Home gunsmithing

[Apache]

Is this what you're looking for?

https://www.pmddtc.state.gov/compliance/documents/ITARRegReqFirearmsManufacturers.pdf

Lot's of discussions on this here too: http://forum.accurateshooter.com/threads/plan-on-paying-your-gunsmith-more.3906517/

[tufrthnails]

No I am looking for a specific EO. This is the one signed on the 22cd: https://www.whitehouse.gov/the-press-office/2016/07/22/executive-order-delegation-certain-authorities-and-assignment-certain, but it reads like greek to me.

[foxx]

I dont think thats the one we are talking about. It appears to me, at this point, the State Department is not relying on an EO. I could be wrong, however

[stomp442]

Well, this has me very concerned as well and really in a bind as how to move forward. I am a new class 07 FFL holder, submitted my paper work in December and received my License the first part of April of this year. I was encouraged by the BATF that what I was wanting to do would require the 07 license, (installing brakes and rebarreling Rifles) along with other common gunsmithing such as bedding jobs and what not. I was told at my inspection that I would not be required for the ITAR registration as long as I worked on owner supplied actions and parts and thats what I have been doing for the last few months. I have always been a gun nut and have always worked on all my own stuff and enjoy it a lot. I decided to take the next step because I was always being asked to do this or that by people when I was at the range. I figured what the heck and take this to the next level and make this a supplemental income that I enjoy doing. Well long story short I am now about 8 grand in debt with a new lathe and tooling plus busniess start up costs and now this ruling comes down from on high and has my head spinning on what to do. Do I cut my losses and run? Try to sell my lathe and tooling and recoup some of my debt or stick it out and hope to absorb the cost of doing business and be marginally successful. I am not trying to get rich and I know gunsmithing is not generally a large money making endeavor I am just trying to have fun and make a little play money in the process.

[Apache]

Stomp442,

This may answer what you're wanting to know....

https://blog.princelaw.com/2012/08/10/department-of-state-is-stepping-up-enforcement-of-itar-related-to-manufacturers/

[The Old Coach]

In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is not required because the following activities do not meet the ordinary, contemporary, common meaning of “manufacturing” that DDTC employs in implementing the ITAR and, therefore, do not constitute “manufacturing” for ITAR purposes:

Does that not suggest that home gunsmithing for one's own collection would be exempt, since the home hobby gunsmith is not soliciting or receiving any work from the public?

[Robinhood]

If this is an Executive order the White house is unaware.
https://www.whitehouse.gov/briefing-room/presidential-actions/executive-orders

[The Old Coach]

If this is an Executive order the White house is unaware.
https://www.whitehouse.gov/briefing-room/presidential-actions/executive-orders

Not a presidential executive order. It's an action taken by faceless and soulless bureaucrats in the State Dept. to fiddle a regulatory definition. Although they are now looking up at Obama with shining faces, saying, "Did do good, Oh Emperor Obama. Do I get a reward?"

[Apache]

Guys.....please don't let this slide off into some kind of political slamming......keep it on topic and informative......and as respectful as possible. It's too important to get it locked up.

[stomp442]

Wow! So yeah sounds like I pay the Ransom to play or close up shop and quit. No middle ground what so ever for a small shop.

[foxx]

duplicate post, and out of intended context as written.

[Apache]

Well......right now it seems that way.

This is what I've gleaned so far and my opinion only.....

You have to remember this is all done via EO for now. IF the Republican gets in, he has promised to repeal all of the EO's....if so...this will all go away. IF the Dems take the presidency, it's going to get worse, not better. I'm waiting to make my final decision after the elections. But I'm also putting somethings into motion JUST IN CASE the Republican doesn't get in.

At this point, they also have no real reinforcement mechanism in place from everything I've read. What little they do have in place is completely overwhelmed right now. It would be like putting a stop sign up and have no cops to enforce it. Now one thing to consider though....this thing has some REAL teeth in it for penalties if they choose to make an example out of someone.

So don't make a decision lightly.

This will be challenged in court at some point also......but it's a toss up on the out come. Most of that will depend on this election.

This is probably THE MOST important election in our lifetime......or longer.

So far, this is my pattern of thinking. I'm still researching this though.

[J.Baker]

Which EO is this specifically I was trying to find the actual order to read the order. https://www.whitehouse.gov/the-press-office/2016/07/22/executive-order-delegation-certain-authorities-and-assignment-certain

There is no Executive Order. This is simply the DOS changing their definition of what is and is not considered "manufacturing" as it applies to DDTC and ITAR.

Also, it's not "if" this becomes law, it already is the law and has been for decades. The only thing that's changed are what specific acts or services the DOS considers to be manufacturing that would require the registration under DDTC.

[foxx]

Does that not suggest that home gunsmithing for one's own collection would be exempt, since the home hobby gunsmith is not soliciting or receiving any work from the public?

Yes, Coach, I believe you are correct.

However, if his suppliers are run-off, the hobbiest will be hard-put to find parts for his projects.

[Apache]

There is no Executive Order. This is simply the DOS changing their definition of what is and is not considered "manufacturing" as it applies to DDTC and ITAR.

Also, it's not "if" this becomes law, it already is the law and has been for decades. The only thing that's changed are what specific acts or services the DOS considers to be manufacturing that would require the registration under DDTC.

Jim...has it been around that long!!!! WOW! I've heard that it was slipped in ambiguously about 5 years ago. ITAR was suppose to regulate international arms trade with other countries......as I understand it, this is their attempt to regulate arms within our own nation now to a much greater degree than before.

[foxx]

There is no Executive Order. This is simply the DOS changing their definition of what is and is not considered "manufacturing" as it applies to DDTC and ITAR.

Also, it's not "if" this becomes law, it already is the law and has been for decades. The only thing that's changed are what specific acts or services the DOS considers to be manufacturing that would require the registration under DDTC.


I agree. I think that is the whole deal here. The current administration has created a new culture that seeks more power and is eager to interpret their roles in a way that justifies or enables whatever agenda they seek. In this case, the State Department is acting the same way the president does when he issues Executive Orders so as to make policy without enacting laws. In this case, they want to destroy the gun industry.

[foxx]

I may begoing out on a limb here, but I believe the problem is rooted in the AR-15 debacle. Liberals want them outlawed. They can't do that right now, but they can make them more difficult for common citizens to obtain. They can make them more expensive, for example. Currently, there are a lot of companies making parts and kits that drive down the cost of building them. What might currently cost a guy $500-600 to build himself or with the help of a gunsmith would, if this action is carried out successfully, might end up costing $1,000 if the only companies making them are Ruger, Remington, Colt, Winchester, etc. THey can afford the fees, but the small companies and gunsmiths can't. In the end, the cost of these "Assault Rifles" that are threatening the Americans or American government because they are so easily produced and so affordable will go up and be less popular.

AR's are the "Saturday Night Special" of the 1970's and 80's and liberals are afraid of them because of their capabilities.

[WV1951]

What has gotten lost in the shuffle and our own interest is that these regs and orders are being interpreted, handed down, revised, changed, etc. for many industries. The gun lobby has seen as much pressure applied as anybody, but we have to realize that the ideology of this current administration has had 7 1/2 years to permeate, fill voids, and take over the thought process in the huge Washington bureaucracy. This large Washington bureaucracy wields tremendous power that is usually runs under the radar. This is one of many possible roadblocks that will come up the next few years. It takes years to "clean" house of a certain ideology.

[Apache]

Norm....Jim....

I'm just asking your opinions based on what you've learned......

Do you think the elections will change these "definitions" of what manufacturing is? Or is this something that is going to be permanent?

[foxx]

What has gotten lost in the shuffle and our own interest is that these regs and orders are being interpreted, handed down, revised, changed, etc. for many industries. The gun lobby has seen as much pressure applied as anybody, but we have to realize that the ideology of this current administration has had 7 1/2 years to permeate, fill voids, and take over the thought process in the huge Washington bureaucracy. This large Washington bureaucracy wields tremendous power that is usually runs under the radar. This is one of many possible roadblocks that will come up the next few years. It takes years to "clean" house of a certain ideology.

EXACTLY, that was my point with my post #28 and the Department of Labor getting involved in your IRA's and your relationship with your financial consultant. Who would have thought the Depart of Labor would see it fitting to even go there?