That's how it reads to me... but furthermore, does it then also apply to adding a +1 base plate to a magazine?
Absolutely insane.
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Not yet. They'll get around it by saying what they think they can get away with now, and then wait for future administrations to tighten up the regs so it will include punishment for those without a FFL making these mods and then telling those with a FFL that a mag base plate swap or shotgun tube extension will be considered manufacturing.
Regulations that only a lawyer can interpret. No wonder lawyers love such things.
Can we outlaw high capacity legislation or assault regulations?
The only thing that can stop a bad lawyer is a good lawyer. Know any good lawyers?
The cost of a firearm, ammunition and training are miniscule compared to the legal bill if you ever need to use that firearm.
Sorry Bert. You work in a highly regulated industry despite the claims by ignorant people who actually believe that we can buy a gun in a supermarket or through the Internet. Lies promoted by those who manipulate the ignorant.
Sad times we live in. Sorry for the news to your business. There is definitely a storm a brewin'.
Training classes I have taken have required passports in order to make sure they comply with ITAR.
We don't live in the land of the free anymore folks.
I'd like to say I saw this coming, and it's the reason I got out of the business earlier this year after doing it for 15, but I didn't, specifically. I felt like more bullshit regulations were coming down the pike, and that was a part of my decision, though.
ITAR was meant to prevent to prevent key tech going to hostile govs. Equipment like rocket motors, guidance and navigation, etc. The fact that some overzelous junior lawyer has been greenlighted to apply tgis at the BPT level is a travesty.
ITAR is a total fawk show that is grossly inefficient.
It sucks the big one when they decide you have to prove you haven't done anything wrong. One of the products I used to sell ended up in Qatar (legit customer sold it on eBay, someone bought it in the US, and then shipped it to Qatar), without any paperwork, and I got to spend 6 months with ITAR attorneys, my employer's attorneys, and reams of BS paperwork.
I spoke with an Industry Operations Field Inspector with the BATFE today regarding this. She was not directly familiar with this particular directive she has a basic knowledge of I.T.A.R.
I read her some of the verbiage and she felt it was "Excessive" and "Unnecessary unless one is exporting defense related goods".
She agrees it really puts the screws to Gunsmiths as most of them are small businesses as myself. She actually was very pleasant to deal with.
Unfortunately she did state that a FFL must abide by all local, state and federal regulations.
She also suggested I call I.T.A.R. for clarification and guidance.
I called Gardeners office and another Senator out of Montana(Steve Daines) who has dealt with getting ITAR regulations stepped back in the past.
We shall see what comes out in the wash but until then, I feel I will have to effectively shut the doors for the time being.
FML