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ITAR - anyone submitted CJ requests?

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  • icentropy
    Member
    • Jul 2009
    • 443

    ITAR - anyone submitted CJ requests?

    Hoping to hear if anyone has submitted CJ requests and what the result was? Have any exemptions been granted?
    "Seems sick and it's hungry, it's tired and it's torn, It looks like it's dyin' and it's hardly been born" Bob Dylan
    "It's the end of the world as we know it...and I feel fine." R.E.M.
  • #2
    Tyke8319
    CGN/CGSSA Contributor
    CGN Contributor
    • Nov 2013
    • 2105

    OK. I give up. What's a "CJ" request???
    American soldier by choice. Made in America by the Grace of God.

    So, now it is ironic that the State whittles away at the right of its citizens to defend themselves from the possible oppression of their State.
    Judge Roger T. Benitez
    LCM's ruled legal 3/29/2019

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    • #3
      icentropy
      Member
      • Jul 2009
      • 443

      Originally posted by Tyke8319
      OK. I give up. What's a "CJ" request???
      Commodity Jurisdiction Request. Basically it's a way to force the State Department to decide if a specific product is considered a defensive article or covered by the US munitions list. There's an on-going debate about whether certain or all civilian firearms should be or are inherently covered by ITAR and therefor require all 07FFLs to register with the DDTC coughing up a $2250 or so yearly fee. Most just roll over and say "yes" it's required. Maybe it is. But a lot of FFLs are very tight lipped about it and a very few have made little side comments that they have had CJ requests granted. If that's true then the whole idea of all firearms being on the USML by definition, is wrong.

      It's really only applicable to tiny 07FFLs as anyone with a decent revenue would probably rather just pay the yearly fee than submit CJs for each and every product they sell (that relates to the USML). But most of those small guys just decide to forget about it and get their 01FFL and once the customer has purchased their parts kits they then have the FFL build the rifle for them as gunsmithing instead of manufacturing.
      "Seems sick and it's hungry, it's tired and it's torn, It looks like it's dyin' and it's hardly been born" Bob Dylan
      "It's the end of the world as we know it...and I feel fine." R.E.M.

      Comment

      • #4
        Funtimes
        Senior Member
        • Sep 2010
        • 949

        Originally posted by icentropy
        Commodity Jurisdiction Request. Basically it's a way to force the State Department to decide if a specific product is considered a defensive article or covered by the US munitions list. There's an on-going debate about whether certain or all civilian firearms should be or are inherently covered by ITAR and therefor require all 07FFLs to register with the DDTC coughing up a $2250 or so yearly fee. Most just roll over and say "yes" it's required. Maybe it is. But a lot of FFLs are very tight lipped about it and a very few have made little side comments that they have had CJ requests granted. If that's true then the whole idea of all firearms being on the USML by definition, is wrong.

        It's really only applicable to tiny 07FFLs as anyone with a decent revenue would probably rather just pay the yearly fee than submit CJs for each and every product they sell (that relates to the USML). But most of those small guys just decide to forget about it and get their 01FFL and once the customer has purchased their parts kits they then have the FFL build the rifle for them as gunsmithing instead of manufacturing.
        Wouldn't these approved requests be subject to a FOIA request?
        Lawyer, but not your lawyer. Posts aren't legal advice.

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        • #5
          icentropy
          Member
          • Jul 2009
          • 443

          Originally posted by Funtimes
          Wouldn't these approved requests be subject to a FOIA request?
          I honestly have no idea. I know there's a lot of military products as well patented engineering data subject to the CJ process and i would be surprised if they simply allowed all that technical data out to the public.
          "Seems sick and it's hungry, it's tired and it's torn, It looks like it's dyin' and it's hardly been born" Bob Dylan
          "It's the end of the world as we know it...and I feel fine." R.E.M.

          Comment

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