MACHINING & MACHINERY
COUNTERFEIT GOODS
TEC TRANSNATIONAL
COUNTERFEIT PARTS AND CONFLICT MINERALS
Counterfeiting has a long and ignoble
history, ranging from art and literature
to manufactured goods. Unlike other
industries, counterfeiting in the aerospace,
defence and automotive industries may
have life or death consequences. Although
it is clear that counterfeit parts do enter
the supply chain, the time and place of
their entry is unpredictable. Managing this
uncertainty has become more important
due to the recent rise in the incidence of
counterfeit reporting. What are counterfeit parts? Counterfeit Part – a fraudulent part that
has been confirmed to be a copy, imitation,
or substitute that has been represented,
identified, or marked as genuine, and/or
altered by a source without legal right with
intent to mislead, deceive, or defraud •
raw materials
•
outsourced special processes
•
mechanical components
•
standard and COTs parts
•
IT and communications technology
Most of us are aware of ‘blood diamonds’
(also called conflict diamonds) which are
diamonds mined in a war zone and sold to
finance an insurgency, an invading army’s
war efforts, or a warlord’s activity! What may
be less well-known are conflict minerals
which share a similar pedigree and may
inadvertently enter the supply chain. They
include tin, tantalum, tungsten and gold
(referred to as ‘3TG’). Recent legislative and
regulatory initiatives by the OECD and EU
seek to keep such ‘contaminated minerals’
out of the industrial supply chain by
requiring organizations to prove that such
minerals are either not from conflict-affected
areas or that their production and trade have
not contributed to conflict financing and
human rights abuses. Fraudulent Part – any suspect part
misrepresented to the customer as meeting
the customer’s requirements (includes
Fraudulent recycled – sold as new “unused”!) .. .. .. and all types of ‘matériel’ – i.e. the
aggregate of ‘things used’ or ‘needed’ by
any organization for the production of its
products – distinguished from personnel.
Suspect Part – a part in which there
is an indication that it may have been
misrepresented by the supplier or
manufacturer and may meet the generic
definition of fraudulent part or counterfeit
part. What are Conflict minerals?
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PECM Issue 40
The following definitions are common to
all standards and regulations relating to
counterfeit parts –
Examples of a counterfeit part can include,
but are not limited to, the false identification
of marking or labelling, grade, serial number,
date code, documentation, or performance
characteristics.
Although most of the focus is on ‘EEE’
(Electrical, Electronic, and Electromechanical)
parts, the principles and practices are
applicable to other commodity types,
including –
In conflict-affected and high-risk areas
of the world, organizations involved in
mining and trade in minerals have the
potential to generate income, growth and
prosperity, sustain livelihoods and foster
local development. Unfortunately, they may
also be at risk of contributing to, or being
associated with, significant adverse impacts
including serious human rights abuses and
conflict.