ITAR Registration -- Plan on Paying your Gunsmith more...

[spclark]

Off topic but interesting

More:

http://heatst.com/politics/still-no...ncs-seth-rich-as-conspiracy-theories-thicken/

 

[cs700]

This may be a dumb question but who has the legal authority to enforce this? Does the ATF enforce State Dept. regulations? FBI? DOJ?

 

[shortgrass]

Shynoloco, the license fee for a ATFE issued 07 Manufacturers License is still $150 for a 3 yr. license. The $2250 fee, is a 'registration fee' paid to the State Dept. (DDTC) yearly. This has been the "way it is" for a long time. The new regs issued by the State Dept make anyone who machines barrels, actions, stocks,parts a "manufacture",,,,,,,, not by ATFE , but by the State Dept. and ITAR regulation. Thus, those who do barrel work or make parts (even if it is ONE part), or glass bed would need to register and pay the fee (the ITAR 'registration fee). They might only hold a 01 Dealers License issued by ATFE, but would be considered a "manufacturer" under the 'new' ITAR regs,,,,,,,, whether they ever export/import, or not. A person or company can do gunsmith work under a 01 Dealers License issued by ATFE. They can install a new barrel from a barrel blank, glass bed, make an unobtainable part, thread a muzzle for a break/can, and much more,,, as long as the serial numbered part (the frame or receiver) is owned by the customer requesting the work. A 07 Manufactures License, issued by ATFE, can own the serial numbered part (the frame/receiver) and use it to build a complete rifle that'll be offered for sale to the general public. The new ITAR regs would have a ATFE 01 Licensed Gunsmith that installes barrels, threads muzzles, glass beds, etc., register with DDTC and pay the $2250 yearly fee, just as a ATFE 07 Licensed Manufacturer does now. (DDTC =Doctorate of Defense Trade Controls , under ITAR , under the US State Dept.) The ITAR regs and the ATFE regs concerning "who is a manufacurer" are different and do not agree. I do know what a 01 Dealer and a 07 Manufacturer (ATFE Licensees, under ATFE Regs) can and can not do as I've been dealing with these issues myself for 20+ yrs.

 

[Raythemanroe]

Shortgrass, What about the section refering to loading and reloading being manufacturing?


Ray

 

[shortgrass]

Ray, there is a seperate ATFE issued license for ammunition manufacturing (designated 06). I know there are excise tax issues with this just as there are excise tax issues for ATFE Licensed Manufacturers of firearms. I load ammo for no one but myself. You'd have to load commercial quanties of ammuntion or charge exorbitant fees to 'custom load' to make a profit and pay the taxes, not to mention the costs of liability insurance for such an endevor. It appears the individual handloader has "dodged the bullet" this time. Home handloader set-ups are not generally "automated", which is the criteria for ammo loading as stated in the new ITAR regs. That's about all I know about loading ammo for others, that and I have no interest in becoming a ATFE Licensed Ammunition Manufacturer. A person or company that holds a ATFE issued 07 Firearms Manufacturing License can manufacture ammunition, also. A ATFE 06 Licensed Ammunition Manufacturer is not licensed to manufacture firearms (or sell firearms, or gunsmith)

 

[shortgrass]

This may be a dumb question but who has the legal authority to enforce this? Does the ATF enforce State Dept. regulations? FBI? DOJ?

The State Dept. would probably refer it to the DOJ to level charges. This administration would probably send a detachment of Marines to come and get you......

 

[cs700]

The State Dept. would probably refer it to the DOJ to level charges. This administration would probably send a detachment of Marines to come and get you......

I would hope they give me notice of when they would be coming so I would have time to make sure I had enough Koolaid to serve them all.

 

[Louisiana Shooter]

TSA=JRS?

They're both Democrat shills........just block them and be done with it. I don't know why they are on this forum in the first place......other than to try to influence others to think in the same stupid communistic way.

 

[22BRGUY]

I am just so confused with all of these terms ITAR; DDTC: ATF; ATFE; DOJ; DOS; EO; etc. etc. I'm still stuck on the MEANING of "SHALL NOT BE INFRINGED". Could someone please clarify my mind on what that MEANS??????? if anything???

 

[Geronimo Jim]

Why in the devil should the state dept have anything to do with gunsmiths? Talk about
stretching logic. I hate liberals.

 

[Cold Bore]

I'm still stuck on the MEANING of "SHALL NOT BE INFRINGED". Could someone please clarify my mind on what that MEANS??????? if anything???

In today's political world?

Little to nothing.

 

[22BRGUY]

The question I have then is the "government" saying it "gives us the right" to "keep and bear" something that is "illegal" to manufacture or hugely "infringed" upon to manufacture??

 

[rardoin]

The State Dept. would probably refer it to the DOJ to level charges. This administration would probably send a detachment of Marines to come and get you......

Not likely...you know how he hates 'boots on the ground'. Now a precision munition launched from a UAV I can believe.

 

[Raythemanroe]

Ray, there is a seperate ATFE issued license for ammunition manufacturing (designated 06). I know there are excise tax issues with this just as there are excise tax issues for ATFE Licensed Manufacturers of firearms. I load ammo for no one but myself. You'd have to load commercial quanties of ammuntion or charge exorbitant fees to 'custom load' to make a profit and pay the taxes, not to mention the costs of liability insurance for such an endevor. It appears the individual handloader has "dodged the bullet" this time. Home handloader set-ups are not generally "automated", which is the criteria for ammo loading as stated in the new ITAR regs. That's about all I know about loading ammo for others, that and I have no interest in becoming a ATFE Licensed Ammunition Manufacturer. A person or company that holds a ATFE issued 07 Firearms Manufacturing License can manufacture ammunition, also. A ATFE 06 Licensed Ammunition Manufacturer is not licensed to manufacture firearms (or sell firearms, or gunsmith)

That seems interesting but I didn't read the intent to sell Clause, just the automated loading and reloading.. I never assume the government means commercial.. I assume from this they mean if you are using automated reloading machine they could assume the intent to sell..

Ray

 

[ED3]

That seems interesting but I didn't read the intent to sell Clause, just the automated loading and reloading.. I never assume the government means commercial.. I assume from this they mean if you are using automated reloading machine they could assume the intent to sell..

Ray

The word in that section that got me thinking was 'automated', and it's interpretation...

 

[madderg]

The sad and frightening fact is, I think, if things continue on this course coming out of Washington we will have to stand and say " No More..." and God help us, be willing to back up what we say. I weep to think of how wrong things have gotten in two generations, May God bless us and open their eyes to the truth.

 

[shortgrass]

Light-up those phones and in-boxes of your elected representatives!

 

[Louisiana Shooter]

Light-up those phones and in-boxes of your elected representatives!

AGREED!!!!! Do it guys!!! Light 'em up! Make your voice heard to your congressman and senators.......and don't forget to VOTE!

 

[WSnyder]

www.pmddtc.state.gov/registration

Note the words "Defense Articles". Read the words and do not read INTO the words. Domestic Gunsmiths are normally not in the business of manufacturing, exporting and importing "Defense Articles." Therefore they are exempt and have been by my reading of the language.

Alex

You are only looking at one little portion rather than the whole. The "defense articles" you speak of are defined in the "munitions list" linked on the page you linked. Read the definitions on that list. I think you'll find that any firearm you likely are interested in is defined in the "munitions list" and are potentially subject to ITAR. The new ruling basically states they do not care if you import/export, you are subject anyway if you perform any of the work defined in the ruling and if you perform any of that work you are a manufacturer in their eyes.

Of course this applies for the most part to licensed FFL's (there are exceptions to this) and not individuals but how long will it be until they seek a way to end the home shop "loophole"?

 

[gme]

Shynoloco, the license fee for a ATFE issued 07 Manufacturers License is still $150 for a 3 yr. license. The $2250 fee, is a 'registration fee' paid to the State Dept. (DDTC) yearly. This has been the "way it is" for a long time. The new regs issued by the State Dept make anyone who machines barrels, actions, stocks,parts a "manufacture",,,,,,,, not by ATFE , but by the State Dept. and ITAR regulation. Thus, those who do barrel work or make parts (even if it is ONE part), or glass bed would need to register and pay the fee (the ITAR 'registration fee). They might only hold a 01 Dealers License issued by ATFE, but would be considered a "manufacturer" under the 'new' ITAR regs,,,,,,,, whether they ever export/import, or not. A person or company can do gunsmith work under a 01 Dealers License issued by ATFE. They can install a new barrel from a barrel blank, glass bed, make an unobtainable part, thread a muzzle for a break/can, and much more,,, as long as the serial numbered part (the frame or receiver) is owned by the customer requesting the work. A 07 Manufactures License, issued by ATFE, can own the serial numbered part (the frame/receiver) and use it to build a complete rifle that'll be offered for sale to the general public. The new ITAR regs would have a ATFE 01 Licensed Gunsmith that installes barrels, threads muzzles, glass beds, etc., register with DDTC and pay the $2250 yearly fee, just as a ATFE 07 Licensed Manufacturer does now. (DDTC =Doctorate of Defense Trade Controls , under ITAR , under the US State Dept.) The ITAR regs and the ATFE regs concerning "who is a manufacurer" are different and do not agree. I do know what a 01 Dealer and a 07 Manufacturer (ATFE Licensees, under ATFE Regs) can and can not do as I've been dealing with these issues myself for 20+ yrs.

good explanation, to that I will add, you dont need to be an FFL at all to be forced to register with the DDTC, only a "maufacturer of articles of defense" in my case making stocks, ATF does not regulate stock makers so I had no need for an FFL at the time, I had not yet supplied any product to any government agency at the time, but because stocks fall under ITAR control (as any component part of a firearm does) I was compelled to register under threat of a large fine.