Death of an industry by regulation...

[BPTactical]

Nope, it's not coal, or gas/oil, or commercial fishing or any other industry you think of being regulated to death.
A little thing called "I.T.A.R" (International Trade in Arms Regulations).
This is something which was started in the Cold War to prevent defense information from being shared with hostile entities.
It is under the auspices of the Department of State (remember that).
In its most basic terms it means that any defense industry related entity may not share technical information with "unapproved" entities.
Well in its omnipotent wisdom it has spread it's influence and regulation to..............wait for it......Gunsmithing!

22 July 2016 this little jewel was dropped in our laps:

On Friday July 22, 2016, the Directorate of Defense Trade Controls (“DDTC”) released a letter issuing guidance on the requirement of firearm manufacturers and gunsmiths to register with DDTC under the International Traffic in Arms Regulations (“ITAR”).

There has been constant discussion on the internet regarding whether an individual who has obtained a federal firearms license (“FFL”) is required to register for ITAR. Some of the Industry Operations Inspectors (“IOIs”) have taken it upon themselves to inform Type 07 FFLs that they must register for ITAR without any guidance from DDTC. There are certain instances where an FFL does not need to register for ITAR.

22 C.F.R. § 122.1 discusses the registration requirements for ITAR.

(a) Any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, is required to register with the Directorate of Defense Trade Controls under § 122.2. For the purpose of this subchapter, engaging in such a business requires only one occasion of manufacturing or exporting or temporarily importing a defense article or furnishing a defense service. A manufacturer who does not engage in exporting must nevertheless register.

The crux of the registration for ITAR (for most FFLs) lies within the definition of manufacturing. DDTC has not promulgated a definition for manufacturing which is the source of a lot of confusion and misinformation.

Full text here: https://blog.princelaw.com/2016/07/2...-registration/


Basically what these new regulations do is deem any Gunsmith that does more than refinish a firearm or change sights a "Manufacturer" and force them to "register" their business with the Department of State, with a $2250.00 annual "registration" fee.
Many small businesses (including mine) cannot afford this annual cost.
It will effectively through regulation, kill a vital part of the firearms industry.
This regulation would mean that between taxes and this fee roughly 5-6 months of the revenue my business brings in will be going to the Feds.
Even if I could afford it, I don't think I would pay it on principle.

One thing that I am confused about as is my attorney is the conflict in Federal regulations. Per the BATFE (who BTW, regulates "Commerce in Firearms")my business does not meet the criteria of a "Manufacture" as defined by them and therefore does not require a 07 FFL.
Yet the Department of State denotes what is considered "Manufacturing" when it comes to Gunsmithing.
There is a clear conflict in regulations between the two entities and I have no idea which takes precedence.

Oh, and my note on remembering who runs I.T.A.R?
The Department of State, also known as the State Department.
This stinks of Obama, Clinton and Kerry.

[ray1970]

When gunsmithing is outlawed, only outlaws will perform gunsmithing.

[BPTactical]

When gunsmithing is outlawed, only outlaws will perform gunsmithing.

I get the gist Ray but I.T.A.R. Regulation violations are nothing to sneeze at. The fines can be as steep as $1,000,000.00.

[KestrelBike]

I get the gist Ray but I.T.A.R. Regulation violations are nothing to sneeze at. The fines can be as steep as $1,000,000.00.

Not to mention possible imprisonment, oh and probable loss of certain rights that comes with that?

WTF is going on with this country...

[DavieD55]

WTF is going on with this country...

[CS1983]

A deluge would be met with a defensive ark. So they water torture/board. Drip... drip... drip... even if they don't drown anyone, they'll make enough people feel like they are to the point they just quit.

[BPTactical]

A deluge would be met with a defensive ark. So they water torture/board. Drip... drip... drip... even if they don't drown anyone, they'll make enough people feel like they are to the point they just quit.

Death by a thousand cuts.

By the letter of these regulations if I make any part that can be installed on a firearm I am considered a manufacturer.
Now look at what Massachusetts pulled with the "Copies" bullshit.
Almost identical.



A storm is coming.

[beast556]

The dems are frothing at the mouth to ban all guns in this country.

[DavieD55]

The dems are frothing at the mouth to ban all guns in this country.

Eventually they will as time goes on as the next generations are brainwashed with socialism and communism in the government teacher union public schools.

[Honey Badger282.8]

I agree, some of the wording is pretty vague.

http://pmddtc.state.gov/compliance/A...0(Publish).pdf

2. Registration Required – Manufacturing: In response to questions from persons engagedin the business of gunsmithing, DDTC has found in specific cases that ITAR registration isrequired because the following activities meet the ordinary, contemporary, commonmeaning of “manufacturing” and, therefore, constitute “manufacturing” for ITAR purposes:

1. a) Use of any special tooling or equipment upgrading in order to improve the capabilityof assembled or repaired firearms;
2. b) Modifications to a firearm that change round capacity;
3. c) The production of firearm parts (including, but not limited to, barrels, stocks,cylinders, breech mechanisms, triggers, silencers, or suppressors);
4. d) The systemized production of ammunition, including the automated loading orreloading of ammunition;
5. e) The machining or cutting of firearms, e.g., threading of muzzles or muzzle brakeinstallation requiring machining, that results in an enhanced capability;
6. f) Rechambering firearms through machining, cutting, or drilling;
7. g) Chambering, cutting, or threading barrel blanks; and
8. h) Blueprinting firearms by machining the barrel.