ITAR Registration

I'd like to think you're right but I'm pretty certain you're not. They consider all firearms defensive articles and, as such, they have jurisdiction whether it's exported or not. They are very clear about that.

I guess we'll just have to wait to see who they go after to make an example and hope it's not one of us. Whether they have jurisdiction or not you'll have spend money to defend yourself.

Oh, and to be clear, when I called them I asked if I were to install a new barrel for someone would I have to register with ITAR. They said if it were a "drop-in" part I would not. I said virtually all barrel installations require threading of the barrel. He said that would require registration. I don't think that question to be leading in any way. He was quite surprised that a type 1 FFL would allow someone to do that type of work.
 
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How much do you want to spend on lawyers and court costs to refute the particularly wide def. of mfg by the state dept? yes they are concerned with import export but the way this is written being as vague as possible leaves a whole lot of nastiness if some desk jocky gets his/her tail feathers all wadded up. Slide it in front of a non friendly court- OUCH.
Look at the excise taxes on sporting goods- somewhat recently revised- as to what constitutes mfg. from the same state dept. - note best be sitting down.
 
TRA, it matters not if you have an FFL of any kind the State Dept doesn't care. Now having an FFL may help lead the State Dept to your door. There are plenty of non-FFL holders that are registered and paying ITAR. If you are in the business to make parts or perform services listed in their declaration to any firearm covered in the munitions list you are likely subject to ITAR. If you call this fanning the flames or want to bury your head in the sand so be it.
 
I just wonder if a smith builds a rifle for someone, and leaves out one important thing, like a trigger let's say, or a firing pin assembly, it would not be a completed item. Kind of like the AR 80% receivers. Then a customer would just be paying for some machine time and not a finished product. It's a non working item at that point. What happens after that would be up to the owner. Would that negate having to pay the fee?
 
go read the words...
you machine on a bbl...you register and pay.
it has nothing to do with a completed gun, it includes making stocks only.
clearly an attempt to control the industry with an unfair tax.

Rflshootr said:
I just wonder if a smith builds a rifle for someone, and leaves out one important thing, like a trigger let's say, or a firing pin assembly, it would not be a completed item. Kind of like the AR 80% receivers. Then a customer would just be paying for some machine time and not a finished product. It's a non working item at that point. What happens after that would be up to the owner. Would that negate having to pay the fee?
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This close to a major election is a good time to make a case to your congressman and senators. They tend to be more responsive than usual. We can gripe to each other till the cows come home and nothing will change. A few good congressman might make a difference.
 
WSnyder said:
TRA, it matters not if you have an FFL of any kind the State Dept doesn't care. Now having an FFL may help lead the State Dept to your door. There are plenty of non-FFL holders that are registered and paying ITAR. If you are in the business to make parts or perform services listed in their declaration to any firearm covered in the munitions list you are likely subject to ITAR. If you call this fanning the flames or want to bury your head in the sand so be it.
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What makes you so sure you're correct? You are ignoring what the regulations actually say. Fact is you nor I, really know but I can comprehend what the scope of a regulation covers and this is not sporting firearms. No where does it say "ALL" nor "SPORTING" anywhere in that publication. Someone had a brain fade and now the sky is falling. Well it's not, and is not going to any time soon.

The sportsman have fought long and hard to keep black guns separate from assault rifles and now everyone wants it to be the same.
I'll bet this fizzles just as fast as surplus brass, green tipped ammo and every other crisis someone creates.

The state department has bigger fish to fry than to screw with every chip maker in the US.

With the upcoming coronation of our new king, this will just be old news come February.
 
go read the words.
firearm is not required for itar registration.
make a rifle stock
work on a bbl
you can mount a scope, but essentially any machine work on a gun part, that 'COULD" BE EXPORTED,
brings you under their 2000 dollar tax. if you are in "business"
two requirements:
be in business
and
any 'machine" work other than drill and tap for scope mounting.
machine work seem to include making stocks.

TRA said:
What makes you so sure you're correct? You are ignoring what the regulations actually say. Fact is you nor I, really know but I can comprehend what the scope of a regulation covers and this is not sporting firearms. No where does it say "ALL" nor "SPORTING" anywhere in that publication. Someone had a brain fade and now the sky is falling. Well it's not, and is not going to any time soon.

The sportsman have fought long and hard to keep black guns separate from assault rifles and now everyone wants it to be the same.
I'll bet this fizzles just as fast as surplus brass, green tipped ammo and every other crisis someone creates.

The state department has bigger fish to fry than to screw with every chip maker in the US.

With the upcoming coronation of our new king, this will just be old news come February.
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pablo said:
Does the State Dept. have jurisdiction over this if the work isn't performed for export?
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They do for plenty of other things on the Defense Munitions List.

Exporting anything on that list including technical information (drawings & methods) gets really touchy really fast.

We had a contract once from a British company to help them test some parts intended for eventual satellite use.

We could advise them on HOW to conduct the test.
We could not comment in any way on how to analyze the results of the test.

DoS actually sent a contractor to 'observe' the testing at Indiana State University's Cyclotron and make sure we did not say anything.
 
you are ignoring the FACT that the current POTUS does not let the LAW getting in the way of his goals.

pablo said:
The point of my post was to point out that if it doesn't involve import or export the State Dept has no say in it.
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