Replacement - So again, if you're shipping to a class 01 or 03 dealer, what's the problem
First off an 03 is not a dealer. An 03 is a collector and if the item qualifies as a C&R except for a handgun can be shipped to the holder.
CA all handguns C&R or not must go through an 01/07 license.
The new CA regs is no more than a FFL EZ check and no big deal.
My corp. holds a 07 manufacture license and at first we were thinking not shipping to CA anymore, but after talking with several of our big customers decided not to abandon them.
Signing on to the new CA system was a breeze and getting the CA proceed # and letter takes seconds. In fact their system is better than the BATFE FFL EZ check.