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Thread: ITAR Registration

  1. #16
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    Quote Originally Posted by pablo View Post
    Does the State Dept. have jurisdiction over this if the work isn't performed for export?
    Absolutely!

    §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.

    This does not apply to just metalwork, it applies to anything covered in the munitions list. http://www.pmddtc.state.gov/regulati...R_Part_121.pdf

    Take a look at page 2 CATEGORY I—FIREARMS, CLOSE ASSAULT WEAPONS AND COMBAT SHOTGUNS. Also take a look at section (h) Components, parts, accessories and attachments for the articles in paragraphs (a) through (g) of this category. It looks to me like it says if you are engaged in the business of making anything for a firearm you are subject to ITAR.

    This can include stocks. Are you in the business of making stocks for sale? You are subject to ITAR. A well known chassis maker has stated he was convinced by the govt that he should register.

  2. #17
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    Apr 2015
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    truly taxation without representation..as they are unelected.

    i am glad i am not in this business.

    ya know in the 90's when tax protestors were dispatcthing
    irs agents, the irs finally got the news, and revised their
    poor behavior.

    if you do not learn from history, you are bound to repeat it.

  3. #18
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    Quote Originally Posted by WSnyder View Post
    Absolutely!

    §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.

    This does not apply to just metalwork, it applies to anything covered in the munitions list. http://www.pmddtc.state.gov/regulati...R_Part_121.pdf

    Take a look at page 2 CATEGORY I—FIREARMS, CLOSE ASSAULT WEAPONS AND COMBAT SHOTGUNS. Also take a look at section (h) Components, parts, accessories and attachments for the articles in paragraphs (a) through (g) of this category. It looks to me like it says if you are engaged in the business of making anything for a firearm you are subject to ITAR

    This can include stocks. Are you in the business of making stocks for sale? You are subject to ITAR. A well known chassis maker has stated he was convinced by the govt that he should register.

    These documents keep referring to "DEFENCE ARTICLES and DEFENCE SERVICES. From what I've read a lot of ffl's are getting poor direction from the same guys who fan these fires.

    For you guys that are contacting some desk jockey about such regulation, my take is you're asking for answers in a way tat they will say yes you have to register.

    If you call and ask if you have a 07 license then you are gonna pay. Get rid of the 07 an just be a lowly gun smith.

    These postings and letters and poor advice are all ignoring the fact this only covers ITAR weapons that are to be used by militaries and sold to foreign governments, to arm their troops.

    The mill drill stock crown, ydaydayda, is worded as to include these procedures with regards to "DEFENCE ARTICLES and
    DEFENSE SERVICES"

    It appears that i you were to dump your 07 and back to 01, all this would away.

    If you currently have an 07 license, you should have known the ramifications you were going to be faced with.

    Realisticly, if you run a machine shop you do all those operations every day just as FN, Baret, Beretta, you are not obligated to register and pay. If you want to be a manufacturer of weapons, like them, and build and "Export Defence Articles and Services", ..you're going to pay. If you have an 07 or higher it's up to you to pay it, or get back down to reality
    Last edited by TRA; 08-02-2016 at 02:22 AM.

  4. #19
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    Apr 2015
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    Go read the new definition
    If you machine a bbl you need itar registration.
    Muzzle brake, chamber,anything other than scope mounting requires.
    Pure bs as it has nothing to do with export or defense.
    Strictly taxation

    Quote Originally Posted by TRA View Post
    These documents keep referring to "DEFENCE ARTICLES and DEFENCE SERVICES. From what I've read a lot of ffl's are getting poor direction from the same guys who fan these fires.

    For you guys that are contacting some desk jockey about such regulation, my take is you're asking for answers in a way tat they will say yes you have to register.

    If you call and ask if you have a 07 license then you are gonna pay. Get rid of the 07 an just be a lowly gun smith.

    These postings and letters and poor advice are all ignoring the fact this only covers ITAR weapons that are to be used by militaries and sold to foreign governments, to arm their troops.

    The mill drill stock crown, ydaydayda, is worded as to include these procedures with regards to "DEFENCE ARTICLES and
    DEFENSE SERVICES"

    It appears that i you were to dump your 07 and back to 01, all this would away.

    If you currently have an 07 license, you should have known the ramifications you were going to be faced with.

    Realisticly, if you run a machine shop you do all those operations every day just as FN, Baret, Beretta, you are not obligated to register and pay. If you want to be a manufacturer of weapons, like them, and build and "Export Defence Articles and Services", ..you're going to pay. If you have an 07 or higher it's up to you to pay it, or get back down to reality
    Last edited by CMaier; 08-02-2016 at 08:56 AM.

  5. #20
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    May 2010
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    Quote Originally Posted by WSnyder View Post
    Absolutely!

    §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.

    This does not apply to just metalwork, it applies to anything covered in the munitions list. http://www.pmddtc.state.gov/regulati...R_Part_121.pdf

    Take a look at page 2 CATEGORY I—FIREARMS, CLOSE ASSAULT WEAPONS AND COMBAT SHOTGUNS. Also take a look at section (h) Components, parts, accessories and attachments for the articles in paragraphs (a) through (g) of this category. It looks to me like it says if you are engaged in the business of making anything for a firearm you are subject to ITAR.

    This can include stocks. Are you in the business of making stocks for sale? You are subject to ITAR. A well known chassis maker has stated he was convinced by the govt that he should register.
    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. They have a limited and narrow jurisdiction. If you read the law and the highlighted parts about defense you can see that is what the law pertains too. Calling someone at the State Dept and asking them about it is stupid, if you communicate with them, it should be done in a very specific written manner by Certified US Mail. I bet their answers will be a whole lot different than any bs they shovel on the phone.

    If this came down from the ATF then we have a problem, the ATF has jurisdiction on what happens here.

  6. #21
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    Jul 2016
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    Colorado
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    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.
    Last edited by parshal; 08-02-2016 at 10:04 AM.

  7. #22
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    Aug 2005
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    835
    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.

  8. #23
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    Arizona
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    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.

  9. #24
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    Balto., MD
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    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?

  10. #25
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    Apr 2015
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    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.

    Quote Originally Posted by Rflshootr View Post
    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?

  11. #26
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    Hubert, NC
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    523
    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.

  12. #27
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    Feb 2005
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    Quote Originally Posted by WSnyder View Post
    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.
    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.

  13. #28
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    Apr 2015
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    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.

    Quote Originally Posted by TRA View Post
    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.

  14. #29
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    Jul 2005
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    599
    Quote Originally Posted by pablo View Post
    Does the State Dept. have jurisdiction over this if the work isn't performed for export?
    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.

  15. #30
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    you are ignoring the FACT that the current POTUS does not let the LAW getting in the way of his goals.

    Quote Originally Posted by pablo View Post
    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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