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.

 

Yea me too.

How many thousands of dollars in minimum fees and taxes (before any profit whatsoever is realized) is acceptable for the privilege of being employed in a particular business in the United States without being put in jail?

Explain that dollar figure to me, please.

 
It's going to put all those "gunsmiths" with a drill press, dremel tool, and tap & die set out of business, though.

 
He didn't say it was acceptable, did he?


He said if $2250 puts you out of business, you're doing it wrong.

 
Are they performing work on a customer's gun for profit?

I'm just glad we have the 86 MG ban in place.   To keep prices high so all the poor scum can't afford them.

That's how you sound in case you were wondering why I wrote that.

b) Modifications to a firearm that change round capacity

It specifically says to a firearm, so modifying mags should still be GTG, right? I'm thinking they mean cutting magwells on WASRs, modifying Saigas, and VEPRs, the actual guns, not just the components. Right?

I don't know that I'd necessarily agree with that.  If you're an individual who started gunsmithing lets say less than 2 years ago, still making a name for yourself, using an older used lathe and every penny you make is going back into the business to expand and improve.  

At the same point in time, this is also going to prevent a lot of people from getting into gunsmithing I believe.  

Got to remember, not everyone gunsmith does it for the money, some people truly are passionate about it, or do it strictly as a hobby.  I can actually see quite a few individuals dropping their FFL all together and going to the old school style, as long as you stay here and watch me do the work, I don't need an FFL mentality.

When I first started with $10,000 and a small line of credit, $2,250 would have made or broke me. Hell, a few hundred bucks could have broke me back during the first 6 months, I had to have every penny working to make a go of it. What new business has $2,250 to blow on some bull shit fee?

A lot of them profit from the videos.

I almost want to write a clarification letter...

If I'm going to pay the fee anyways, I might as well send a letter highlighting the language that says firearm.

No it isn't, because a huge majority of them are operating on a cash basis with no license of any type to begin with, to include an FFL. These guys are blatantly advertising on social media constantly and the ATF, with 2400 SA's roaming the country can't catch them. You think State's gonna hire a few thousand people to hunt for some dude threading a few barrels in his basement? Oh, they'll stumble across one now and again, but by and large the squeeze will be felt by the guys who care about being legitimate. I bet half the damn country has never heard of the State Department, and the half that has doesn't know what they do.

 

I would argue that most traditional "gun smithing" is not simple parts replacement. It sounds like you're thinking purely from an ar-15 (or similar) perspective.
First of all is the incredible overreach; this measure has nothing to do with export restriction as it squarely targets smaller gunsmiths largely doing work locally.  I think it's a last ditch act from an administration, frustrated by its lack of progress at the congressional level, desperately trying to stick it's thumb in the eye of the firearms industry any way it can.  That alone is an issue, perhaps more than anything else.
What I find interesting is that it probably affects "Fudds" more than the evil assault weapons owners. You know, we don't want to take YOUR guns. This will really affect those who want a trigger job on their target pistol, or to get the barrel on their 700 bedded, or if their grandpa's 16 gauge needs repair that requires machining.

ITAR absolutely needs to be repealed. If a few terrorists get a few fancy toys, so the fuck what? Minor in the grand scheme of things and not worth the impact on liberty and commerce. But that will be the hangup on any repeal effort, especially with Democrats and McCain-style Republicans. It still needs to become a priority.

The stated purpose of ITAR was to be aware of what companies were producing items which could be subject to export restriction - by having those companies register with a small basement run 2 employee dept in the basement of the Dept of State. ( started by the Carter Admin )

This vague and ambiguous requirement has grown into a monster.

If you make laces for tennis shoes your OK, but if some of your laces could be used on boots - well now you have to register... Because boot laces are considered "an implement of war"

Not only is the government using this to beat up on gun users, it totally fails equal protection under the law because there are MILLIONS of business that produce products that could be considered for export restriction - but the .gov will not bother them at all because it is not firearms related. There have been cases where the .gov went after one manufacture for ITAR and yet all the competing companies making nearly identical products were never contacted.

This registration "FEE" is an un-authorized tax on business. Congress needs to step in and yank the purse strings. No fee's to register for any domestic company not involved in export activities and reasonable fee's for exporters.

It is not the responsibility of US Business to fund the State Dept. - Congress provides the State Dept. budget. and its time they slapped some extra rules on the State dept.

To put it in perspective - the State Dept issues our US Passports - a business should not need to pay more than the cost of a passport to register with the State Dept. and that registration should be good for the same 10 year period.

Oh, I agree, it's a bitch move from a bitch Administration intended strictly to make our lives a little harder, for spite.

I do think from an AR perspective, somewhat, but even with traditional arms, the old style of 'smithing is growing less common. There are still guys needing things done like you cited, but the trend is more and more toward drop in components (triggers, etc.). Why spend big bucks and time building a custom bolt gun when you can buy one that will shoot sub-MOA with factory ammo right out of the box? I'm sure I'm not the only one who has noticed that there are far fewer gunsmiths (actual, not dude with a Dremel) around than there were 20 years ago. They weren't regulated out, time caught up with them. When guns broke, people took them to the gunsmith and he fixed them. Now when they break, they shoot the manufacturer an email, manufacturer sends a label and the gun goes in for a warranty repair. Even outside warranty repair, unless the gun is very old or very rare, few problems can't be solved with a parts order and a YouTube tutorial. The business model is simply outdated... That doesn't make it suck any less for the guys it's going to shut down, though.

Businesses shouldn't have to register, period. The purpose of ITAR was wrong-headed to begin with and goes beyond what is necessary and proper to regulate commerce with foreign nations.

Zimmermann did nothing wrong.

Are you fucking kidding me?

When you do gunsmithing as a hobby out of your garage as a hobby, doing things like barrel chops/threading/crowning, pin/weld, trigger work, slide/frame fitment, stippling, assembling, installing/fitting components, applying metal/stock finishes and other such things on such a small scale, you'd be lucky to make five grand a year.

If you suddenly have to become an FFL, fill out ridiculous and asinine amounts of paperwork while also paying over two grand every year for a ridiculous tax that was applied to you by executive fiat, that will put you out of business.

Why? Because your hobby is no longer worth the cost and effort.

The whole fucking point of Obama doing this is to fuck over small businesses, and attack the infrastructure of the Second Amendment. That jug-eared cocksucker just sucker punched us because he fucking felt like it.

And if we let this sort of shit slide, then another president is going to have the ITAR tax jacked up to five grand a year. Then it'll jump to 10K. Then 20K. As always, this communist shit is just one more step towards outlawing gun ownership.

And whether you like him or not (I don't), people need to realise that they need to get on board if they value the 2A.

If you're one of those #nevertrumpers think of it this way... Your vote potentially alters the course of the US for at least 50 years. If you are comfortable going down the current path for the next 50 years (that would be you, your kids, your grandkids) then find a reason not to vote trump.

If you think it's an issue of principles, then ask yourself whether the founding fathers were thinking of themselves or the greater good of the nation.

The first time your drill hits that 80% lower.

There you go thinking again, that'll get you in trouble... "We're changing the definition of..."

It's all so 1984 it's surreal.

Trump's not going to do shit about this. He can barely articulate pro-gun sentiments. This sort of thing is not even on his radar. Heck, this sort of thing isn't even on the radar of some solidly pro-gun guys.

Not sure what that has to do with my post.

I didn't say anything about suffering in silence, I just said that Trump won't give us a thing.

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.

QFT. I have to be careful what I publish wrt my research, because it can be ruled to be under the umbrella of ITAR even after the fact. I really wanted to ask the agents if I should stop teaching my students how to calculate stresses in cylinders (and thereby give them the ability to predict burst pressures of pressure vessels). Knowledge is dangerous, you know.

2 pages and yet I see no link.
Linky clicky here
Its a short, easy read.

And a painful read.
Thanks for providing a link.

So "gunsmith" buys firearm to be worked on for $1. He does what ever he wants because it's his. Sells it back for 1$ plus value of work. Done.

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.

The same way they atered "how you hold a firearm" into "redesign a firearm".

Unless some definitions have changed do to this ITAR reg working on gun parts separate from the registered receiver is not considered gunsmithing requiring an FFL.
Example - working on an ar15 upper group to do repair/modification is not gunsmithing as long as the lower was not in your shop/possession.

No, the "laws" they enforce should be repealed and the agents should not be on the payroll.  There are malls out there that need ninjas to harass the customers and I don't think we should deprive them.

You are correct, unless you are working on/have possession of the serialized component (firearm), no FFL is required per the BATFE.
ITAR is totally separate from BATFE however.
Their registration criteria and re definition of "Manufacturing" covers any and all "Defense Related Products", which uppers are a part of.


Well worth 10 minutes of your time: http://m.youtube.com/watch?v=GTAHEYFu8mY

Yes the part in red I was aware of and is the topic of this thread.
Thanks

Of course it is not on his radar, it wasn't on most of our radars until we read about it here. We need to put it on his radar.

That was initially proposed a few years back.

ITAR covers the "Sharing of information" aspect of "Defense related products" as well.
The iterations of ITAR are disturbing.

Yep. I guess I'll start seeding the 3D gun files again.

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

I agree and the fact that the State Dept. and ATF have banded together to say "if you have an 07FFL you must pay ITAR" is fucking stupid.  The gunsmithing thing is just an added dose of derp.
 

Oh really?  That's funny...



 

This girl s what they want. Chill the industry.

Doubled

I'm in the business and I agree with Hockey. Sounds like you're in the business, but make excuses for this shit because it helps edge out your competition.