FALL 2016

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THE DISTRIBUTOR’S LINK
MICHAEL MOWINS COUNTERFEIT COMPONENTS – MITIGATING RISK BEYOND THE FQA from page 28
Reputable manufacturers of fasteners will stand
behind the quality of their products and will take the
steps necessary to keep counterfeits out of the market
but they may not be able to eliminate poor quality knock
offs that look similar to their products.
Published standards for fasteners that require testing
and certification are a first step toward assuring that the
fasteners are genuine. Buying parts to these standards
is a good way to minimize the risk of counterfeit and nonconforming
products, but it isn’t a cure all. Disreputable
manufacturers have been known to forge head marks,
paperwork, and certifications that are supplied with the
fastener. Knowing your source becomes a crucial part
of a good risk mitigation program. What other steps can
a distributor take to assure the quality of the parts they
supply? One of the best ways, beyond buying from a
reputable manufacturer, is to buy a trademarked product.
Trademarks are a vital part of commerce that is intended
to assure the quality of products that bear the mark. The
owner of the trademark must take steps to assure that
the products in the market place conform to a certain
level of quality and that they meet an expected level of
performance.
Often a manufacturer will use a trademark to
differentiate their brand in the market from those of
their competitors. Distributors and end users learn
to associate the trademark with a certain company or
product and the quality of the product. Additionally,
firms that specialize in innovation will license the use of
their trademark to companies that agree to meet certain
levels of quality for the products that they make and sell
using the trademark. Well known trademarked products
in the fastener world include numerous drive systems,
thread forms, blind fastening systems, and composite
fasteners. What sets a trademarked product apart from
a part that is made and marked with a standard head
mark?
A part shipped into the United States that is marked,
labeled, and packaged with a standard part number is
not subject to special scrutiny by U.S. Immigration and
Customs Enforcement (ICE). The underlying assumption
is that the part will meet the standard. The same is not
true in the case of a trademarked product that bears
the registered trademark in addition to the standard part
number. Proper use of a registered trademark brings with
it specific enforcement rights with ICE. There is a specific
process that a trademark owner can use to inform ICE
of the products that bear their trademark, the producers
that are authorized to use the trademark, the countries
of origin for products that bear the trademark, and what
action should be taken if products come into the US
from a company or country not authorized. Immigration
and Customs Enforcement can stop a shipment entering
the country with a known trademark and verify with the
trademark owner if the goods are genuine providing a very
powerful barrier to counterfeit products.
What other steps are being taken to help end users
mitigate the risk of counterfeit hardware coming from
their supply chain? In response to requests from DoE
and DoD, the SAE is developing a group of standards
to help end users limit their exposure to potential
counterfeit products. The initial publication of AS6174A,
Counterfeit Materiel; Assuring Acquisition of Authentic
and Conforming Materiel, in 2012 followed by a revision
in 2014 is the building block of a series of standards
aimed at mitigating the risk of acquiring counterfeit
materiel including fastener hardware. Currently going
through committee work in the G-21 Counterfeit Materiel
Committee are standards for counterfeit refrigerants
(AS6886) and one for fastener hardware under the
working group G-21F. The working group is composed
of representatives from aerospace end users, fastener
manufacturers, distributors, and related technical experts
from private industry and government. The new standard
is in the final draft stage and will be going to ballot in the
near future. It is anticipated that this new standard will
be used by end users to assure that their distribution
channel has appropriate policies and procedures in
place to mitigate the potential for counterfeit products in
the supply chain. Distributors that supply the DoD and
aerospace industry will most likely be seeing these new
standards cited in their procurement documents soon
after its publication.
There are many ways to limit your company’s
exposure to counterfeit material that have been covered
in this article but perhaps the most important component
of a good anti-counterfeiting program is education. Make
sure that your staff is educated about counterfeits in your
supply network and about the practices that can help to
minimize your exposure.
MICHAEL MOWINS