made by a supplier. This will check for both counterfeit materials that were given to your supplier, as well as mistakes such as a supplier sending you the wrong material. Again, this is dependent on the risk, not only from the supplier, but from the use of the material in your product.

Some options, included in AS9100, should be considered when determining what processes to put in place. These include:

  • Training and awareness – What do your suppliers and inspectors need to look for?
  • Use of original or authorized manufacturers – If you are getting your product from the producer, there is less chance than a questionable distributor of using counterfeit parts.
  • Verification and test – Can you test materials or parts (or a sample of a batch) to verify they are what they claim to be? For example, the 32GB memory chip disguised as a 64GB memory chip.
  • Monitoring reports from external sources – One example of this is the Government Industry Data Exchange Program (also known as GIDEP), which will send reports of known problems. This allows you to determine whether or not those problems affect you. The European equivalent is the European Space Agency (ESA) alert system.
  • Quarantine & reporting of counterfeit parts – This will be handled in your non-conforming outputs process.


As with previous clauses, there is no identified documented information for this clause in AS9100, because any records will be kept under other processes. Some examples are: quarantining of counterfeit parts recorded in the non-conforming outputs process, or verification and testing recorded in your inspection processes.

Requirements specific to your products

As you can see, the requirements for preventing counterfeit parts need to be interpreted with respect to your individual product. The extent of the control you will need can range from control of suppliers to ensure the correct materials and parts are supplied from only authorized manufacturers, and can extend to performing repeat testing of materials or X-ray examination of electronic components to ensure that you have been supplied authentic parts that meet the requirements of you and your customer.

With the troubles that can exist in the world of counterfeit parts and materials, this is not just a requirement of AS9100 Rev D, but also a good idea to ensure the reliability of your products; you just need to make sure the controls you put in place are realistic and help you overall.

This article is an excerpt from the book Applying AS9100 Rev D: The hassle-free approach to implementing an aerospace QMS for small business – click here to see a preview of the book.

Advisera Mark Hammar
Mark Hammar
Mark Hammar is a Certified Manager of Quality / Organizational Excellence through the American Society for Quality and has been a Quality Professional since 1994. Mark has experience in auditing, improving processes, and writing procedures for Quality, Environmental, and Occupational Health & Safety Management Systems, and is certified as a Lead Auditor for ISO 9001, AS9100, and ISO 14001.