SR-11(3): Anti-counterfeit Scanning

SR-11(3) requires you to scan system components for counterfeits as part of your supply chain and component acceptance practices. To operationalize it, define what “component scanning” means for your environment, apply it at receiving and during maintenance/refresh cycles, and retain objective evidence that scanned items were screened and exceptions were dispositioned. ¹

Key takeaways:

• Define a counterfeit scanning standard tied to component risk and acquisition channels, then embed it into receiving and maintenance workflows.
• Make scanning outcomes auditable: logs, inspection records, exception tickets, and supplier traceability must map to specific component identifiers.
• Treat “can’t scan” as a controlled exception with compensating checks and documented approval, not a silent gap.

The sr-11(3): anti-counterfeit scanning requirement sits in NIST’s Supply Chain Risk Management (SR) control family and is aimed at one operational problem: you can’t manage what you can’t trust, and counterfeit components undermine both reliability and security. Your assessor will not be satisfied with a policy statement that says “we avoid counterfeit parts.” They will look for repeatable, embedded steps in procurement, receiving, staging, and maintenance that show you actively screen components and know what to do when a component fails screening.

For a Compliance Officer, CCO, or GRC lead, the fastest path is to translate “scan for counterfeit system components” into (1) defined scanning triggers (when you scan), (2) defined methods (how you scan), (3) defined scope (what you scan), and (4) defined evidence (what you retain). This page gives requirement-level implementation guidance you can hand to IT operations, data center teams, endpoint teams, and procurement to implement quickly, then defend in an audit.

Regulatory text

Requirement (excerpt): “Scan for counterfeit system components {{ insert: param, sr-11.03_odp }}.” ¹

Operator interpretation of the text: You must perform a scanning/inspection activity designed to detect counterfeit system components, and you must be able to show it happened for components in scope. The control does not prescribe a single technology; it requires an implemented practice that is appropriate for your environment and is executed consistently. ¹

Plain-English interpretation (what it really means)

• You cannot rely only on supplier promises. You need an internal screening step.
• “System components” includes hardware and can reasonably include replaceable parts (drives, memory, network modules), and other components your organization accepts into the environment.
• “Scan” should be defined in your environment. It can include authenticity checks, serial/lot verification, packaging/label inspection, and other technical or procedural checks that detect counterfeit indicators.
• If you use third parties (integrators, maintenance providers), you still own the requirement. You can delegate performance, but not accountability.

Who it applies to

Entity scope: Federal information systems and contractor systems handling federal data that implement NIST SP 800-53 controls. ¹

Operational scope (where this shows up):

• Procurement and sourcing: purchase channels, approved suppliers/resellers, contract language, receiving requirements.
• Receiving and inventory control: docks, IT storerooms, data center receiving, kitting/staging areas.
• Build and deployment: imaging stations, configuration facilities, integration labs.
• Maintenance and refresh: RMA processes, spare parts, break/fix workflows, field service.
• Asset management: tying authenticity checks to asset identifiers and chain-of-custody records.

What you actually need to do (step-by-step)

Use this as a build sheet. Assign an owner for each step and require evidence output.

Step 1: Define component scope and “scan” standard

1. Define “system components” for your program (categories you will scan). Keep it concrete: servers, laptops, network gear, storage, removable/replaceable modules, critical spares.
2. Define what “scan” means in your SOP. Your definition should include:
   • What checks are performed (for example: serial/part number validation, packaging/label inspection, supplier traceability confirmation).
   • What tools/systems are used (asset system, supplier portals, inspection checklists, test utilities).
   • What constitutes pass/fail/needs-review.
3. Set triggers for scanning so execution is deterministic:
   • At receiving for newly purchased components.
   • At staging before deployment (if receiving is centralized and staging is separate).
   • At re-introduction (repairs, RMAs, returned spares).
   • For high-risk channels (spot buys, urgent replacement purchases) apply heightened checks.

Control objective you’re building toward: a consistent, documented scanning practice aligned to your supply chain risk posture. ²

Step 2: Build the workflow into procurement and receiving

1. Procurement gate: require purchase through approved channels where possible, and flag exceptions (gray market sourcing, non-authorized resellers) for additional screening steps.
2. Receiving checklist: create a standard inspection record completed at receipt. Minimum fields to capture:
   • Purchase order / receipt identifier
   • Supplier identity
   • Component make/model
   • Serial number(s) / asset tag
   • Inspection/scanning steps performed
   • Result (pass/fail/hold)
   • Inspector identity and date/time
3. Quarantine process: establish a “hold” location or logical quarantine state in inventory for items pending review or that fail scanning.
4. Disposition rules: define what happens when a component is suspected counterfeit:
   • Stop deployment.
   • Escalate to Security/ITAM/procurement.
   • Open a tracked ticket.
   • Preserve packaging and documentation for investigation.

Step 3: Tie scanning results to asset management (audit survivability)

1. Bind scan evidence to unique identifiers: serial number, asset tag, or other immutable identifier.
2. Record chain-of-custody: at minimum, record who accepted the component, where it was stored, and where it was deployed (or that it was rejected).
3. Map to your control inventory: ensure SR-11(3) is mapped to an owner, procedure, and recurring evidence artifacts so the control is assessable on demand. This is the most common gap in practice: scanning may happen informally, but there’s no control package to prove it. ¹

Step 4: Manage third-party and integrator involvement

1. Contractual expectations: require third parties who supply, integrate, or service components to follow your anti-counterfeit acceptance requirements or to provide equivalent evidence.
2. Evidence intake: define what you will accept as evidence from a third party (inspection logs, authenticity attestations tied to serial numbers, chain-of-custody documentation).
3. Spot checks: reserve the right to re-scan or re-inspect a sample of third-party-provided components internally, particularly for critical systems.

Step 5: Operate the control continuously (not a one-time project)

1. Training: train receiving/staging staff and IT operations on counterfeit indicators and your escalation path.
2. Exception handling: create a formal exception mechanism for cases where scanning cannot be performed (for example, emergency replacements). Require compensating controls and written approval.
3. Metrics you can defend without making up numbers: track counts of components received, scanned, held, rejected, and exceptions approved. Keep the reporting internal; the audit requirement is evidence of execution, not performance marketing.

Required evidence and artifacts to retain

Your assessor will ask for objective evidence. Build a tidy evidence set:

Core artifacts (expected)

• Anti-counterfeit scanning SOP (what “scan” means, scope, triggers, pass/fail criteria). ¹
• Receiving inspection/scanning records tied to serial/asset identifiers. ¹
• Quarantine and disposition tickets for failed/held components (with approvals and outcomes).
• Approved supplier/channel list and documented exception approvals (if applicable).
• Asset inventory entries that reference scan status or link to scanning evidence.

Supporting artifacts (often needed in audits)

• Third-party evidence package for integrators/maintainers (attestations + component identifier lists).
• Training records for staff performing inspections.
• Periodic management review notes (what was reviewed and what corrective actions were opened).

Common exam/audit questions and hangups

Expect these, and prep the answers with evidence pointers:

1. “Define ‘scan.’ What exactly do you do?” Auditors reject vague language. Show the SOP and a completed inspection record. ¹
2. “Show me proof for a sample of components.” Be ready to produce a list of recently received components with linked scan records.
3. “What happens when something fails?” Show a ticket, quarantine record, and disposition decision.
4. “How do you cover components provided by third parties?” Show contractual language and third-party evidence intake records.
5. “Who owns the control?” Name an accountable owner (often IT Asset Management, Supply Chain/Procurement, or Security) and show the control mapping and evidence cadence. ¹

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails in assessment	Fix
“We only buy from reputable suppliers” as the whole control	SR-11(3) calls for scanning; procurement hygiene alone rarely proves execution	Add receiving/staging checks with recorded outcomes. 1
Informal scanning with no records	Audits run on evidence	Use a checklist or ticket template tied to serial numbers.
Scanning only for brand-new purchases	Counterfeits enter through RMAs, repairs, and spares	Apply triggers for re-introduction and maintenance workflows.
Exceptions handled ad hoc	Exceptions become the real process	Require formal exception approval and compensating steps.
Third-party integrator “handles it”	Accountability still sits with you	Require evidence from third parties and perform periodic internal verification.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so this page does not summarize enforcement actions.

Operationally, the risk is straightforward: counterfeit components can degrade availability, void warranties, introduce unknown firmware or hardware behavior, and complicate incident response because you cannot trust the component baseline. From a compliance standpoint, the most common failure mode is “activity without evidence”: teams may do visual checks, but cannot demonstrate consistent scanning tied to specific assets. ¹

A practical 30/60/90-day execution plan

Use phased execution to get to audit-ready operation quickly without inventing timing guarantees.

First 30 days (stand up the control)

• Assign a single accountable owner and name supporting teams (Procurement, Receiving, ITAM, Security).
• Draft and approve the anti-counterfeit scanning SOP: scope, triggers, steps, pass/fail criteria, quarantine, disposition, exceptions. ¹
• Implement a standard inspection record (form, ticket type, or workflow) and require serial/asset identifiers.
• Pilot the workflow with one component class (for example, end-user devices or network gear) to validate evidence capture.

Days 31–60 (expand and integrate)

• Expand scope to additional component classes and all receiving locations.
• Add RMA/repair/returns triggers so re-introduced components are scanned.
• Update third-party agreements or add operating procedures for integrators and maintenance providers to deliver acceptable evidence.
• Create an internal evidence folder structure (or GRC control record) so audit requests can be fulfilled quickly.

Days 61–90 (stabilize and make it repeatable)

• Run a sampling review: pick recent receipts and confirm each has complete evidence and correct disposition.
• Train staff who execute the control and track training completion.
• Add a lightweight management review step to catch drift (missing serials, incomplete checklists, undocumented exceptions).
• In Daydream, map SR-11(3) to its owner, procedure, and recurring evidence artifacts so requests and renewals do not depend on tribal knowledge. ¹

Frequently Asked Questions

Does SR-11(3) require a specific anti-counterfeit scanning tool?

The text requires you to “scan for counterfeit system components,” but it does not mandate a single tool. Define what scanning means in your SOP and prove consistent execution with evidence tied to specific components. ¹

What counts as a “system component” for SR-11(3)?

Treat it as the hardware and replaceable parts you accept and deploy in your environment, especially those that can affect security or availability. Document your scope decision so auditors see a deliberate boundary, not an omission. ¹

How do we handle emergency purchases where we can’t follow normal channels?

Allow a controlled exception with written approval, compensating checks, and a post-receipt inspection record. Do not allow “urgent” to become an undocumented bypass of the scanning requirement. ¹

If a third-party integrator provides the components, are we still responsible?

Yes. You can require the third party to perform scanning and provide evidence, but your program must be able to produce that evidence during assessment. ¹

What evidence do auditors ask for most often?

They typically ask for your procedure plus a sample set of receiving records tied to serial numbers, along with any quarantine/disposition tickets for failures. Build your workflow so this evidence is produced automatically as work is done. ¹

How do we prove the control operates over time, not just once?

Show multiple inspection records across different dates and component types, plus periodic review notes and exception tracking. In practice, auditors want to see a repeatable workflow with consistent artifacts. ¹

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5