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Focus on Regulation

Hogan Lovells Issues Client Alert on New DoD Counterfeit Parts Regulations

Hogan Lovells’ Government Contracts Practice recently issued a Client Alert on the first proposed rule issued by the Department of Defense (“DoD”) regarding the detection and avoidance of counterfeit parts in the DoD supply chain.  Authored by Partners Thomas L. McGovern III and Michael D. McGill and Associate Michael J. Scheimer, the alert analyzes each section of the proposed rule, including key definitions, cost principles, and contract clause language.  The authors write:

The proposed regulations . . . reveal that DoD does not intend to extend the reach of the rules beyond electronic parts, at least for the immediate future.  But the Proposed Rule seems to raise or avoid as many questions as it answers, falling short of the hope that it might provide clarity on the most pressing issues, including DoD’s intentions with respect to designating “trusted suppliers” and what will be expected of prime contractors in managing their respective supply chains.

You can download a copy of the client alert here.