Registration with DDTC and payment of $2250 reg. fee!!

[Tyke8319]

[edgerly779]

Very scary as a hobbyist

[snypr]

any more to this?

[Librarian]

https://www.pmddtc.state.gov/ seems to show no change from the July 'guidance', quoted in the OP.

[Tyke8319]

I have submitted the below question to ITAR.
_________________________________________________

Applicability of the ITAR Registration Requirement to Firearms Manufacturers and Gunsmiths, dated July 22, 2016

Question:

Is the (above) ITAR Registration Requirement presently in effect and does (or will) it impact “gunsmiths” , as defined who are within the United States and if so are those who fall under such definition subject to the $2,250 registration fee?

Thank you...
__________________________________________________ ____

I will post any response it receive.

[kendog4570]

Why give this crap any credibility at all? This BS is very much like the California Air Resources board. A bureaucracy with no way of enforcing it's decisions, unless of course a gullible public buys in hook line and sinker and willingly complies with every crackpot scheme they can come up with, or strong-arm various jurisdictions into implementing this stuff. Make THEM prove it.
Have you ever received a CARB "ticket" for having a smoking vehicle? I have, when the ol 6.9 Ford was out of tune. I wadded it up and threw it away. They never enforced it. They 1) don't have the enforcement arm, and 2) dont have the money to enforce it, and 3) they have no legal right or status to enforce it. If I would have reported myself to a referee I would still be jumping through hoops to satisfy them.
Another time I was getting a building permit for a project at my old house in Aptos. The county came at me with a document that they said I have to sign, that would give "Dept of Fish and Game, and/or any other Law Enforcement Agency" the right to trespass on my property to look for "Endangered Species", and it will be recorded on my deed In Perpetuity. That means whoever owns it in the future will be giving the same permission to trespass. I asked "what if I dont want to sign it?" They replied "You have to sign it, its the law", and "if you don't, you will never get a final on your permit". I was about to sign it when my wife told them "if it is a LAW then you dont need our signature". I didn't sign it, it is not recorded on my deed, and I got a final on my project. And I took my wife out to dinner because she is awesome.
Granted, this one is a little more onerous because it deals with guns.
If this becomes a LAW, then I will consider my options. Until then, they can piss up a rope.

[weaselfire]

Keep in mind, if you have no FFL, it doesn't apply to you. Currently, if you perform any manufacturing as defined, you need to register. NRA, NSSF and others are pushing to negate all ITAR issues by moving it to Commerce instead of State.

Jeff

Sent from my XT1254 using Tapatalk

[Tyke8319]

ITAR's reply....

Mr. XXXX:
I don’t know how much you know about DDTC – we are the Directorate of Defense Trade Controls, part of the US Department of State, and we are responsible for regulating the export of defense and space products – which includes firearms but a lot of other industries as well. Our regulatory authority is based on the ITAR regulations. Those regulations require any company that is manufacturing an ITAR-controlled product – whether it be an air-to-air missile or a handgun -- to register with our Directorate. This registration requirement applies to companies whether they have any export business or not.



The guidance we issued on July 22 (on our web site, at

http://pmddtc.state.gov/compliance/d...ufacturers.pdf)

was intended to help FFL holders understand what constitutes manufacturing as regards the firearms industry. It’s a consolidation of existing policy guidance and is intended to aid companies in making registration determinations. It’s already in effect in the sense that it is existing policy guidance.



If you are engaged in the business of conducting activities clearly described in the guidance as ones that DDTC has previously determined to constitute manufacturing, then it is likely that you are required to register with DDTC.



For more on the registration requirement, and guidance on how to register, please see our web site at http://pmddtc.state.gov/registration/index.html



John Hall
PM Response Team


Note: Information in this message generally discusses controls and information contained in the Arms Export Control Act and the International Traffic in Arms Regulations (ITAR), both of which are authoritative on this matter. The Response Team fields basic process and status questions, and assists exporters in identifying how to get answers to more complex questions handled by the Directorate of Defense Trade Control’s licensing and compliance offices. The Response Team’s services are not a substitute or replacement for the advisory opinion, general correspondence, and commodity jurisdiction processes delineated in the ITAR, which should be used to obtain authoritative guidance on export control issues, and do not in any way relieve exporters from their responsibilities to comply fully with the law and regulations.





This email is UNCLASSIFIED.

[Tyke8319]

Further....

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) Re-chambering firearms through machining, cutting, or drilling;
g) Chambering, cutting, or threading barrel blanks; and
h) Blueprinting firearms by machining the barrel.

[Tyke8319]

FFL Licensing Requirements (Dealer/Manufacturer/Importer/Exporter):

10. At what point should I obtain a Federal firearms license (FFL)? How do I obtain a FFL?

[HardwoodRods]

The best part is I had to register and at that time pay 2000 per year, but couldn't ship anything out of CONUS, even though I was being charged as if I was. It is just another attempt to shut down the firearms industry. And for the poster above, yes they enforce this. It's the Feds and they have the largest collection agency in the world at their disposal.

[Tyke8319]

I'm not for a minute suggesting what others do or what laws, policies or procedures they follow. I'm merely reporting what has come to my attention and given the nature of that which I have posted coupled with some rather extensive research I've dome on the subject it is my opinion that when, if ever, this "policy" becomes enforced (most likely by ATF when applying for FFL renewal) I'll be put out of business by the mere fact that the gunsmithing work I do fall clearly within the guidelines as listed below:

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 break 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.

ALL OF WHICH is exactly what most "gunsmiths" are engaged in.

[kendog4570]

There are already Federal codes defining what a dealer and a manufacturer are. So these guys get to come along and make up some regs and we all have to just suck it up?

This ain't over with...

https://www.nraila.org/articles/20160930/legislation-introduced-to-protect-american-gunsmiths-from-reckless-state-department-guidance

[Tyke8319]

I would all FFL gunsmiths to go to the below web site and read the NRA-ILA letter to the State Dept. At the bottom you will find "click here" which will lead to a site that allows you to contact your respective Congress-person and r Urge Your Legislators to Support the Export Control Reform Act of 2016!

https://www.nraila.org/articles/2016...tment-guidance

[dvs762]

as an 07 this concerns me greatly but at this time I dont do anything that triggers this fee on me but I have been told that many non FFL's who do barrel work have quit doing work because of this ruling.