doublegunshop.com - home Forums General Discussion DoubleGun BBS @ doublegunshop.com All Gunsmith's and Members of ACGG are now Felons

I believe we may be being deceived as to the scope of application.
If you Google US Munitions List, you should be directed to a link. 22 CFR 121.1 which details what is covered. At the end of paras a thru i is a Note
"Note . This coverage by the US Munitions List in paragraphs (a) through (i) excludes any non combat shotgun with a barrel length
of 18" or longer............
Thus working on sporting shotguns is fine,does not require ITAR registration, we may continue to drill and tap for mid beads and remain felony free.
The note specifically goes on to state "This category does not cover Riflescopes and sighting devices that are not manufactured to military specifications."
So adding a commercial scope to a gun, including drill and tap as required is not an ITAR covered activity.

What may well be problematic and subject to government overreach would be whether this can be applied to working on AR15 type Rifles. I would be most interested on what the ACGG's Legal Counsel have to say about it's scope and implementation

you are out of your mind if you think this won't be abused.the IRS scandal it a clear indication that individuals with a small amount of power will ruin peoples lives because of personal beliefs.

Mr. Lomas

I agree about the sporting shotguns with barrels greater than 18 inches. but rifles are a different story:

Category I - Firearms, Close Assault Weapons and Combat Shotguns

* (a) Nonautomatic and semi-automatic firearms to caliber .50 inclusive (12.7 mm).

Note:
This coverage by the U.S. Munitions List in paragraphs (a) through (i) of this category excludes any non-combat shotgun with a barrel length of 18 inches or longer, BB, pellet, and muzzle loading (black powder) firearms.

Are bolt action rifles non automatic? What about single shot rifles, or pump and lever action rifles?

Maybe it's a good thing.
Perhaps it will get Elmer stirred up, motivated and on the right side of the equation.

Incrementalism has gone into steamroller mode.

What you forgot to include is that the " * " before that means any of those guns that are considered "Significant Military Equipment".
There in lies the key point to all this. !!!

Dave K provided this about a page ago. So far it seems that this info has not been disputed.

While it's plain to see, there is a definition of 'manufacturing for itar purposes', in the first sentence. And apparently, it's related to routine inquiries from 'persons engaged in the business of gunsmithing'.

I doubt the sky is falling, but I wouldn't be surprised if a few folks engaged in the business are made examples of. Though it isn't legislated, the various forms of executive order are thought to be enforceable as if law.

If all this hinges on the exception of 'sporting shotguns', that's sure to be an all inclusive incremental change down the road. But, we're in agreement that all other civilian firearms fall under the 'new' rules, or just the military looking ones? Doesn't seem too encouraging.

I heard today that ATF is not renewing Gunsmiths FFLs without ITAR.

It is not military looking firearms. It is MILITARY firearms used for defense, as in the military. NOT Civilians.

And the above statement about the atf not renewing ffls without ITAR is just plain bogus. Come on! The new regs are just over 2 weks old. And you are already "hearing" these things??? From where? Some forwarded email, or even facebook? Or maybe some internet message board...

Besides, chances are most gunsmithing operations that this pertains to already are licensed as manufacturers with BATF. This would require them to register with the DDTC.

Lest anyone think for one second that i am in support of the new regs, believe me, i am not. I simply ask that people realize that these regs are not as far reaching as most of you think and the title of this thread suggests.

And... I personally am done talking about this.

So can I tune my Garand for accuracy ?

With all respect I think you're reading this wrong. The definition of significant military equipment is outlined in Sect. 120.7. After reading the regs, I can find no exception for sporting arms other than shotguns with bbl longer than 18", bb guns and pellet guns and muzzle loading guns..


� 120.7 Significant military equipment.

(a) Significant military equipment means articles for which special export controls are warranted because of their capacity for substantial military utility or capability.

(b) Significant military equipment includes:

(1) Items in � 121.1 of this subchapter which are preceded by an asterisk; and

(2) All classified articles enumerated in � 121.1 of this subchapter.
[58 FR 39283, July 22, 1993, as amended at 62 FR 67275, Dec. 24, 1997]


Dept of Commerce Firearms Export FAQ includes the following:

What types of firearms does the Department of Commerce have jurisdiction over?

The Department of Commerce's Bureau of Industry and Security (BIS) has jurisdiction over shotguns with a barrel length of 18 inches or more and related components. BIS also has jurisdiction over muzzle loading rifles and handguns, air guns, replica firearms, shotgun shells and components, and most optical sighting devices for firearms.
What types of firearms does the Department of State have jurisdiction over?

Department of State�s Directorate of Defense Trade Controls (DDTC) has jurisdiction over defense articles and services. This includes rifles and handguns and certain optical sighting devices. DDTC also has jurisdiction over shotguns under 18 inches in barrel length.
They go on to say that rifle stocks are under the jurisdiction of the Dept. of State (DDTC), which administers ITAR.

There is a provision to request a commodity jurisdiction(CJ) to determine if your goods or service falls under ITAR regulation. Apparently this cannot be filed for a class of items but must be filed for each item.