SD-2 Dod Acquisitions Buying Commercial Items And Nondevelopmental ItemsThis document offers guidance on acquisitions involving all types of commercial and nondevelopmental items: systems, subsystems, assemblies, parts, and items of supply. Commercial services are also addressed.This document does not present a “cookbook” approach to the acquisition of commercial and nondevelopmental items; such an approach could not accommodate the vast array of potential applications. It does offer lessons learned and things to consider when participating on an integrated product team.

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According to organizations that have investigated the counterfeiting problem, the best miti- gation strategy is to procure items only from OCMs and their franchised or authorized distrib- utors. When the original manufacturer no longer makes the required item, or the item is in short supply, users must obtain these products on the open market, which increases the risk of purchasing counterfeits.Therefore, purchasing on the open market warrants special precautions.

The most effective precaution is to purchase from suppliers that maintain full traceability.

The most important document for traceability is the certificate of conformance, a formal decla- ration by the supplier that all requirements have been met. Responsible suppliers must provide traceability certificates that trace parts back to the OCM. Lacking a certificate, the next best

trail is an unbroken chain of documentation (certifications, packaging slips, etc.) tracing the movement of the parts back to the OCM. Although traceability provides some level of insur- ance, be aware that, just as parts can be counterfeited, certificates can be faked as well.

Products backed by the original manufacturer's warranty offer the greatest assurance of in- tegrity and traceability. Each step further away from the OCM adds a new layer of uncertainty about the pedigree, decreasing buyer confidence in the product's authenticity and increasing the risk that the part may be a counterfeit. Another precaution is to know what the item should cost. If a supplier's prices are significantly lower than expected, or significantly lower than the competition's prices, the supplier may be offering counterfeits.

If it is impossible to avoid buying products from an unknown or less-trusted source, the purchased products should be subjected to rigorous inspection and testing to determine their authenticity.The inspectors should look for signs of counterfeiting in two places: the products themselves, and the documentation and packaging accompanying the products.Table A-1 iden- tifies some visual cues or indications of possible counterfeit parts.

Table A-1. Indications of Possible Counterfeiting