High Cap Mag Permit without FFL?

[echoarms]

Hi, is it possible to get a high cap mag permit without a FFL? I have the application and see that they ask for your cal DOJ dealer listing number. I have a friend who has the accessory sales contracted for a large name gun manufacturer and part of what he wants to sell is the mags in addition to the shirts, hats, mugs, etc. Will he need an FFL? Can I use my FFL/mag permit to be the responsible person?

[Librarian]

Doesn't look like it.

PC 32315:

32315. Upon a showing that good cause exists, the Department of
Justice may issue permits for the possession, transportation, or sale
between a person licensed pursuant to Sections 26700 to 26915,
inclusive, and an out-of-state client, of large-capacity magazines.

and 26700 is

26700. As used in this division, and in any other provision listed
in Section 16580, "dealer," "licensee," or "person licensed pursuant
to Sections 26700 to 26915, inclusive" means a person who satisfies
all of the following requirements:
(a) Has a valid federal firearms license.
(b) Has any regulatory or business license, or licenses, required
by local government.
(c) Has a valid seller's permit issued by the State Board of
Equalization.
(d) Has a certificate of eligibility issued by the Department of
Justice pursuant to Section 26710.
(e) Has a license issued in the format prescribed by subdivision
(c) of Section 26705.
(f) Is among those recorded in the centralized list specified in
Section 26715.