New Executive Order that will impact the shooting sports

[Mike Hunter]

All, some very disturbing information, which will affect all in the shooting sports.

U.S. State Department’s Directorate of Defense Trade Controls (DDTC), which is primarily responsible for administering the Arms Export Control Act (AECA) and its implementing rules, the International Traffic in Arms Regulations (ITAR). The upshot is that DDTC is labeling gunsmiths as “manufacturers” for performing relatively simple work such as threading a barrel or fabricating a small custom part for an older firearm. Under the AECA, “manufacturers” are required to register with DDTC at significant expense or risk onerous criminal Penalties:
http://pmddtc.state.gov/compliance/Appl ... blish).pdf

2. Registration Required – Manufacturing: In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is required because the following activities meet the ordinary, contemporary, common meaning of “manufacturing” and, therefore, constitute “manufacturing” for ITAR purposes:

a) Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms;

b) Modifications to a firearm that change round capacity;

c) The production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors);

d) The systemized production of ammunition, including the automated loading or reloading of ammunition;

e) The machining or cutting of firearms, e.g., threading of muzzles or muzzle brake installation requiring machining, that results in an enhanced capability;

f) Rechambering firearms through machining, cutting, or drilling;

g) Chambering, cutting, or threading barrel blanks; and

h) Blueprinting firearms by machining the barrel.

So, if you own a lathe or milling machine would that be ” Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms” What about Brownells magnabit screwdrivers?

If you convert a bolt action rifle that holds 5 rounds to be a single shot, or convert a shotgun to only hold 3 rounds, you are now a manufacturer. (See b.) They don’t state increase round capacity, only change round capacity.

If you make a stock for a custom rifle or make one for that Parker, you are now a manufacturer, make a set of double set triggers, new barrel for a custom single shot…. You are now a manufacturer (See c.)

Buying a pre threaded/ pre chambered barrel for custom installation, as soon as you touch a lathe bit to that barrel to get correct headspace you are a manufacturer (see e. & h)
And god help you if you actually thread and chamber a barrel, you are definitely a manufacturer (see e. f. g. & h)

Do you reload? “ d. The systemized production of ammunition,” all reloading by definition is systemized (to arrange in or according to a system; reduce to a system; make systematic), guess what reloaders, you are now a manufacturer. There is no distinction between personal or commercial use, and no definition on quantity. So if you produce one round in a systematic manner you are a manufacturer.

If you look at Category I (j)(1) of the United States Munitions List (USML) (22 CFR § 121.1) there is no exemption for sporting arms, or antique arms:
121.1 General. The United States Munitions
List.
1.
(j) The following interpretations explain and amplify the terms used in this category and throughout this subchapter:
(1) A firearm is a weapon not over .50 caliber (12.7 mm) which is designed to expel a
projectile by the action of an explosive or which may be readily converted to do so.

Might want to contact your representatives.... that's what they are there for

[Chuck 100 yd]

That just about covers everything we do, yes /no ?
Those jerks have to much power,or at least they think they do. We need to clean house.

[JerryB]

Thank you Mike, that just about covers al that we do as reloaders, plus what we have done by our local gunsmiths.

[Blaine]

Setting the stage for the new SCOTUS appointment.

[Mike Hunter]

All
Appreciate the comments, but I recommend to all that you contact your representatives (Senators/Congress), it takes 5 minutes and you can do it online.
Bottom line is that the guidance published on 22 July 16 is so broad, that it has the potential to put a lot of gunsmiths out of business.

Think about this for a minute:

Your gunsmith now has to apply for a 07 Manufacturing License from the ATF, and all the reporting requirements associated with that license.

In addition they now must register with the Department of State, Directorate of Defense Trade Controls (DDTC), pay a $2200 annual fee and a whole new set of reporting requirements.
So, to fit a new barrel, stock, cylinder trigger etc., or to blueprint your action your gunsmith must register with ITAR and do all the above.

That’s’ a lot to ask of your gunsmith.

For reloaders: “d. The systemized production of ammunition, including the automated loading or reloading of ammunition.”

Now, there are NO stipulations stating reloading for personal use is ok, NO stipulations on round count. Bottom line is if you currently reload you are probably in violation of the ITAR as currently written. Are you ready to go get your 07 manufacturing license and pay $2200?

[gundownunder]

The systemized production of ammunition, including the automated loading or reloading of ammunition.

I think they'd be stretching it to call a hand operated reloading press either systemized, or automated.
Even a full progressive press is still a hand operated tool.

[ole pizen slinger]

Question? Is this a result of the arms treaty that was signed by Kerry?

[Chuck 100 yd]

I wonder just how many gangbangers reload their own ammo or have custom work done to their guns?
Obviously this is aimed at you and me. They don't care stuff about stoping the bad guys, only preventing us from having/using our firearms for what the 2nd. was written for.
Wee the SHEEPLE ........

[handirifle]

Gun control has and never will be about stopping or reducing crime or criminals, it's about control, of us.

Next there will be an EO on USING firearms, or running a shooting range. There is no end to where these people will go, and we MUST defeat them in November, if not WE are the defeated.

I have heard sooo many times that the stuff that Hitler did could never happen in America. Well it's happening now. This Adolf just has to go about it slightly different, for now.

[AJMD429]

The systemized production of ammunition, including the automated loading or reloading of ammunition.

I think they'd be stretching it to call a hand operated reloading press either systemized, or automated.
Even a full progressive press is still a hand operated tool.

Oh, they'll have no problem "stretching" the law - they always do...

Obviously this is aimed at you and me. They don't care stuff about stopping the bad guys, only preventing us from having/using our firearms for what the 2nd. was written for.

Yep. That's because the 'bad guys' only threaten the citizenry, whereas a "well-armed militia" is a threat to tyrants*, and so tyrants are more interested in legislating against lawful gun ownership than actual violent crime.

*Note that such a militia is NOT a threat to a Constitutional and legitimate government; therefore one way to spot a tyrant versus a legitimate politician is their stance on 'gun control'.

[1894cfan]

GUYS, I THINK IT'S TIME TO TAKE ANOTHER LOOK AT THE DECLARATION OF INDEPENDENCE! And while you're at it, take a look at the Articles of Confederation.

[FWiedner]

I think it's time to stop asking for permission to be free, and just do it.

[Blaine]

Quick Question: If this is about ITAR, isn't that all about import/export, and not with our hobbies?

[J Miller]

I've seen so much b.s. and scare tactics come from this administration that I'm waiting for the GOA to email me about it. They're usually Johnny On The Spot with things like this. I haven't heard from them yet.
Just a couple weeks ago my wife read an article where obummer said he was going to stop the SS payments and we wouldn't get them this month. Well they came. I've taken a wait and see attitude about anything that comes from him.

I think it's time to stop asking for permission to be free, and just do it.

I'm in total agreement with you about this.


Joe

[Mike Hunter]

Joe

I talked with GOA yesterday, they didn't know anything about it. This info was released in a nondescript memo on 22 July 16, no fan fare, no news coverage, just some B.S. memo "clarifying" existing rules, BUT with far reaching impacts.

I didn't know about it until a customer brought it to my attention.

Here's a little more on it:

https://www.gunsamerica.com/blog/new-it ... n-control/

http://www.thetruthaboutguns.com/2016/0 ... -business/

[J Miller]

I hoped that Bush II would reverse the illegal things clinton did, but he just added to them.

Should I hope that the next POTUS will have the guts to do what is needed and reverse obummers wrong doings, or should I realize that my country is in it's last days as a free country?

There comes a time that hope and optimism has to be laid aside and the realization that it's time to take other forms of action accepted.

The more I've contacted the congressional parasites the worse this has gotten. I really doubt writing letters, calling, or emailing will do or does any good.

As a matter of fact I think it gives the enemy more knowledge of us because we have to give them our address and phone number when we contact them. They know where we are.
Just look at all the Naturopathic Doctors or those that oppose the hildabeast that are coming up dead. Think that's any form of coincidence? Gibbs doesn't believe in coincidences and neither do I.

I'm too old to quit, but I think the end is nigh. I'm convinced the prediction I made back when the GCA 68 was signed into law; that we would see the end of this country before I die, will come true.

Sorry for the negativity, just the way I feel.

Joe

[mohavesam]

I posted over on the rugerforum.com.
I served as ITAR Administrator for years with a major manufacturer. ITAR regs are US Code under military procurement. Only a manufacturer selling directly to a military contract is ever going to be affected. Civilian police cannot use ITAR regs for a warrant nor do they have powers of arrest for ITAR regs.

Put away the tinfoil hats friends.

[AJMD429]

This from the dot-gov themselves....I underlined the parts that gave me the creeps:

This may "only" apply to military/defense manufacturers in intent, but the wording is so unclear that it would be easy for our current snakes-in-public-office to make it apply to everyone.

The mere fact that the law considers things like threading a muzzle or installing improved sights, or for that matter doing anything that 'improves' the firearm, to be MORE than 'ordinary gunsmithing' is very creepy indeed.

What do they consider 'ordinary gusmithing' then...??? Just polishing off nicks and replacing loose screws...???

I would like to see concrete assurance that this in no way affects any manufacturer or gunsmith who isn't engaged in international business, and I don't see that in the wording.

United States Department of State Bureau of Political-Military Affairs Directorate of Defense Trade Controls Washington, D.C. 20520-0112 July 22, 2016

Applicability of the ITAR Registration Requirement to Firearms Manufacturers and Gunsmiths

Summary:

The Directorate of Defense Trade Controls (DDTC) has reviewed and consolidated policy guidance about whether various activities related to firearms constitute manufacturing for International Traffic in Arms Regulations (ITAR) (22 CFR Parts 120-130) purposes and require registration with DDTC and payment of a registration fee. DDTC has found that many – but not all - traditional gunsmithing activities do not constitute manufacturing for ITAR purposes and, therefore, do not require registration with DDTC. The following guidance is confined to DDTC’s ITAR implementation. You must also comply with all other relevant laws.

Background:

The Arms Export Control Act (AECA) (22 U.S.C. § 2751 et seq.) and the Gun Control Act (GCA) (18 U.S.C. § 921 et seq.) are two distinct U.S. laws that concern manufacturing of firearms. The GCA requires firearm manufacturers to obtain licenses as manufacturers (known as Federal Firearms Licenses (FFLs)) from the Department of Justice’s Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The AECA, in relevant part, requires manufacturers of defense articles, including certain firearms, to register with the Department of State, Directorate of Defense Trade Controls. Because the GCA is intended to cover a broader scope of domestic activity than the AECA, the ATF regulations define the term “firearm” more broadly than the ITAR. As a result, not every firearm controlled by the ATF regulations is also controlled by the ITAR.

The AECA’s statutory requirement for firearms manufacturers to register with DDTC is implemented in Part 122 of the ITAR:§122.1 Registration requirements.

(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.

ITAR Registration Requirements – Consolidated Guidance July 22, 2016 Firearms Manufacturers and Gunsmiths

ITAR registration is required of persons who engage in the business of manufacturing defense articles. Persons who do not actually manufacture ITAR-controlled firearms (including by engaging in the activities described below, which DDTC has found in specific cases to constitute manufacturing) need not register with DDTC – even if they have an FFL from ATF. As indicated above, the requirements for obtaining FFLs under the GCA are separate and distinct from the requirement under the AECA and ITAR to register with DDTC.

The term “manufacturing” is not defined in the ITAR. In order to determine whether a firearms- related activity constitutes manufacturing for ITAR purposes, DDTC applies the ordinary, contemporary, common meaning of the term. Likewise, DDTC applies the ordinary, contemporary, common meaning for “gunsmithing,” which traditionally has broadly included designing, making, or repairing guns. Not all firearms (as defined by ATF regulation) are “defense articles” under the ITAR, however, and not all activities involving assembly of and repairs to firearms qualify as manufacturing for ITAR purposes. DDTC has found that many traditional gunsmithing activities do not constitute manufacturing for ITAR purposes and, therefore, do not require registration under the ITAR, particularly where such activities do not require cutting, drilling, or machining and do not improve the accuracy, caliber, or operation of the ITAR-controlled firearm beyond its original capabilities.

Policy Guidance:

The guidance below is limited to domestic (U.S.) activities involving firearms (as defined in Category I(j)(1) of the United States Munitions List (USML) (22 CFR § 121.1)) and related ammunition that are .50 caliber (12.7 mm) or smaller - i.e., firearms in Category I, paragraphs (a) and (b), related items in paragraphs (e)-(h), and ammunition in Category III(a) for those firearms. Activities involving items elsewhere on the USML, including Category I, paragraphs (c) and (d), are not included in the scope of this guidance.

1. Registration not Required – Not Manufacturing:

In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is not required because the following activities do not meet the ordinary, contemporary, common meaning of “manufacturing” that DDTC employs in implementing the ITAR and, therefore, do not constitute “manufacturing” for ITAR purposes:

• a) Occasional assembly of firearm parts and kits that do not require cutting, drilling, or machining;
  
  b) Firearm repairs involving one-for-one drop-in replacement parts that do not require any cutting, drilling, or machining for installation;
  
  c) Repairs involving replacement parts that do not improve the accuracy, caliber, or other aspects of firearm operation;
  
  d) Hydrographic paint or Cerakote application or bluing treatments for a firearm;
  
  e) Attachment of accessories to a completed firearm without drilling, cutting, or machining—such as attaching a scope, sling, or light to existing mounts or hooks, or attaching a flash suppressor, sound suppressor, muzzle brake, or similar item to a pre- threaded muzzle;
  
  f) Cosmetic additions and alterations (including engraving) that do not improve the accuracy, caliber, or other aspects of firearm operation beyond its original capabilities;
  
  g) Machining new dovetails or drilling and tapping new holes for the installation of sights which do not improve the accuracy or operation of the firearm beyond its original capabilities; and
  
  
  h) Manual loading or reloading of ammunition of .50 caliber or smaller.
  
  Activities limited to the domestic sale or resale of firearms, the occasional assembly of firearms without drilling, cutting, or machining, and/or specific gunsmithing activities that do not improve the accuracy, caliber, or operations of the firearm beyond its original capabilities (as described above) are not manufacturing within the context of the ITAR. If you are not manufacturing, exporting, temporarily importing OR brokering defense articles or services, you are not required to register with DDTC.
  [that "or" means 'manufacturing, without necessarily 'exporting, temporarily importing, or brokering', would be included, and we see their definition of 'manufacturing' basically includes anything that 'improves' a firearm, or requires drilling or machining...]

2. Registration Required – Manufacturing:

In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is required because the following activities meet the ordinary, contemporary, common meaning of “manufacturing” and, therefore, constitute “manufacturing” for ITAR purposes:

• a) Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms;
  
  b) Modifications to a firearm that change round capacity;
  
  c) The production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors); [this would include making a spring or screw]
  
  d) The systemized production of ammunition, including the automated loading or reloading of ammunition;
  [is my Dillon 'automated', or not...and who gets to decide...?]
  
  e) The machining or cutting of firearms, e.g., threading of muzzles or muzzle brake installation requiring machining, that results in an enhanced capability;
  
  f) Rechambering firearms through machining, cutting, or drilling;
  
  g) Chambering, cutting, or threading barrel blanks; and
  
  h) Blueprinting firearms by machining the barrel.

3. Registration Required – Other than Manufacturing:

• a) Assisting foreign persons in the design, development, and repair of firearms may constitute the export of a defense service (see 22 CFR § 120.9) and require ITAR registration with and authorization from DDTC; and
  
  b) Exporting a firearm or any other item on the USML requires ITAR registration with and authorization from DDTC.

If, after careful review of this guidance, you are unsure as to whether you are required to register with DDTC, you may submit an advisory opinion request (see 22 CFR § 126.9) detailing exactly what you do or intend to do with regard to firearms and ammunition. This request should be sent in hard copy (services like UPS or FedEx recommended for faster delivery) as indicated on our website: http://pmddtc.state.gov/about/contact_information.html.

If you have any general follow-on questions, please feel free to contact the Response Team at (202) 663-1282 or DDTCResponseTeam@state.gov.

"These requirements apply, even if the business does not, and does not intend to, export any defense article."

See https://www.nraila.org/articles/2016072 ... un-control for the full text.

I'm still not reassured.... I'd feel better if the local FFL's and gunsmiths I knew had been told by the ATF (preferably in writing) that they really would not be affected by these rules, (...at least until the welfare mooches, wealthy leftists, news media, and never-Trump crowd succeeds in getting Hillary elected... )

I guess I'll find out soon, as I have a couple barrels I need threaded.

[Mike Hunter]

Don't look to the ATF for the answer, it's not their regulation, and they could give a rat's behind, this is coming from the State Department.

[1894cfan]

I think it's time to stop asking for permission to be free, and just do it.

Are you willing to live by that statement? My take on being free is... no SSN, no DL, no vehicle registration, no Social Security, no property tax, no voter registration as we know it today, no Govt. healthcare and no insurance! EVERYTHING you earn is yours, EVERYTHING you buy is yours! And YOU are responsible for your actions and your life.
Scary isn't it?

[J Miller]

I think it's time to stop asking for permission to be free, and just do it.

Are you willing to live by that statement? My take on being free is... no SSN, no DL, no vehicle registration, no Social Security, no property tax, no voter registration as we know it today, no Govt. healthcare and no insurance! EVERYTHING you earn is yours, EVERYTHING you buy is yours! And YOU are responsible for your actions and your life.
Scary isn't it?

The part I find scary is the transition from how it is, to that form of life. What you described is how it should be. That unto itself is not scary. Cutting the govs tentacles from every factor of our lives and their taking offense to that ... is scary.

Joe

[Blaine]

I think it's time to stop asking for permission to be free, and just do it.

Are you willing to live by that statement? My take on being free is... no SSN, no DL, no vehicle registration, no Social Security, no property tax, no voter registration as we know it today, no Govt. healthcare and no insurance! EVERYTHING you earn is yours, EVERYTHING you buy is yours! And YOU are responsible for your actions and your life.
Scary isn't it?

So, you want to take civilization back to the stone age?

[Griff]

Since some of these regulations have been in place since 1993, has anyone outside of the military/industrial arena been fined, indicted or somehow forced into registration? Yep, if you're doin' work on EBRs, then maybe you need to read a little closer... but my take is also:

Put away the tinfoil hats friends.

[1894cfan]

I think it's time to stop asking for permission to be free, and just do it.

Are you willing to live by that statement? My take on being free is... no SSN, no DL, no vehicle registration, no Social Security, no property tax, no voter registration as we know it today, no Govt. healthcare and no insurance! EVERYTHING you earn is yours, EVERYTHING you buy is yours! And YOU are responsible for your actions and your life.
Scary isn't it?

So, you want to take civilization back to the stone age?

Nope, just want to get govt. out of our lives!!!!!!!!!!!!!!!!!!!!!!!

[Blaine]

I think it's time to stop asking for permission to be free, and just do it.

Are you willing to live by that statement? My take on being free is... no SSN, no DL, no vehicle registration, no Social Security, no property tax, no voter registration as we know it today, no Govt. healthcare and no insurance! EVERYTHING you earn is yours, EVERYTHING you buy is yours! And YOU are responsible for your actions and your life.
Scary isn't it?

So, you want to take civilization back to the stone age?

Nope, just want to get govt. out of our lives!!!!!!!!!!!!!!!!!!!!!!!

IMO, your original statement is throwing out the baby with the bathwater. Heck, go try it out. Walk out into the wilderness, take whatever you can carry, and just do it. But, when you think about it, I'll bet your pretty happy in your situation. Nice house with electricity, a road of some sort to get around. Indoor plumbing. Kudos if you chop your own wood, or hump a coal hod, but I doubt it.
Now, if you want to talk about unnecessary gubment regulation, and all the local, state, and federal taxes, I'm on your side. Gubment has ruined healthcare. Gubment has ruined DoD. Gubment should stick to what the constitution sez it can do and leave the rest to the states. But, let's fact it, states will still have a gubment that the people will allow to be in place. Doing away with LBJ's Great Society would be a fantastic start.

[AJMD429]

So, you want to take civilization back to the stone age?

No.....but I'd settle for about 110 years ago, in terms of 'government'...

[Blaine]

So, you want to take civilization back to the stone age?

No.....but I'd settle for about 110 years ago, in terms of 'government'...

Agreed, to a certain extent. As a teenager, when Uncle Sam pushed thru the 5 MPH Bumpers as law, I knew we were eventually doomed.
The key (and impossible dream) will be to bust up the urban poverty plantations. Some assistance while they obtain new factory jobs that MUST be brought back to the USA. Fifteen bucks an hour making ties, pants, shoes, dresses etc, and a bunch of personal tax breaks will go a long way.

[JerryB]

I saw a piece about on this on the news this morning, it is real.

[1894cfan]

Are you willing to live by that statement? My take on being free is... no SSN, no DL, no vehicle registration, no Social Security, no property tax, no voter registration as we know it today, no Govt. healthcare and no insurance! EVERYTHING you earn is yours, EVERYTHING you buy is yours! And YOU are responsible for your actions and your life.
Scary isn't it?[/quote]

So, you want to take civilization back to the stone age? [/quote]

Nope, just want to get govt. out of our lives!!!!!!!!!!!!!!!!!!!!!!![/quote]


Now, if you want to talk about unnecessary gubment regulation, and all the local, state, and federal taxes, I'm on your side. Gubment has ruined healthcare. Gubment has ruined DoD. Gubment should stick to what the constitution sez it can do and leave the rest to the states. But, let's fact it, states will still have a gubment that the people will allow to be in place. Doing away with LBJ's Great Society would be a fantastic start.[/quote]

That's what I was referring to, LOVE to have government regulation out of my life!
BTW, and I've mentioned this before, there is the United States of America and there is the United States, two different entities! I'd much rather live in the United States of America, but good luck to that! Most everybody lives in the United States, with all the government regulation that entails (which is what we have today)! Same two State governments, there is the "state" (name of state, in my case, California, as established by the Articles of Confederation) and there is The State of (again in my case, The State of California, as established by the United States Constitution). Check out both of those documents, there is a difference there. And yes, the Articles of Confederation is still valid!

organiclaws.org/unlimited-self-government/

[mohavesam]

ITAR regulations (military procurement code) are defined in the "Buy American Act" (the act which authorizes ITAR regs) as applicable to sales to the US Government and Military procurement under the Arms Export Control Act (AECA), and are described in Title 22 (Foreign Relations). Not applicable to civilians NOT selling services/goods to the military.
Cannot be used for warrant purposes, and enforcement is limited to US Military and overseas authorities for MIL purposes.

If your gunsmith sells directly to the US military, then yes, they may be affected. That is their business.

I was an ITAR Administrator for more than five years. I only know what the US Dept of State taught me...

Consider the sources...

[AJMD429]

I believe you, mohavesam, but I've seen so many times the feds ignore what the law says and turn it upside down, that I understand the fear this new policy will be misused.

Hopefully the anti-gun Demoncraps will be defeated in 90 days....

[Mike Hunter]

Mohavesam

Understand that you were an ITAR Administrator for a while, BUT…. This new “Guidance” changes many things. 1. If you can be considered a manufacturer as redefined by the DDTC you must register, even if you have no intent on exporting, or working on Defense Materials. 2. You are now redefined as a “Manufacturer” after only one occasion of “Manufacturing”.

So, a gunsmith that relines little Bobbie’s squirrel rifle is now a “Manufacturer” and is required to register with ITAR and pay a $2250 yearly registration fee.

Part 122 of the ITAR:

§122.1 Registration requirements.
…. 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.

“A manufacturer who does not engage in exporting must nevertheless register.”

2. Registration Required – Manufacturing: In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is required because the following activities meet the ordinary, contemporary, common meaning of “manufacturing” and, therefore, constitute “manufacturing” for ITAR purposes:

a) Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms;
b) Modifications to a firearm that change round capacity;
c) The production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors);
d) The systemized production of ammunition, including the automated loading or reloading of ammunition;
e) The machining or cutting of firearms, e.g., threading of muzzles or muzzle brake installation requiring machining, that results in an enhanced capability;
f) Rechambering firearms through machining, cutting, or drilling;
g) Chambering, cutting, or threading barrel blanks; and
h) Blueprinting firearms by machining the barrel.

[Malamute]

Mike, I saw something elsewhere discussing this topic, it was mentioned that IF a gunsmith made a part to sell, on their own initiative, it was manufacturing. IF the part was made/modified at the customers request, such as bringing a gun in for work, not made beforehand, it wasnt considered manufacturing. Do you know anything about that? I cant recall where I saw it, I'll see if i can find it and report the source.

Edit: found it.

Post No 8. The link is http://bulletin.accurateshooter.com/201 ... g-license/


Its based on ATF definitions, so may or may not be applicable in the case of DOS.

[flatnose]

The last time I read up on ITAR, a couple of years ago, I would have agreed with sam. If you were not exporting or selling to the military or police I think, there was no need to register for ITAR.
I was reading a post from a cast bullet manufacturer, and it seems he was told even back then that he was required to be ITAR registered. If you asked different people, you got different answers or interpretations of the regs.
Its sad that it has come to this, but for the sake of $2250 , one maybe better of paying it than running the risk of tangling with the government.
It appears that ITAR has now been expanded.
There is also the possibility that some information that is shared on the internet and forums, may come under ITAR restrictions and ruling. That would be the sharing and making available, ie exporting, of information with other countries.
This is the problem with legislators..............they legislate. Its their job.
As a side note, Here in california, we average about 1,000 new laws per year. I have been here 30 years. Approx 30,000 laws passed.
How many new laws per year in your state?

[FWiedner]

This is the problem with legislators..............they legislate. Its their job.

Therein lay the crime.

This is not legislation.

This is dictat.

[AJMD429]

Lawyer speaks on ITAR - https://blog.princelaw.com/2016/07/25/d ... istration/

I think the guy (Adam Kraut) is running for NRA board, so he is at least pro-gun, and an attorney.

Video Version https://www.youtube.com/watch?v=GTAHEYFu8mY

[Griff]

Lawyer speaks on ITAR - https://blog.princelaw.com/2016/07/25/d ... istration/
I think the guy (Adam Kraut) is running for NRA board, so he is at least pro-gun, and an attorney.
Video Version https://www.youtube.com/watch?v=GTAHEYFu8mY

Well, that clears things up to the level of mud...