ISO Compliance Insights & Best Practices

Counterfeit Parts Prevention: A Complete AS9100 8.1.4 Guide (2026)

Counterfeit parts are the supply-chain risk AS9100 names in its own clause: 8.1.4, Prevention of Counterfeit Parts, requires the organisation to “plan, implement, and control processes, appropriate to the organization and the product, for the prevention of counterfeit or suspect counterfeit part use and their inclusion in product(s) delivered to the customer”. The clause is short and its NOTE is long — training, obsolescence monitoring, sourcing from original or authorised manufacturers, traceability, verification and test methods, monitoring of external reporting, and quarantine and reporting of suspect parts — and the IAQG’s published key changes for IA9100 turn those NOTE items into requirements. A counterfeit part is, in the standard’s definition, an unauthorised copy, imitation, substitute or modified part knowingly misrepresented as a specified genuine part of an original or authorised manufacturer; the electronic component that fails at altitude and the fastener with a forged certificate are both in scope. This guide sets out what 8.1.4 requires, the seven elements of a prevention process and how each is evidenced, the sourcing hierarchy that does most of the work, the detection methods, what to do when a suspect part is found, and where AS5553, AS6174, AS6081 and the DFARS counterfeit rules add obligations.

Counterfeit parts prevention under AS9100 8.1.4: seven elements — Training · Obsolescence monitoring · Approved sources (OCM/OEM, authorised distributors) · Traceability to the manufacturer · Verification and test · Monitoring of external reports · Quarantine and reporting of suspect parts.

What AS9100 8.1.4 requires

Element	AS9100D	IA9100 (pending, per IAQG key changes)
Requirement	Plan, implement and control processes for the prevention of counterfeit or suspect counterfeit part use and their inclusion in delivered product	Retained
NOTE items — training; obsolescence monitoring; controls for acquiring from original or authorised manufacturers, distributors or other approved sources; traceability to original or authorised manufacturers; verification and test methodologies; monitoring of counterfeit parts reporting from external sources; quarantine and reporting of suspect or detected counterfeit parts	Guidance — ‘should consider’	‘NOTE items now requirements’, per the IAQG clause-by-clause summary
Flow-down	8.4.3: information for external providers includes the need to prevent the use of counterfeit parts	Expanded sub-tier control expected
Definition	Counterfeit part: an unauthorized copy, imitation, substitute, or modified part knowingly misrepresented as a specified genuine part of an original or authorized manufacturer	Retained

The practical reading is that an organisation certified to Rev D that treats the NOTE as its process design has nothing to change when IA9100 arrives; one that has a one-paragraph policy and no records does. Our guide to IA9100 covers the revision’s timing.

The seven elements of a counterfeit parts prevention process

Element	What it involves	Evidence an auditor asks for
1. Training	Purchasing, receiving inspection, engineering and quality personnel trained in counterfeit risk, indicators and the organisation’s procedure	Training records and content; awareness on the receiving dock, not only in quality
2. Obsolescence monitoring	Parts approaching or past end of life identified, because obsolete and long-lead parts are where counterfeits enter	An obsolescence register; last-time-buy and redesign decisions; a link to the risk register
3. Approved sources	Purchase from the original component manufacturer (OCM/OEM) or its authorised distributors; independent distributors and brokers only under a documented risk-based exception	Approved supplier list flagging source type; exception approvals with the added verification each carried
4. Traceability	Documentation tracing each part to the original or authorised manufacturer — certificates of conformance, manufacturer date and lot codes, the unbroken chain of custody	Traceability documents reviewed at receipt; a defined response to gaps
5. Verification and test	Inspection and test proportionate to source risk: documentation review, visual and marking inspection, dimensional, X-ray, decapsulation, electrical test, solvent and heated-solvent tests for remarking	Inspection plans by risk tier; test reports; laboratory accreditation where external
6. Monitoring external reporting	Subscription to and review of counterfeit reporting sources — GIDEP and ERAI are the ones the sector uses — and customer and industry alerts	Alert review log with actions taken on relevant reports
7. Quarantine and reporting	Suspect parts segregated so they cannot re-enter the supply chain; reported to the customer, to the reporting bodies and, where applicable, to authorities; not returned to the supplier	Quarantine records, reports filed, disposition decisions

The sourcing hierarchy

Most counterfeit parts prevention is procurement discipline. The sector’s hierarchy, formalised in SAE AS5553 for electronic parts and AS6174 for materiel, runs: the original manufacturer; the manufacturer’s authorised distributor; an authorised aftermarket manufacturer; and only then independent distributors and brokers, each step down carrying more verification. The organisation’s counterfeit risk is largely the fraction of its spend that sits in the last tier, and the process should be able to state that fraction. Where an independent source is unavoidable — obsolescence again — the mitigations are contractual (AS6081-compliant distributors, return and remedy clauses), documentary (full traceability or an explicit acknowledgement of its absence) and physical (the test regime the risk tier calls for). Our guide to AS9100 vs ISO 9001 covers how 8.4’s external provider controls carry these requirements.

Detecting counterfeit parts at receipt

Documentation. Certificates that do not match the part, the lot or the manufacturer’s format; missing chain of custody; a distributor certificate standing in for a manufacturer’s.
Markings. Inconsistent fonts, misaligned or resurfaced markings, date codes that post-date the part’s obsolescence, country of origin inconsistent with the manufacturer.
Physical. Sanding or blacktopping on packages, indent depth differences, lead re-tinning, solder residue on ‘new’ parts, packaging inconsistent with the manufacturer’s.
Test. Electrical parametric test against the datasheet, X-ray die and bond-wire comparison, decapsulation, and for mechanical parts material and hardness verification against the specification.

Receiving inspection is where the process either works or does not; a procedure that ends with “check the CoC” has one of the four.

When a suspect counterfeit part is found

Quarantine it with its documentation, physically segregated and controlled, and identify every other part from the same lot and source.
Do not return it to the supplier. A returned counterfeit re-enters the market; the sector reporting bodies and customer contracts expect retention pending disposition.
Confirm through the verification and test regime, using a laboratory where needed.
Report — to the customer under 8.7’s notification requirement, to GIDEP or ERAI, and, for US defence contracts, as the DFARS clauses require.
Trace the impact: parts already built into product, delivered product, and the risk assessment under 8.1.1.
Close the loop — supplier disposition, sourcing exception review, and a corrective action that asks how the part got past the process.

Where the wider rules add obligations

Rule	Applies to	What it adds
SAE AS5553	Electronic parts; often flowed down by primes	The detailed avoidance, detection, mitigation and disposition process for electrical, electronic and electromechanical parts
SAE AS6174	Materiel — raw materials, castings, fasteners, non-electronic parts	The equivalent process for non-electronic items
SAE AS6081	Independent distributors of electronic parts	The distributor-side requirements primes may demand of brokers
DFARS 252.246-7007 and -7008	US DoD contractors and their supply chains for electronic parts	A counterfeit electronic part detection and avoidance system; sourcing from original manufacturers or authorised suppliers with defined exceptions; GIDEP reporting
AS9120	Distributors and stockists	The distributor’s own 8.1.4 obligations, plus splitting, storage and traceability rules that preserve the chain of custody

Frequently asked questions

What does AS9100 require for counterfeit parts?
Clause 8.1.4: processes, appropriate to the organisation and product, to prevent counterfeit or suspect counterfeit parts being used or delivered. Its NOTE lists training, obsolescence monitoring, approved-source purchasing, traceability, verification and test, monitoring of external reports, and quarantine and reporting — items the IAQG says become requirements in IA9100.

What is a counterfeit part?
AS9100’s definition: an unauthorised copy, imitation, substitute or modified part knowingly misrepresented as a specified genuine part of an original or authorised manufacturer. Remarked electronic components, cloned parts, salvaged parts sold as new and fasteners with forged certificates all qualify.

Are independent distributors banned?
No, but they are the last resort in the sourcing hierarchy and carry added verification. Primes commonly require AS6081 compliance from independent distributors and documented risk-based approval for each purchase from one.

What should we do with a suspect part?
Quarantine it and its lot, do not return it to the supplier, confirm by test, report to the customer and to GIDEP or ERAI (and under DFARS where applicable), trace any product it reached, and run a corrective action on the process that let it in.

Does counterfeit prevention apply to non-electronic parts?
Yes. AS9100 8.1.4 covers parts generally; AS6174 supplies the process for materiel — raw material, castings, forgings, fasteners — where forged certificates are the common counterfeit.

Where this leaves you

Build the counterfeit parts process from the seven NOTE items as if they were already requirements — because in IA9100 they will be — with the sourcing hierarchy doing most of the work, receiving inspection doing the rest, and a quarantine-and-report procedure that keeps a suspect part out of the supply chain rather than sending it back into it.

References

IAQG — IA9100 Key Changes, clause view — 8.1.4 Prevention of Counterfeit Parts: NOTE items becoming requirements.
SAE AS5553 — Counterfeit Electrical, Electronic, and Electromechanical (EEE) Parts; Avoidance, Detection, Mitigation, and Disposition — The detailed process standard for electronic parts.
DFARS 252.246-7007 — Contractor Counterfeit Electronic Part Detection and Avoidance System — The US defence obligation.

More on AS9100

Counterfeit parts prevention — you are here
Aerospace quality management: the AS9100 family
AS9100 vs ISO 9001
Product safety under AS9100 8.1.3
IA9100: the 2026 revision
Supply chain security

The Counterfeit Parts Prevention Procedure with the seven elements, the approved source register, the receiving inspection checklist, the suspect part quarantine and reporting form and the supplier flow-down clauses are in the AS 9100/9110/9120 Aerospace QMS Toolkit, or start with the free templates.

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