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United States News Title: Oldie but Goodie: New ITAR Guidance to Squeeze Small Gunsmiths According to DDTC, anyone meeting the following requirements should expect to apply for ITAR registration, even if business activities are limited to domestic sales/services (bold added by Prince Law): (a) Any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, is required to register with the Directorate of Defense Trade Controls under § 122.2. For the purpose of this subchapter, engaging in such a business requires only one occasion of manufacturing or exporting or temporarily importing a defense article or furnishing a defense service. A manufacturer who does not engage in exporting must nevertheless register. Now, all of that may make perfect sense on the surface. It seems reasonable that anyone who manufactures defense articles or provides defense services should fall under ITAR regulations. However, there are a few problems with these terms. Firstly, the United States Munitions List, upon which classification as a defense article is based, is remarkably inclusive. In fact, virtually any firearm .50 caliber and smaller is included on the list. Military use of a firearm or class of firearms has no bearing on its inclusion. So in reality, a firearm need not have a defensive application to be considered a defense article. Secondly, the list of actions that constitute defense services is also surprisingly extensive. It is this section of the guidance that should be troubling for small-time gunsmiths. First, lets take a look at what does not require registration: Barrel threading isnt the only sort of activity that this guidance could cover, though. Virtually any sort of commercial machining work that materially changes a firearms characteristics (e.g. shortening the barrel, fluting/dimpling the barrel, rebarreling certain firearms) now requires ITAR registration. The real issue here isnt necessarily the added paperwork of ITAR registration. Currently, Tier 1 registration (the level most domestic organizations would seek) costs $2,250 per year. This is up from the $1,750 fee that was charged before the 2008 introduction of the tiered system. For a small business, thats a substantial amount of money. Considering that most shops charge between $50 and $100 to thread a barrel, thats somewhere between 20 and 50 jobs that a gunsmith must complete before simply breaking even on the ITAR fee. Needless to say, some shops are really going to feel the squeeze. The unwitting expansion of BATF bureaucratic powers have been expanded to include the above griefs. The federal government's power to tax and thus restrict or otherwise eliminate personal RKBA based on national defense purposes will increase or diminish RKBA. Post Comment Private Reply Ignore Thread Top Page Up Full Thread Page Down Bottom/Latest
#1. To: buckeroo (#0)
A family was manufacturing complete AR15 recievers in their little shop. IIRC they were using a 3D printer for some parts. She advertised on fb's buy and sell page and promptly got the bootstamp of disapproval. No news. Don't know what happened to them.
The Trumpkins do all their own modifications, so they're exempt. Big deal. Where is the microwave, beer dispenser, and the refrigerator ??
Si vis pacem, para bellum Rebellion to tyrants is obedience to God. Never Pick A Fight With An Old Man He Will Just Shoot You He Can't Afford To Get Hurt I am concerned for the security of our great nation; not so much because of any threat from without, but because of the insidious forces working from within." -- General Douglas MacArthur
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