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Posted: 8/22/2016 9:32:17 AM EDT
| I would like to start a business building and selling UPPER receivers ONLY from parts already manufactured. Do I need a FFL of any kind? I was told I need a 07 FFL and to register with ITAR with a $2250 a year fee, limited to 50 sales before taxes had to be paid. Anyone doing this? Any lawyers here? ATF agents lurking around that can answer my question. :) |
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IMO.. No FFL and No ITAR. However. You are still technically bound by ITAR regulations on sales to forigen nationals or delivery of US Muntitions List Items to a forigen Country. Which an AR upper falls under !
It is not a grey area. Anything AR related is a Munitions list item and can not (knowingly) be exported out of the US without license from the State Dept. Normaly items like receivers and barrels that have a manufacturing excise tax attached are paid by the actual manufacturer of the component. It would amount to double taxation. |
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Itar not needed? <a href="http://s745.photobucket.com/user/sergio762/media/20161011_093444_zpsph0umlmx.jpg.html" target="_blank">http://i745.photobucket.com/albums/xx96/sergio762/20161011_093444_zpsph0umlmx.jpg</a> Quoted:
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Uppers are not firearms. No FFL is needed. You will need the ITAR registration though. Itar not needed? <a href="http://s745.photobucket.com/user/sergio762/media/20161011_093444_zpsph0umlmx.jpg.html" target="_blank">http://i745.photobucket.com/albums/xx96/sergio762/20161011_093444_zpsph0umlmx.jpg</a> As for Item D, it was my understanding that if you had someones complete firearm overnight for coating, you needed an FFL, in particular, if you were disassembling and reassembling the weapons. Same with engravers. OP, if you can qualify and get an FFL, why not just do it? It opens up a lot more avenues of cash flow. |
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Buy parts, build and sell, then ITAR applies. Sell parts first then buld for customer, no ITAR. Not true, While ATF considers assembly as a manufacturing operation, the State Department does not. Meaning you buy parts, lowers, uppers and assemble a firearm you'll need an 07FFL but do not need to pay ITAR. |
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Not true, While ATF considers assembly as a manufacturing operation, the State Department does not. Meaning you buy parts, lowers, uppers and assemble a firearm you'll need an 07FFL but do not need to pay ITAR. Quoted:
Quoted:
Buy parts, build and sell, then ITAR applies. Sell parts first then buld for customer, no ITAR. Not true, While ATF considers assembly as a manufacturing operation, the State Department does not. Meaning you buy parts, lowers, uppers and assemble a firearm you'll need an 07FFL but do not need to pay ITAR. I called the 1800 # spoke to them about assembling ar15s from parts kits. They said no registration required and would send a letter stating so. I think you are correct tom. |
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I called the 1800 # spoke to them about assembling ar15s from parts kits. They said no registration required and would send a letter stating so. I think you are correct tom. Quoted:
Quoted:
Quoted:
Buy parts, build and sell, then ITAR applies. Sell parts first then buld for customer, no ITAR. Not true, While ATF considers assembly as a manufacturing operation, the State Department does not. Meaning you buy parts, lowers, uppers and assemble a firearm you'll need an 07FFL but do not need to pay ITAR. I called the 1800 # spoke to them about assembling ar15s from parts kits. They said no registration required and would send a letter stating so. I think you are correct tom. On FFLs Only there is a letter from DDTC |
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