AQAP-2021 avoidance of counterfeit materiel

What it is

What AQAP-2021 covers

AQAP-2021 is NATO guidance, published as an Allied Quality Assurance Publication in June 2023 (Edition A, Version 1), for avoiding counterfeit materiel in the defence supply chain. It defines counterfeit materiel broadly: any materiel whose origin, age, composition, configuration or certification status has been falsely represented, through misleading marking, misleading documentation, or any other means including failing to disclose information, unless the misrepresentation is shown not to be the result of dishonesty. That carve-out matters: an honest labelling mistake is not counterfeiting under this document's own definition.

The guidance names the conditions that raise counterfeit risk: parts known to be vulnerable to counterfeiting such as electrical, electronic and electro-mechanical (EEE) components; parts that are obsolescent or foreseen to become so during the life of the equipment; multiple tiers in the supply chain; traceability that is not otherwise mandated; fraudulent test results; and counterfeited certificates.

Who it names, and how it binds

AQAP-2021 addresses NATO nations and agencies involved in the acquisition and assurance of defence materiel, and it is explicit that it is not itself a contractual document. Instead it offers an example set of counterfeit-avoidance contract requirements that a nation or agency can choose to write into a contract, to give the acquirer confidence a supplier has appropriate arrangements. Nothing in AQAP-2021 binds a supplier until that happens. It sits under STANREC 4791, which recommends the standard rather than committing nations to it, so adoption is a national choice, not an obligation.

The nine areas Annex A sets out

Annex A's example clauses run through nine areas: a documented counterfeit-avoidance policy and Anti Counterfeit Management Plan available to customers on request; a named management representative with authority over the arrangements; role-based training and awareness with records kept; purchasing controls that assess counterfeit risk against criticality and trace materiel to the manufacturer where product integrity matters; test and verification rigor set by risk and criticality; control of suspected and confirmed counterfeit materiel so it cannot re-enter the supply chain; reporting occurrences to the customer, the genuine materiel's IP owner, information-gathering bodies and national law enforcement; wider anti-corruption measures such as covert marking, controlled destruction of substandard materiel and tooling, and published lists of franchised distributors; and an Obsolescence Management Plan aligned with EN IEC 62402:2019, since unmanaged obsolescence is one of the document's named risk factors.

What an auditor checks

Where a contract has incorporated these requirements, NATO nations and bodies are told to consider Government Quality Assurance Surveillance (GQAS) to confirm supplier arrangements are appropriate and effective. That is government quality assurance, a national authority's representative auditing against a specific contract, not third-party certification, and AQAP-2021 does not establish or claim any certification scheme. Annex B gives the auditor's actual questions: whether the policy is documented and reviewed, who the management representative is, whether inspectors are trained to recognise counterfeit parts, how the Approved Supplier List is rated on counterfeit-avoidance criteria, what traceability evidence exists to the OEM or OCM at goods-inward, and how scrap, packaging and tooling are disposed of so they cannot be reused to fake legitimate materiel. The document does not say how often this surveillance runs; that is left to the contract.

Where it sits among other counterfeit-avoidance standards

AQAP-2021 takes its terms from ISO 9000:2015 and AQAP-2110 unless it defines them separately, and its one normative reference is EN IEC 62402:2019 Obsolescence Management. Clause 2.3 points to SAE AS5553, IEC/TS 62239, SAE AS6174 and UK Def Stan 05-135 as alternative counterfeit-avoidance requirements a nation could use instead, and Annex C synopsises a further set, including ISO 22380, IEC/TS 62668-1 and -2, and several more SAE documents, for organisations that already work to one of them.

Standards it references

• AQAP-2110Background