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Oh Well

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DR4NRA:
Cant believe there is nothing on here about this. Figures.

https://www.nraila.org/articles/20160727/just-in-time-for-his-party-s-convention-obama-administration-releases-latest-executive-gun-control

On Friday, July 22, just as members of his party were gathering in Philadelphia to coronate Hillary Clinton as their presidential nominee, the Obama Administration once again released a sweeping gun control measure by executive fiat. This time the bad news came via the U.S. State Department’s Directorate of Defense Trade Controls (DDTC), which is primarily responsible for administering the Arms Export Control Act (AECA) and its implementing rules, the International Traffic in Arms Regulations (ITAR). The upshot is that 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.

Mali:
Thank you for posting the information, and here is a link to the actual notice that we can read for ourselves: http://pmddtc.state.gov/compliance/Applicability%20of%20the%20ITAR%20Registration%20Requirement%20to%20Firearms%20Manufacturers%20(Publish).pdf

The contents that seem to be most important:

--- Quote ---1. Registration not Required – Not Manufacturing: 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:
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.
Activities limited to the domestic sale or resale of firearms, the occasional assembly of
firearms without drilling, cutting, or machining, and/or specific gunsmithing activities
that do not improve the accuracy, caliber, or operations of the firearm beyond its original
capabilities (as described above) are not manufacturing within the context of the ITAR.
If you are not manufacturing, exporting, temporarily importing or brokering defense
articles or services, you are not required to register with DDTC.

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.

3. Registration Required – Other than Manufacturing:
a) Assisting foreign persons in the design, development, and repair of firearms may
constitute the export of a defense service (see 22 CFR § 120.9) and require ITAR
registration with and authorization from DDTC; and
b) Exporting a firearm or any other item on the USML requires ITAR registration with
and authorization from DDTC.
--- End quote ---

2D concerns me as this seems to indicate that just the act of reloading ammo may require an FFL depending on the meaning of "systemized". The rest concerns me as well, but particularly this phrase since I am not planning on anything else in the list. It is amazing how they can just make changes like this without any challenge or issue.

RobertH:
so... get all reloaders registered as FFLs.  great way to form/supplement a national database.

i assume the ammo reloading FFL is different than a gun selling FFL?

m0par:
Correct me if I'm wrong, but doesn't this new "guidance" only impact those "in the business"?

IOW, it still stinks to high heaven, but doesn't affect reloaders or even machinists who are working on their own stuff. No?

ETA: the regs also state that "engaging in such a business requires only one occasion of manufacturing".

(Threading a barrel = manufacturing? What imbecile came up with that?)

depserv:
The Obama ATF tried to outlaw 5.56 mm green tip ammo and was stopped by loyal Americans.  What can loyal Americans do to reverse this power grab?  Contact our senators and congressman I suppose?

Since moving to the Omaha area my congressman is now a traitor by the name of Brad Ashford, so it won't do me any good to contact him I suppose.  But I will contact my senators.  And hopefully things like this will wake the citizens of Omaha up so they won't reelect the traitor they elected last time.     

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