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I'm in the business and I agree with Hockey. Sounds like you're in the business, but support this shit to help edge out your competition.

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Yeah, because wishing the market had fewer idiots fucking people's guns up for money is the exact same as supporting restrictions on machineguns.


 

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A couple of points to your post:

If you are doing any Gunsmithing, even as a hobby and you are charging a fee for it you are considered "in the course of business" and you must have a FFL.
The FFL cost is minimal, $200.00 every 3 years which is a reasonable cost for a hobbyist business to absorb.
The vast majority of working Gunsmiths are 01 licensed, you don't have to be a 07 "Manufacturer" to modify/repair firearms.

The remainder of your post is dead bang on.

As far as the crowd that makes the statement that if you can't afford $2250.00 a year your doing it wrong, get over yourselves. Your clearly not in the business. My best year when I was full time showed $24,000 after my accountant was done with all the taxes(36% bracket) and deductions etc. $2250.00 a year is a serious chunk of that, nearly 10%. Many small businesses cannot afford 10% of their profit to be sucked up by fees.


But let's look at the part time guy which is the majority of Gunsmiths. A large amount are retirees such as myself that do it as an additional source of income or as a hobby income. Even the BATFE IOI's that I spoke with regarding this "Guidance Letter" feel it is unwarranted and excessive.
Going off of my last year's taxes between them and now an additional $2250.00 annually I will basically have to work for free for 4-5 months of the year just to stay on the right side of the Feds. Who can afford that?
I dropped a good chunk of change to an ITAR compliance attorney plus spoke with 2 ITAR compliance officers for a manufacturing firm where a buddy works.

Here is the bottom line- if your are engaged in business in any form as a Gunsmith and so much as put a file to metal (remove material), this "Guidance Letter" and ITAR registration applies to you.
This document is so broadly and poorly written that it applies to every Gunsmith.
There is a statement in it that if you use "Specialized Equipment" you are a "Manufacturer". Guess what? A Sight Pusher is "Specialized Equipment", just as a bore sighter, a sear jig, a dovetail cutter and a range rod is.

For the crowd that is of the "Fuck them, I'm doing it anyway" mentality, go nuts. Granted the odds of getting tripped up on this are likely pretty small but just how much cash/assets do you have on hand to fight a long and drawn out legal battle against the .gov machine?

I can't swing the $2250.00 registration fee at this time let alone hundreds of thousands in legal defense fees.


The compliance officers I spoke with did feel there would be changes to this decree, they had just gotten back from an ITAR conference and they said the during the conference this "Guidance Letter" was the bulk of discussion. The firearms industry is livid over this.
But who knows when we may see some changes?
Possibly a restructuring of the fees or stepping back the regulations is in the future but until then my doors are closed.

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I welcome legitimate competition.

The guys fucking shit up in their garage for people who don't know any better are not my competition.  They need to stick to fucking up their own guns and stop calling themselves "gunsmiths."

Then again, maybe I should be encouraging them because someone has to fix their screw ups.
 

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You just stated that you hoped ITAR would force smaller smiths out of the market.   You acknowledged that ITAR is, itself, bullshit, that the fees are bullshit, but that you hope that the outcome of this bullshit would force people you don't like out of business.  





Yes, it is exactly the same thing.   I'm sure I'm not the only person that sees it.

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Who died and made you the pope?   Do you work for the government or something?   You sure sound like it.

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I welcome legitimate competition.

The guys fucking shit up in their garage for people who don't know any better are not my competition.  They need to stick to fucking up their own guns and stop calling themselves "gunsmiths."

Then again, maybe I should be encouraging them because someone has to fix their screw ups.
 

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You must work for the media.  Instead of taking what I say and twisting it like a dipshit, how about you read what the fuck I'm typing?  It's right there in plain English so you don't even have to apply your "what is he really saying" bullshit filter to it.

"and the legitimate small time smiths will see a big enough bump in business to cover ITAR and turn a hefty profit."

It's not about "people I don't like."  It's about people who shouldn't touch another person's gun and certainly shouldn't be paid for fucking people's shit up.

If someone does good work, they should live long and prosper.  If someone is swindling their customers out of money and performing god-awful work, they should go out of business and choke on a bag of dicks.
   

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The free flow of information scares the fuck out of them. Hence trying to control the Internet. Obama is going to violate law and hand control of ICANN to internationalists.



For those that don't know.
The Internet Corporation for Assigned Names and Numbers (ICANN) is an American private nonprofit organization that is responsible for coordinating the maintenance and procedures of several databases related to the namespaces of the Internet - thereby ensuring the network's stable and secure operation. ICANN performs the actual technical maintenance work of the central Internet address pools and DNS Root registries pursuant to the Internet Assigned Numbers Authority (IANA) function contract.

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Nope. You must now get your 07 FFL because:
1- you are engaged in business
2- you enhanced the value of the firearm and resold it for profit.

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Yep. That was already specifically addressed in differentiating between a gunsmith and a manufacturer prior to the ITAR ruling Itar is just icing on the cake.

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Faced with that, don't be surprised when someone makes interesting times for the arresting agents.

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You must work for the media.  Instead of taking what I say and twisting it like a dipshit, how about you read what the fuck I'm typing?  It's right there in plain English so you don't even have to apply your "what is he really saying" bullshit filter to it.



"and the legitimate small time smiths will see a big enough bump in business to cover ITAR and turn a hefty profit."



It's not about "people I don't like."  It's about people who shouldn't touch another person's gun and certainly shouldn't be paid for fucking people's shit up.



If someone does good work, they should live long and prosper.  If someone is swindling their customers out of money and performing god-awful work, they should go out of business and choke on a bag of dicks.

   

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Doesn't the free market apply here, as in if someone fucks people's guns up then no one will give them any business.

What about the people, say a retired machinist that has a mill, lathe and radial arm drill in his garage and does stuff for family, neighbors and some neighbor's relatives for free? Does this new ITAR crap pertain to them or does it just hamper people that charge for 10 minute job on a mill?
 

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I'm going to petition the WH to undo something the WH did intentionally to attack us? That's like the zoo asking the Hirambe memes to stop.

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Yes Sir. I live around some people out here in hillbilly land that have had enough and planned accordingly to show they have had enough of the Obamunists ruining the country and many of them are vets and some aren't

All this made me think back to when I was a kid, when no one would have thought actual communists not only exist in this country but flaunt it and no one thought these people would be in our government

I am old though and maybe the younger people were brought up different
 

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Look its ok guys.   This is just going to put all the shitty gunsmiths out of business.   This will actually be a plus for all the good gunsmiths.   See, once all the shitty small-time gunsmiths go starve in a gutter, we'll be forced to use only good gunsmiths.

Isn't government great?  Remember to thank government in your prayers tonight.

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Put a dimensioned drawing of an AR-15 lower on a t-shirt.  That'll do it.

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Technically, you need an FFL to be in the business of gunsmithing.   Of course, that FFL only costs 60 dollars every 3 years...

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Look its ok guys.   This is just going to put all the shitty gunsmiths out of business.   This will actually be a plus for all the good gunsmiths.   See, once all the shitty small-time gunsmiths go starve in a gutter, we'll be forced to use only good gunsmiths.

Isn't government great?  Remember to thank government in your prayers tonight.

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c) The production of firearm parts (including, but not limited to, barrels, stocks,
cylinders, breech mechanisms, triggers, silencers, or suppressors)

You don't need an FFL to manufacture some of the above items, like barrels, stocks, or triggers.

Don't some of the armor piercing pistol ammo regs only apply to FFLs, like rumor had it that FFLs were supposed to stop selling 5.45 when it was deemed armor piercing pistol ammo. Does this ITAR reg only apply to gunsmith & manufacturer FFLs?

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Technically by the most absolute and simplest terms, if ANYONE manufactures any item as a course of business that CAN be used on a "Defense Related Product" then they must register with ITAR.

Billy Bob's Machine shop that makes takedown pins and front sight posts as a subcontractor- yup, gotta register.
Joes Spring Emporium that makes springs that CAN be used as detent springs- yup, gotta register.
Smilies Plastics that molds dust shields for Trijicon- yup, gotta register.


No, this does not apply to FFL's only

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The first time your drill hits that 80% lower.

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I welcome legitimate competition.

The guys fucking shit up in their garage for people who don't know any better are not my competition.  They need to stick to fucking up their own guns and stop calling themselves "gunsmiths."

Then again, maybe I should be encouraging them because someone has to fix their screw ups.
 

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snip


Fucking insane. I've had pins made for me to sell with some other parts. You can give dimensions and the company won't even know they're making parts that can be used in a gun. Basically, everyone is a criminal and they can target whoever they want.

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I would guess it's because the gunsmithing that is going to be affected is not something most shooters need or use commonly. The vast majority of "gunsmithing" done is simple parts replacement, which does not fall under the new regulations. The M855 thing would have had an effect on everyone who shoots any 5.56 rifle. This will not even be noticed by most. How many people outside our little sphere of uber-enthusiasts here is going to get a barrel cut down, re-threaded, and have a flash hider pinned and welded? Damned few. I can't even include myself in that number because there's no way in hell I'm welding my muzzle device to lose 1.5 inches.  

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For those that want to see the original: Department of State Bureau of Political-Military Affairs Directorate of Defense Trade Controls "Applicability of the ITAR Registration Requirement to Firearms Manufacturers and Gunsmiths" in PDF

ITAR registration is required of persons who engage in the business of manufacturing defense articles. Persons who do not actually manufacture ITAR-controlled firearms (including by engaging in the activities described below, which DDTC has found in specific cases to constitute manufacturing) need not register with DDTC – even if they have an FFL from ATF...

Registration not Required – Not Manufacturing: In response to questions from personsengaged 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:
a) Occasional assembly of firearm parts and kits that do not require cutting, drilling, or machining;
b) Firearm repairs involving one-for-one drop-in replacement parts that do not require any cutting, drilling, or machining for installation;
c) Repairs involving replacement parts that do not improve the accuracy, caliber, or other aspects of firearm operation;
d) Hydrographic paint or Cerakote application or bluing treatments for a firearm;
e) Attachment of accessories to a completed firearm without drilling, cutting, or machining—such as attaching a scope, sling, or light to existing mounts or hooks, or attaching a flash suppressor, sound suppressor, muzzle brake, or similar item to a prethreaded muzzle;
f) Cosmetic additions and alterations (including engraving) that do not improve the accuracy, caliber, or other aspects of firearm operation beyond its original capabilities;
g) Machining new dovetails or drilling and tapping new holes for the installation of sights which do not improve the accuracy or operation of the firearm beyond its original capabilities; and
h) Manual loading or reloading of ammunition of .50 caliber or smaller.

Sounds great... but wait...

Registration Required – Manufacturing: In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is required because the following activities meet the ordinary, contemporary, common meaning of “manufacturing” and, therefore, constitute “manufacturing” for ITAR purposes:
a) Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms;
b) Modifications to a firearm that change round capacity;
c) The production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors);
d) The systemized production of ammunition, including the automated loading or reloading of ammunition;
e) The machining or cutting of firearms, e.g., threading of muzzles or muzzle brake installation requiring machining, that results in an enhanced capability;
f) Rechambering firearms through machining, cutting, or drilling;
g) Chambering, cutting, or threading barrel blanks; and
h) Blueprinting firearms by machining the barrel.

Thanks, Obama!

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Put a dimensioned drawing of an AR-15 lower on a t-shirt.  That'll do it.