How counterfeiting threatens Supply Chain Integrity
Counterfeiting has been prevalent throughout the global industrial era, and given its profitability and the low risk of conviction for offenders it is not going away anytime soon. Unfortunately, there have been numerous examples of public and private organisations which unknowingly procure counterfeit, fraudulent, substituted or substandard products in their supply chain – two such examples include:
- June 2020: U.S. Air Force pilot 1st Lt. David Schmitz died when his parachute didn’t deploy from a malfunctioning ejection seat, which the US Air Force later found may have contained up to ten counterfeit and faulting resistors and semiconductor chips
- March 2021: Police in China and South Africa seized thousands of fake doses of Covid-19 vaccine, with Interpol warning this represented only the “tip of the iceberg” globally. Police raided the manufacturing premises, arresting ~80 suspects and seizing over 3,000 fake vaccines
As the above examples show, it is all too easy for counterfeit materials to enter the supply chain of even the world’s largest organisations. Critical Infrastructure operators, such as those falling under the purview of Australia’s Security of Critical Infrastructure Act 2018, have a requirement to use high quality parts and components produced by reputable manufacturers to an engineer’s specifications, whilst in life sciences, fraudulent or substandard medicines frequently cause premature death or serious injury.
How do sub-standard parts enter a supply chain?
Before we explore this further, we need to remember there are two perspectives here: (1) what a manufacturer can do to ensure their products are not counterfeited or compromised between the factory and the end user, and (2) what end users can do to ensure they do not introduce compromised product into their inventory or operations. The second option is the focus of this post.
Sub-standard, counterfeit or fraudulent parts / components / products (also referred to as ‘non-conforming‘ materials) can enter the supply chain in at least four ways, including:
- Supplier intentionally introduces non-conforming material, perhaps for profit or because they are unable to obtain the conforming item and do not want to risk their relationship with the buyer
- Supplier unintentionally introduces non-conforming material as a result of inadequate or complacent internal practices and procedures
- Corrupt or malicious insider compromises the supply chain for gain or profit, or,
- As a result of foreign interference by a nation state actor against an adversary
Given these vectors for introducing non-conforming materials, how can organisations protect their supply chain integrity? The answer is developing an Anti-Counterfeit Management Plan, otherwise known as a Material Authenticity Assurance Plan (MAAP), which based on AS6174 published by SAE International can be developed in five main steps.
Step 1 – Assess the risk posed by sourcing counterfeit product
I have previously written about the concept of security risk management and the fact that we can’t treat all problems to the same standard: Risk management decisions must be based on risk appetite and focused on using a business’s limited resources to protect the most critical assets.
For a buyer, the risk of counterfeit parts is largely a quality control issue as long as there are multiple qualified suppliers in a given market. However, for products requiring specific know-how or capability, or where Intellectual Property licensing applies, different sourcing considerations are required.
The first step in managing supply chain integrity issues arising from counterfeits involves identifying those areas where the business impact of compromise is greatest. This allows sourcing managers to modify their approach and policies to compensate for potential risks. One example of criticality tiering by product can be found below:
|Impact / Criticality||Type of product|
|HIGH||LIfe dependent applications|
|Safety critical applications|
|Mission critical applications|
|Applications where field work / repair is impossible|
|MEDIUM||Reclaimed / Refurbished parts|
|Product is accessible for field repair|
|Short product life expectancy|
Step 2 – Identify which sources provide the greatest assurance
Budget is always a finite issue in any organisation, and it is not always possible (or necessary) to buy the best of everything. Where multiple suppliers exist it makes good business sense to buy the highest quality items (typically the most expensive) for those areas which are the most critical either to your business’ operations or to life and safety.
So how do you determine this? SAE International provides useful guidance here, ranking the main types of ‘source’ in order of those which provide the greatest level of confidence that their materials will be high quality (and therefore the lowest risk of non-conformance):
|Confidence Level |
|Product / Component Source|
|OEM or Certified Manufacturer|
|Original Manufacturer or Contract Manufacturer|
|MEDIUM||Vetted or pre-qualified Independent Distributor (e.g. verified quality, reputation)|
|Unknown Independent Distributor (e.g. quality, reputation not asessed)|
(VERY HIGH risk)
|Vendor is subject to adverse reporting from industry participants (i.e. other buyers have reported purchasing non-confirming product from this seller)|
Step 3 – Develop your organisation’s product assurance processes
The risk of sourcing non-conforming material is omnipresent for any critical industry or life sciences organisation, so undertaking assurance on your suppliers and any parts / components / software purchased from them is an ongoing activity for the life of your operations.
For physical products, there are four ways to obtain this assurance which can be used in isolation or in combination depending on the risk profile:
- Document and packaging inspection – before opening the package, inspect for obvious tampering, spelling errors, typographic issues, missing or damaged holograms, peeling labels, amended dates, etc.
- Visual Inspection – remove the product / part / component from the packaging. Does it match the expected style, form and quality of what was ordered?
- Non-Destructive Testing – involves radiological, acoustic, thermographic and optical techniques to verify conformance without damaging the component / part / product.
- Destructive Testing – usually used as a last resort these options involve analytical chemistry, deformation and metallurgical tests, exposure tests, and functional tests which will likely damage the component / part / product.
Further information can be found here. Irrespective of whether fraudulent, substandard or counterfeit, non-conforming materials identified should always be removed from circulation within the organisation’s inventory or operations, and either retained as evidence for legal and associated purposes, securely destroyed or returned to the supplier (depending on your policies and obligations).
Step 4 – Plan for contingencies
It is a fact of life that manufacturers stop producing products / components due to factors such as shortages in raw materials, financial solvency, or simply product strategy decisions. Buyers who require parts or components to support an extended operational life of say two to three decades need to implement plans to mitigate these risks.
Contingencies include purchasing additional inventory, regular engagement with manufacturers to obtain advanced notice of production changes, finding contract manufacturers, or sourcing alternative components.
Step 5 – Document your Product Assurance Framework
To ensure consistency and proper governance some sort of framework is required to set out your organisation’s policies, risk appetite, roles and responsibilities, regulatory compliance obligations, key risks and controls, staff awareness training and product assurance program.
A documented provides a mechanism to ensure consistent implementation throughout the organisation, and a mechanism to continuously improve as well as benchmark historical performance.
- Agence France-Presse (2021). Interpol warns fake vaccines seized in China and South Africa are ‘tip of iceberg’, The Guardian.
- Curwell, P. (2021). Unpacking AS6174 in relation to Supply Chain Integrity, www.forewarnedblog.com
- Post, R. S. and Post, P.N. (2008). Global Brand Integrity Management: How to protect your product in today’s competitive environment, McGraw-Hill, New York.
- SAE International (2014). AS6174 Counterfeit Material; Assuring Acquisition of Authentic and Conforming Material, Rev. A, Aerospace Standard, www.sae.org.
- U.S. Department of Commerce (2010). Defence Industrial Base Assessment: Counterfeit Electronics, Bureau of Industry and Security, https://www.bis.doc.gov, p.ii, accessed 19/5/2019.
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