July 29th, 2016

ALERT: Feds Impose ITAR Registration Burdens on Gunsmiths

AECA DDTC Federal export manufacturer registration requirement criminal sanctions Annual fee NRA-ILA

If you are a gunsmith or work on firearms, you need to read this carefully. The Federal Government, acting through the Department of State Directorate of Defense Trade Controls (DDTC), has imposed significant new burdens on gunsmiths by expanding the definition of “manufacturing”. This is a big deal, as the Arms Export Control Act (AECA) and its implementing rules, the International Traffic in Arms Regulations (ITAR), require firearms “manufacturers” to register with DDTC and to pay a registration fee that (for new applicants) is currently $2,250 per year.

READ DDTC’s ITAR Registration Requirements Concerning Gunsmithing Dated 7/22/2016
Official Title: ITAR Registration Requirements — Consolidated Guidance July 22, 2016 — Firearms Manufacturers and Gunsmiths

Previously, most small gunsmithing operations that did not export firearms were NOT subject to AECA/ITAR registration requirements. Now, by virtue of a DDTC “Guidance” ruling issued 7/22/2016, ordinary gunsmiths might be required to register as a manufacturer simply because they thread a muzzle or cut a chamber.

The NRA-ILA states: “DDTC is labeling commercial gunsmiths as ‘manufacturers’ for performing relatively simple work such as threading a barrel or fabricating a small custom part for an older firearm. Under the AECA, ‘manufacturers’ are required to register with DDTC at significant expense or risk onerous criminal penalties.” Read NRA-ILA Full Report.

AECA DDTC Federal export manufacturer registration requirement criminal sanctions Annual fee NRA-ILA

Here is the key language in the DDTC’s “ITAR Registration Requirements – Consolidated Guidance” Ruling of 7/22/2016:

2. 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.

Editor’s Comment: Does this mean that any stock-maker or stock supplier is an ITAR “manufacturer” under part 2(c)? Would installing a scope or accessory rail fall under part 2(a) as “equipment upgrading”? Would fluting a barrel be considered “manufacturing” under part 2(h)?

Impact of New Registration Requirements
As the NRA-ILA (Institute for Legislative Action) reads this, gunsmithing shops (even one-man operations) will now be subject to ITAR regulation though they export nothing: “These requirements apply, even if the business does not, and does not intend to, export any defense article. Moreover, under ITAR, ‘only one occasion of manufacturing … a defense article’ is necessary for a commercial entity to be considered ‘engaged in the business’ and therefore subject to the regime’s requirements.”

As a consequence, these new regulations may drive smaller gunsmithing services out of business: “DDTC’s move appears aimed at expanding the regulatory sweep of the AECA/ITAR and culling many smaller commercial gunsmithing operations that do not have the means to pay the annual registration fee or the sophistication to negotiate DDTC’s confusing maze of bureaucracy. [This is] likely to have a significant chilling effect on activity that would not even be considered regulated.”

Statutory Authority for Registration
The AECA’s statutory requirement for firearms manufacturers to register with DDTC is implemented in Part 122 of the ITAR:

§122.1 Registration requirements.
(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.

Barrel chambering image from Primal Rights, dealer for Desert Tactical Arms.
Permalink Gunsmithing, News 18 Comments »
July 29th, 2016

GUNVOTE Program Promotes Voter Registration and Education

nssf hornady gunvote election 2016

The National Shooting Sports Foundation (NSSF) #GUNVOTE program is an important voter registration and education campaign for the November 2016 election. The NSSF’s Gunvote.org website helps visitors register to vote, find a polling place, and determine how candidates stand on gun rights and Second Amendment issues. Quickly find all state and federal candidates in your area with a Zip Code search (or you can search by name). The NSSF’s #GUNVOTE program also provides election news, voter education video resources, and more.

nssf hornady gunvote election 2016To assist the NSSF’s voter registration and education efforts, Hornady Manufacturing has committed $250,000 in support of #GUNVOTE programs. This is the largest donation the #GUNVOTE campaign has received to date.

“For the first time in our nation’s history, we have a Presidential candidate who is openly running against the lawful commerce in firearms, which is a prerequisite to our ability to exercise our Second Amendment rights,” said Stephen Hornady, President of Hornady Manufacturing. “It is vital that America’s hunters, target shooters and all gun owners become educated on what the candidates are saying and that’s why the #GUNVOTE initiative of our industry is so important. Our company is proud to be a part of this cooperative effort.”

We support the NSSF’s efforts to inform the public and help gun owners register to vote. This is a very important election for firearms owners and supporters of the Second Amendment. As the NSSF explains: “With the balance of the Supreme Court at stake, this election will affect our constitutional rights. It is crucial that all gun owners and Second Amendment supporters register to vote, become informed about candidates’ positions, and on Election Day, #GUNVOTE.”

Permalink News 1 Comment »
July 29th, 2016

Quality, Affordable Laminated Wood Stocks for Savage A17

Boyds stocks laminate laminated wood varmint thumbhole hunter stock

The Savage A17 17 HMR rifle was named American Hunter’s 2016 Rifle of the Year. And we understand why. This little rifle is a hoot to shoot. The model we tested proved reliable and quite accurate with the new 17 HMR ammo developed by CCI expressly for the A17. After the first production run Savage made a few tweaks to the A17’s magazine well; this has resulted in very good reliability with current models.

When the A17 was released, a rather whimpy, Tupperware stock was the only option. The Length of Pull (LOP) was a bit short for a full-sized adult and the short, narrow fore-arm was less than ideal when used with a front rest or sandbag. Savage now offers laminated wood stocks from the factory, but most of the A17s that have been sold to date have the black plastic stock. But don’t worry… you can re-stock your A17 for under $130.00.

Now, thanks to Boyds Gunstocks, there are some good, very affordable stock options for the A17. Boyds has introduced Savage A17 replacement gunstocks in multiple styles: Savage Classic, Featherweight Thumbhole, Heritage, Platinum, Prairie Hunter, Pro Varmint, and Varmint Thumbhole designs. Five of these styles are shown in the photos above. Nearly all of Boyd’s laminated wood Savage A17 stocks are just $129.00 with a few left-hand versions priced at $144.00 (still a bargain). For field use, we like the Varmint Thumbhole because it has a comfortable grip and a longer, straight fore-end that works well with either sandbags or bipod. For target work, we favor the Pro Varmint stock. This stock features a relatively straight toe on the buttstock that is very steady on a rear bag.

Boyds stocks laminate laminated wood varmint thumbhole hunter stock

Boyds plans to offer a variety of options for their Savage A17 stocks. These will include new custom wood options, custom length of pull, and an adjustable comb. In addition, as with other Boyds stocks, a wide selection of laminated wood colors are available. Boyds recently released eight new laminate wood color options including Sage, Prairie Wind, Ripple Timber, Ripple Forest Camo, Ripple Blaze, Ripple Royal Jacaranda, Ripple Sky and Ripple Zombie.

Permalink Gear Review, New Product No Comments »