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

[riverwolf1]

JRS, is a flaming liberal bomb thrower, just put him on your ignore list, trust me you will be glad you did!

 

[JLT]

That question is probably why you are no longer in business. An additional $5.00 dollars to chamber the barrel helps to recover the ITAR fee. You can't dump the ITAR fee on one customer. It has to be amortized.

450 barrels per year to recover the ITAR registration fee @ $5 per. That's NOT an average gunsmithing operation.

 

[gme]

That question is probably why you are no longer in business. An additional $5.00 dollars to chamber the barrel helps to recover the ITAR fee. You can't dump the ITAR fee on one customer. It has to be amortized.

I didn't know I was no longer in business, and I'm registered with the DDTC so i know more about the subject than you do, the paperwork is a real pain, and so is the cost, I have many gunsmith friends who would be hurt by this, who simply could not justify the cost because their profits are just too slim, so unless your in the business (yes, like I still am) you need to show a little gratitude for the men that are willing to work for peanuts to keep your rifles up and running...

 

[Shynloco]

Guys,
I'm no export, but that organization has to do with importing and exporting certain MILITARY grade weapons and DOMESTIC GUNSMITHS are exempt UNLESS THEY IMPORT OR EXPORT weapons.

Alex

 

[shortgrass]

Please show us where it states that, Shynoloco. Please provide a 'link'. 'Cause I'm not reading it that way.

 

[gme]

Guys,
I'm no export, but that organization has to do with importing and exporting certain MILITARY grade weapons and DOMESTIC GUNSMITHS are exempt UNLESS THEY IMPORT OR EXPORT weapons.

Alex

not anymore

 

[JLT]

not anymore

Gary is correct. Any operation involving 'machining' or 'cutting' of a firearm or any major component is considered 'manufacturing'. The threading, chambering or rechambering of barrels are operations specifically mentioned as requiring registration with the DDTC. The drilling and tapping of receivers for scope mounting are specifically exempt (thanks for the crumbs, you creeps!), but any other operation involving a lathe, mill, drill press or EDM tooling will likely be considered 'manufacturing'.

Any way you slice it, this is a turd sandwich.

 

[gme]

Here's contact page for your state representative in DC, you may want to let them hear from you on this matter
http://www.house.gov/representatives/find/

 

[Shynloco]

Please show us where it states that, Shynoloco. Please provide a 'link'. 'Cause I'm not reading it that way.

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

Editor: Alex, sorry, normal firearms ARE considered Defense articles. That's very clear if you read the DDTC notice. AND it's also clear from ITAR rules that this registration requirement applies even if NO PRODUCT of any kind is actually exported.

 

[gme]

It's amortized. You add the cost to recover your outlay with each and every function you perform. It might be pennies, it might be one dollar. You want to stay in business and make a profit? You'd better learn how to treat it as such!

so to the guy who does 20 barrels a year he'll need to add $112.50, like Nat said in his OP "plan on paying your gunsmith more"

 

[itchyTF]

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

I wouldn't put it past this sleazy administration to expand definitions to suit them. Didn't/doesn't the military use shotguns and Rem 700s? Wouldn't they be considered "defense" articles?

Would this mean the home "gunsmith" who just does this for himself come under this?

 

[gme]

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

that page was updated last on 4/20/15, the new guidelines were enacted by Obama on 7/22/16

 

[swd]

Does anyone know when this goes into effect?

 

[tmr]

This can also open it up to having to charge Excise tax as well since they are now calling rebarreling "manufacturing". If the TTB Treasury decided to, they could follow suit and call a barrel job manufacturing and hit the smith with another 10-12% excise.

 

[Bob L.]

It's amortized. You add the cost to recover your outlay with each and every function you perform. It might be pennies, it might be one dollar. You want to stay in business and make a profit? You'd better learn how to treat it as such!

Since the fee is annual, the amortization period is annual. Many smaller gunsmith operations simply do not have enough functions to spread the fee over and still maintain competitive pricing. I believe a large percentage will simply close up shop rather than try to expand their volume to cover the added fee. The juice will not be worth the squeeze.

This is the intent.

 

[savagedasher]

I wouldn't put it past this sleazy administration to expand definitions to suit them. Didn't/doesn't the military use shotguns and Rem 700s? Wouldn't they be considered "defense" articles?

Would this mean the home "gunsmith" who just does this for himself come under this?

The way I read it is you import or export Larry

 

[swd]

This is just so effed

The way I read it is you import or export Larry

Thats not the way I read it but I'm no expert. I hope you're right!

 

[savagedasher]

This is just so effed

Thats not the way I read it but I'm no expert. I hope you're right!

Neither am I I don't deal in the military sales. Larry

 

[gme]

If you can't figure out how to amortize your actual cost's, you shouldn't be in business!

I get by

 

[JLT]

It's amortized. You add the cost to recover your outlay with each and every function you perform. It might be pennies, it might be one dollar. You want to stay in business and make a profit? You'd better learn how to treat it as such!

I believe the word you are looking for is 'allocated', not 'amortized'. I'm quite familiar with general business practices, having served as a senior executive in several large corporations throughout my career. I own and operate a bricks & mortar firearm and custom shop because I want to, not because I have to. I have the luxury of being able to walk away without having to worry about paying the bills and putting food on the table. Others are not so fortunate and I feel badly for those folks.

There are many methods of allocation - not everything can or should be treated as overhead, which is what you argue. Some expenses are most correctly allocated to the operations that generate them. A purely retail LGS thinking about expanding into repairs and custom work should not think in terms of 'how much can I raise my prices' to directly offset the capital investment and any other expenses that would be incurred as a result of the expansion. The expansion must make economic sense in a much narrower context, if not completely on its own, otherwise the LGS will never sell another can of RemOil or another box of .22 rimfire again. Big box stores will absorb even more market share as the threshold of elasticity is exceeded by more and more folks that think 'overhead' is the way to go. I'm located two miles from a WalMart. I see this every day. The roadside is littered with failed businesses that thought they could get one part of their operation to subsidize another.

This is a real problem for many.