DEFENSE DEPARTMENT

Comments on counterfeit IT regulation due Monday

Main problem is lack of clarity

Comments on the Defense Department’s first set of proposed regulations on counterfeit electronic parts are due on July 15.

Originally released on May 16, the Defense Department’s  proposed regulations were required in Section 818 of the 2012 National Defense Authorization Act.

It called on the Defense Department to eliminate the use of counterfeit electronic parts in products tused by the agency.

However, Section 818 left the definition of “counterfeit part” up to the Defense Department to define, and the three definitions that were given have caused controversy, generally because their lack of specificity.

For more information, Foley and Lardner LLP published a comprehensive breakdown of the issue, which can be accessed here.

Comments can be submitted by any of the following methods:

E-mail: dfars@osd.mil, and include DFARS Case 2012-D055 in the subject line.

Fax: 571-372-6094

Mail: Defense Acquisition Regulations System, Attn: Ms. Meredith Murphy, OUSD(AT&L)DPAP/DARS, Room 3B855, 3060 Defense Pentagon, Washington, D.C. 20301-3060

Regulations.gov: Submit comments via Federal eRulemaking portal by entering “DFARS Case 2012-D055” under the heading “Enter keyword or ID” and selecting “Search.” Select the link “Submit a Comment” that corresponds with “DFARS Case 2012-D055.” Include name, company name (if applicable), and “DFARS Case 2012-D055” on the attached document.

Please keep in mind that comments will generally be posted to the Regulations.gov website, including any personal information provided.

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