Counterfeit Policy

Legacy Components, LLC is committed to Quality, and we are continuously enhancing our quality management system and procedures to combat the growing problem of counterfeit parts from entering the supply chain.

IN-HOUSE INSPECTION (ALL PRODUCTS)

  • Visual and or Microscopic Inspection in ESD Certified Area
  • Pin-Out / Marking and part dimensions confirmation via our 260 Million+ Component Database, customer spec, and or datasheets.
  • Lot Code / Date Code documentation
  • Digital Photo records of all product is permanently archived

IN-HOUSE INSPECTION (WHEN APPLICABLE)

  • Decapsulation
  • Permanency Testing for marking authenticity

OUTSOURCED TO PARTNER LABS (WHEN APPLICABLE)

  • XRF – PB, RoHS, and materials
  • X-Ray and secondary X-Ray Fluorescence
  • Baking for all MSL (Moisture Sensitivity Level) required items
  • Electrical Test
  • Upscreen

We guarantee Form, Fit, and Function per the manufacturer’s specifications on all product shipped. Below is a review of how counterfeit risk mitigation  is integrated into our Quality Management System and our processes.

Contract Review

The Initial Quote to the customer is converted through the software directly into a Sales Order on receipt of a Customer Purchase Order. All Customer requirements are then entered into Pentagon. Sales Order then undergoes a contract review and approval process whereas the Sales Order Processor reviews customer requirements and verifies what is applicable before signing off on the order. Due to permissions in the system, orders are required to be signed off by the Sales Order Processor before the order is released for procurement.

All applicable Customer requirements are automatically flowed down through the software and to the Supplier via a LEGACY purchase order and/or our Terms and Conditions of Purchase.

Procurement – When procuring parts it is always Legacy Components, LLC preferred method to procure directly from OCM’s or Authorized Suppliers*  who are listed on the AVL.

When a new source is used Legacy Components has an approval process that ensures compliance with our Quality Standards and the terms and conditions of our Purchase Order. Legacy Components, LLC requires all Suppliers to acknowledge and confirm the understanding of requirements and terms upon acceptance of a LEGACY purchase order.

To further mitigate the risks of receiving counterfeit parts all Purchase Orders have the following terms listed:

  1. All parts must be new and in original manufacturer’s packaging unless otherwise stated above. A minimum 1 year warranty is required on all parts.
  2. Parts must be fit, form, and function, and require a Certificate of Conformity, along with test reports and/or airworthiness certificates traceable to OEM.
  3. Flow down of all requirements listed on this PO to sub-tier suppliers is required.
  4. Please notify us in writing prior to shipping if there are any changes or nonconformities identified with this product.
  5. Legacy Components retains the right of access to all organizations, authorities, records, and facilities involved with this order.
  6. If parts received are deemed “suspect counterfeit” or “counterfeit” full traceability to the OEM will need to be provided or parts will be impounded.

Full replacement or credit will be at your expense. This may result in you being removed from our AVL.

  1. Vendor responsible for all escrow fees, shipping costs & other charges if products are in non-compliance with our PO requirements and terms & conditions.
  2. Acceptance of this PO is acknowledgement that you have read and agree to all Purchase Order Terms and Quality Clauses found listed and on our website.

In addition, LEGACY Purchase Order Terms and Conditions do have a Counterfeit Parts Clause that states the following:

COUNTERFEIT PARTS. Seller is hereby notified that the delivery of counterfeit parts is of special concern to Buyer. Seller shall not deliver Counterfeit parts to Legacy Components under this purchase order. Seller shall only purchase products to be delivered to Legacy Components from the Original Component Manufacturer (OCM), or the Original Equipment Manufacturer (OEM),

Regardless of the source of procurement, Seller must provide OCM/OEM documentation that authenticates traceability of the part to the applicable OCM/OEM.

i.) If suspect or counterfeit parts are furnished under this order or are found in any of the goods delivered hereunder, such items shall be impounded by Buyer.  Seller shall, at its own expense, promptly replace such counterfeit parts with parts acceptable to the Buyer and Seller shall be liable for all costs related to the removal and replacement of said parts. The remedies contained in this paragraph are in addition to any remedies

ii.) Legacy Components may have at law, equity or under other provisions of this purchase order. Seller shall include this clause or equivalent provisions in lower tier subcontracts for the delivery of items that will be included in or furnished to Legacy Components under this purchase order.

Supplier Approval A register of all unapproved and approved Suppliers is maintained, including the scope of their supply and the criteria for approval. Due to security controls within our software a PO cannot be generated for a supplier that is not approved. All Suppliers are approved in accordance with Customer requirements and LEGACY QMS procedures & work instructions.

In such case where a supplier is not an Authorized Supplier *, or OEM/OCM, Legacy Components takes action to mitigate risk.

A thorough evaluation is performed, which includes, but is not limited to verification of a quality management system, a satisfactory completion of our quality questionnaire, references check, and thorough review of the supplier through various industry sources such as ERAI. These suppliers are then put in our system on a probationary status as we monitor the performance of the initial 3 orders all according to our Work Instructions for Vendor Approval (WI- P1).

Supplier performance which includes on time delivery and quality of product is monitored.

Verification of Purchased Product – All materials received are inspected to verify conformance to the Customer and Manufacturer specifications and according to the ERAI guidelines. Parts are tested if necessary and/or required by customer. Where customer requires in purchase order supply chain traceability to the OCM or aftermarket manufacturer that identifies the name and location of all of the supply chain intermediaries from the part manufacturer to the direct source of the product for the seller can be provided. If traceability cannot be provided when required or it is determined it may be falsified. A non-conformance is issued. Based on the response a supplier may be removed from our AVL (Approved Vendor List).

Material Control – All materials deemed to be suspect, fraudulent or confirmed counterfeit shall be processed in accordance with LEGACY‘s QMS

PROCEDURE 8.3 CONTROL OF NONCONFORMING PRODUCT.

Training – All personnel are trained as appropriate to their job requirements in the avoidance, detection, mitigation and disposition of suspect, fraudulent or confirmed counterfeit parts. Training is provided annually or as needed.

*AUTHORIZED SUPPLIER: Aftermarket manufacturers and OCM authorized sources of supply for a part.

 

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