07's and ITAR....

[zfields]

So we are applying for our FFL, and trying to decide between keeping it as an 01, or going with an 07. I see a lot of conflicting information and interpretations regarding 07's having to register with ITAR.


Has anything changed or clarified on this?

[lugnutwrench]

So we are applying for our FFL, and trying to decide between keeping it as an 01, or going with an 07. I see a lot of conflicting information and interpretations regarding 07's having to register with ITAR.

Has anything changed or clarified on this?

We're looking into this as well. It's my understanding that before an FFL actually completes manufacture of any firearm, it either needs to be registered with the DDTC ($2,250 annually), or it needs to apply for and receive a Commodity Jurisdiction exemption for each model it intends to manufacture. These are helpful:

• http://www.calguns.net/calgunforum/s...d.php?t=871063
• http://www.silencertalk.com/forum/vi...hp?f=4&t=45696
• http://www.ar15.com/forums/t_6_44/35....html%26page=5
• http://www.pmddtc.state.gov/commodit...ion/index.html

Allegedly, the DDTC has gotten hold of the ATF's list of 07s and is using it to contact them individually. Contrary to what they say, as far as I can tell, an 07 who hasn't manufactured anything doesn't need to register. However, as soon as you assemble your first complete AR for sale, you're probably a manufacturer as far as the DDTC is concerned, so you'll likely want to have your ducks in a row before pushing in that second takedown pin and offering it for sale (irrespective of whether anyone buys it)....

If you're not already a member, you might find additional help here. Apparently, many FFLs tend to be fairly tight-lipped about this stuff (they consider a lot of it to be "trade secrets", or they don't want to be held responsible for providing legal advice without a license, etc.). We're not very far along (we haven't even locked down what models we want to assemble, much less sell), but we're happy to compare notes and share experiences. Feel free to PM me, and we can keep in touch.

[zfields]

Pretty much the dame info I have seen also. Thanks.

sent from my damn tappy device...

[Bigmanjay3]

I called them they said as long as you aren't machining anything you dont need to register

[PolishMike]

Be careful with that. Last time I talked to my ATF guy he said every 07 in his region is now being forced to be registered and must show proof on audit

[lugnutwrench]

I called them they said as long as you aren't machining anything you dont need to register

Called who? The ATF or the DDTC? Who did you speak to? Did you get a response in writing?

The ATF and the DDTC are separate agencies, each with their own definitions of "manufacturing" and each with their own policies and regulations. They have nothing to do with each other (other than they may share information from time to time if it helps with their respective extortion efforts).

[lugnutwrench]

Be careful with that. Last time I talked to my ATF guy he said every 07 in his region is now being forced to be registered and must show proof on audit

This is similar to other anecdotes I've read. Those links I cited describe this in more detail (and make some suggestions on how to avoid registration where an 07 hasn't yet manufactured anything).

[zfields]

This is similar to other anecdotes I've read. Those links I cited describe this in more detail (and make some suggestions on how to avoid registration where an 07 hasn't yet manufactured anything).

That's what it seems like.


I'm wondering how hard it is to get a CJ exception, and if its something I can even do before having my FFL in hand.

[Bigmanjay3]

This is who I called did not get in writing though.
DDTC
Division VI - Small Weapons and Firearms
(USML Commodity Categories I, II, III and X)
Chuck Schwingler Division Chief