Prove it or it doesn't ship: approved origin for every part

Federal buyers and automakers now face hard deadlines to keep restricted semiconductors and modules out of what they buy and sell. Yet the industry still answers "where did this part come from?" with a supplier's signature. When a re-marked chip passes electrical testing and a cloned module boots like the real one, paperwork is a statement of belief, not evidence.

The rules now ask for proof, and the clock is running

• Federal procurement. Section 5949 of the FY23 defense authorization bars federal agencies from buying products containing chips from named chipmakers and their affiliates. The FAR Council's proposed rule takes effect December 23, 2027, and asks contractors for a "reasonable inquiry" and a certification, with no bill of materials required.
• Connected vehicles. Commerce's connected vehicle rule bars restricted connectivity and automated-driving software from model year 2027 and hardware from model year 2030. Automakers file annual Declarations of Conformity.
• Counterfeit parts. Defense counterfeit-part rules already require suppliers to detect and avoid counterfeit electronic parts, through supplier controls, traceability records and testing.

Every one of these ends in a signature. None of them asks the part to prove anything itself.

Why hunting for banned parts fails

The usual approach is a blocklist: find the bad parts and pull them. It loses because the bad part is built to look like a good one.

• Markings lie. A chip's top marking is ink. Re-marked parts carry the logo, part number and date code of the real thing.
• Tests pass. In ERAI's 2025 data, 24% of suspect counterfeits that were tested passed electrical testing.
• Bills of materials stop at the first layer. A module maker can declare its own parts. It rarely knows where its supplier's supplier sourced a memory chip.
• Sampling misses. Labs inspect a few parts per lot; the rest ship on faith.

Flip the question: prove it is approved

Stop asking "is this part banned?" and ask "can this part prove it is approved?" A part that cannot answer is not approved. No silicon identity, no approval.

1. Enroll at the source. An approved fab or assembler enrolls each part that carries the UBIQS identity. The enrollment record captures who made it, where and in which lot.
2. Verify anywhere. At receiving, at integration and in the field, the part proves it matches its enrollment. A re-marked, swapped or cloned part fails, because the identity is silicon-intrinsic with no stored secret and cannot be moved to another part.
3. Attest the whole product. A board or module built around the UBIQS root of trust produces signed, tamper-evident proof of what it is and where it was enrolled.

A banned part does not need to be recognized. It simply cannot produce the proof.

What changes for the people who sign

• Federal contractors answer a "reasonable inquiry" with per-unit proof that every chip came from an approved source, instead of a chain of supplier letters.
• Automakers back their annual Declaration of Conformity for the software-defined vehicle with signed proof from each telematics module and driving computer.
• Defense suppliers close the counterfeit gap at receiving, without relying on a sample sent to a lab.
• Auditors check signatures, not paperwork, and can re-check any unit in the field years later.

The deadlines are fixed, and the parts going into those products are being designed and sourced now. Build the proof into the silicon today, and compliance becomes a check you run instead of a risk you sign for.

Sources

• FAR Council issues notice of proposed rulemaking to implement prohibition on acquisition of certain semiconductors, Covington, February 2026
• Commerce finalizes rule to secure connected vehicle supply chains, Bureau of Industry and Security, January 2025
• 2025 Annual Report, ERAI