Starting a casting business/Suggestions needed

[cricco]

Greetings fellow boolit maniacs! I have decided that I am going to venture into casting commercially. Small scale at first. Hopefully it will grow into a profitable business. I have decided that when I do this (soon I hope), I will concentrate on primarily pistol boolits. It's just easier to keep track of for now. I would like to hear from the fine folks on this forum:

1) Would any of you be interested in purchasing boolits from me?

2) Which boolit sizes would be most popular to start with?

3) Are there any specific hard to find, or custom boolits that you would like to see available from me?

Thanks for any input. I would also love to hear from anyone who might have suggestions for me as a newcomer to commercial casting. Thanks folks.

Cricco

[44fanatic]

Go with what is popular and in high demand..... .223/7.62/9mm/45.

Already casting my own for what I have, so wont be purchasing any. Find what has a high demand market and low supply...but expect that market to slow down someday.

[Tazman1602]

Greetings fellow boolit maniacs! I have decided that I am going to venture into casting commercially. Small scale at first. Hopefully it will grow into a profitable business. I have decided that when I do this (soon I hope), I will concentrate on primarily pistol boolits. It's just easier to keep track of for now. I would like to hear from the fine folks on this forum:

1) Would any of you be interested in purchasing boolits from me?

2) Which boolit sizes would be most popular to start with?

3) Are there any specific hard to find, or custom boolits that you would like to see available from me?

Thanks for any input. I would also love to hear from anyone who might have suggestions for me as a newcomer to commercial casting. Thanks folks.

Cricco

Hey Cricco,

Remember man, you are going to have to get an FFL with ammunition manufacturing endorsement, Pay ITAR thier rediculous fee and charge an 11% tax on your bullets (I believe it's 11%). I know it sounds stupid to have to have an FFL to just cast and sell bullets but that's been all covered in this forum somewhere, and as an FFL holder I can tell you this is what was told to me by my friendly neighborhood ATF agent when I asked if I could sell my cast bullets without being considered a manufacturer of ammunition............

Art

[Adam10mm]

1) Would any of you be interested in purchasing boolits from me?
No. I roll my own. Most here do.


2) Which boolit sizes would be most popular to start with?
Well, what market do you want to cater to? Blackpowder? IDPA? Hunting? Revolvers only? Pistols only?


3) Are there any specific hard to find, or custom boolits that you would like to see available from me?
Let me clear one thing up (sorry to sound like a jerk), but custom means "made to order" as in you jot down a design, I get a mold and cast you bullets. That's custom. Custom doesn't mean "hard to find" or "I designed a mold myself".


Thanks for any input. I would also love to hear from anyone who might have suggestions for me as a newcomer to commercial casting. Thanks folks.

Cricco
I've been a commercial ammunition manufacturer and bullet caster for a little over 3 years now. I appreciate your enthusiasm as I shared it when I started. This industry will change you. You will become callus quicker than you would imagine. Don't let yourself get pushed around. Get your business plan down on paper and see to it. Use cash and cash only. Never get a business loan. Starting day one in debt is not a solid plan. Cash is king. If you have to use credit, you can't afford it.

Sell only from stock on hand, take cash only, no checks, no credit cards. More trouble than they are worth. Stay off the goddarn Internet until you can handle the onslaught that will happen.

Crawl, walk, run. Hit your local gun shows. Sell to your local gun shops. Put an ad in the newspaper on rotation. Once you prove yourself in your county, move to take over your state. Once you have your state taken over, start going regional. Once you dabble in two to three states and remain profitable, then maybe it's time to think about getting a website to take orders. Nothing wrong with having a website to showcase your products and prices, but listen to me on this: do not take mail orders until you are good and ready. I mean at least a year in business and being profitable. Then keep your prices the same, make it your cash price, credit cards are 3% on top of that.

Mail order should be bulk only. None of this 50 or 100 ****. 500 absolute minimum, 1,000 is better. The time and hassle it takes to box and ship orders isn't worth the time for small orders. Ideally, you should ship by the pallet to gun shops and ranges. If you have to take time to pack it up, you better be making money at it.

Bullet casting is a hard business people don't seem to realize until they are neck deep in it and want out. Few make it long term. It isn't luck. The French word for "luck" is chance. Success is preparation meets opportunity. Be prepared for an opportunity and exploit it when it comes along. You will probably be successful or lose your butt. That's the risk of business.

[MT Gianni]

Imo a web or night classes in business bookkeeping, fundamentals and planning would be a good first step.
An employer once asked me what I thought was the most important thing to do in running a plumbing business. I was an apprentice and dad had run a sewer and drain cleaning business for 10+ years. I replied that you needed to do good quality work with repeat customers. He said I was wrong, that you needed to bill accurately, collect it on time and pay your suppliers on time to get all discounts applicable. Plenty of people have done it my way and gone broke. I have considered that statement many times over the last 30 years.

[cajun shooter]

I don't want to bust your bubble but in my 63 years on this terra firma I've seen a lot of casters come and go . I myself started such a business in the late 70's early 80's and lost my butt. I have two friends who are sitting on some very expensive Magma machines gathering dust as we speak. I live in an area that has over 1 million people so it's not for lack of bodies to purchase. You will notice that such bullet companies that survive only sell bullets of high BHN. That is not always good for the shooter but good for the caster. You can't have 10 customers and make 10 different alloys to cater to the wants of them. Perhaps it would do you good to go to your local college and find materials and listen in on some ideas about starting a business. The one big thing that I found out that hurt me is that people who profess to be your friend will buy from some one else that sells for a dollar less.

[mtgrs737]

Small businesses are often more work than most want to tackle, they are not a 8 to 5 type of job and have very little benefits that you don't pay for. If you are a hard worker and able to do most all tasks yourself then you might do well in a small bullet making business, but everything changes fast once you hire the first full time worker! Cajun Shooter is correct about "friends" abandoning you for a dollar savings! LOL! Good luck!

[qajaq59]

My brother built a very succesful company and he once told me that the secret to success was his company was the most important thing he did. Far more then vacations, hunting trips or whatever. I'd keep that in mind before you start.

[sturf]

The first thing you need is an FFL. You have to have one to sell boolits for profit.

[cricco]

The first thing you need is an FFL. You have to have one to sell boolits for profit.

I just got off the phone with A woman from the BATFE in Connecticut. She informed me that an FFL is NOT needed for commercial sales of boolits. She also stated that cast boolits do NOT fit the BATFE definition for "ammunition". She also said "If we regulated that, then we would have to go after everyone who makes fishing sinkers". So, there ya have it. From the BATFE.

[oldUSMCsgt]

I just got off the phone with A woman from the BATFE ... So, there ya have it. From the BATFE.

I suggest getting it in writing. I've heard of ppls that have been told things by the IRS that weren't particularly accurate.

[Adam10mm]

I just got off the phone with A woman from the BATFE in Connecticut. She informed me that an FFL is NOT needed for commercial sales of boolits. She also stated that cast boolits do NOT fit the BATFE definition for "ammunition". She also said "If we regulated that, then we would have to go after everyone who makes fishing sinkers". So, there ya have it. From the BATFE.
One hand doesn't know what the other does. Here is the actual statute, which is from the Gun Control Act of 1968, which the ATF enforces. The woman you spoke to is a complete idiot.


Ammunition. Ammunition or cartridge cases, primers, bullets, or propellent powder designed for use in any firearm other than an antique firearm. The term shall not include (a) any shotgun shot or pellet not designed for use as the single, complete projectile load for one shotgun hull or casing, nor (b) any unloaded, non-metallic shotgun hull or casing not having a primer.

Ammunition includes components such as bullets, cases, primers, and powder. If you make any of these you need an 06 FFL. Period. No argument.

The reason the ATF cannot go after people that sell fishing sinkers is that they are not a bullet "designed for use in any firearm".

The ignorance of that woman is dumbfounding. I would love to know what office you called and whom you spoke with. I want to talk to this airhead myself.

She is correct that you do not need an FFL to SELL bullets but but she is dead wrong regarding cast bullets not being "considered" bullets. You sure do need one to MAKE them and that includes any manufacturing method be it cast, swaged, or turned on a lathe, for examples.

[44fanatic]

When talking to an individual at a large agency, take into consideration that they are not knowledgeable on all aspects of their organization.

An agent enforces/investigates the laws. They do not know everything about the law.

Lawyers are very knowledable on law, yet they have to do research for a case and they may put a team together so that individuals can pursue different aspects of the law.

From one source of information, you may obtain very little information. Updates may have been added at a later time that not everyone is familiar with. Additonally, one source of information may contradict another source of legit information.

Seen it....Done it.

[qajaq59]

If you don't have it in writing on the BATF letterhead then you don't have an answer.

[Rocky Raab]

Still enthused?

[Adam10mm]

When talking to an individual at a large agency, take into consideration that they are not knowledgeable on all aspects of their organization.

An agent enforces/investigates the laws. They do not know everything about the law.

Correct. In the ATF there are two distinct jobs titles. Agent and investigator. An agent is trained and authorized to carry a firearm, make an arrest, and transport prisoners to the prison or to US Marshals. An investigator is not authorized to carry a firearm, has absolutely no authority to arrest, and cannot ever transport a federal prisoner. An investigator is who deals with FFLs. Think of them as accountants because that's pretty much what they do. If an arrest is to be made, the agents do it, not the investigators.

[RodneyUSAF]

One hand doesn't know what the other does. Here is the actual statute, which is from the Gun Control Act of 1968, which the ATF enforces. The woman you spoke to is a complete idiot.



Ammunition includes components such as bullets, cases, primers, and powder. If you make any of these you need an 06 FFL. Period. No argument.

The reason the ATF cannot go after people that sell fishing sinkers is that they are not a bullet "designed for use in any firearm".

The ignorance of that woman is dumbfounding. I would love to know what office you called and whom you spoke with. I want to talk to this airhead myself.

She is correct that you do not need an FFL to SELL bullets but but she is dead wrong regarding cast bullets not being "considered" bullets. You sure do need one to MAKE them and that includes any manufacturing method be it cast, swaged, or turned on a lathe, for examples.

Does this mean that casting boolits in your garage is technically illegal without an FFL? What is the number of boolits that puts a person in the realm of "manufacturing".

[qajaq59]

Does this mean that casting boolits in your garage is technically illegal without an FFL? What is the number of boolits that puts a person in the realm of "manufacturing". It is not the casting that requires an FFL. It is the "selling".

[Tazman1602]

I just got off the phone with A woman from the BATFE in Connecticut. She informed me that an FFL is NOT needed for commercial sales of boolits. She also stated that cast boolits do NOT fit the BATFE definition for "ammunition". She also said "If we regulated that, then we would have to go after everyone who makes fishing sinkers". So, there ya have it. From the BATFE.

You better get that in WRITING because I have it in writing somewhere from my friendly neighborhood ATF agent that if you are engaged in the BUSINESS of selling bullets and bullets alone you NEED an FFL manufacturing, you NEED to comply with ITAR, and you NEED to charge their outrageous tax.

Not trying to mess with you man, just don't want you to get into trouble. I didn't believe this either when I first ran into it......

Art

[Tazman1602]

It is not the casting that requires an FFL. It is the "selling".

+1 Right on the money.......................

[Wayne Smith]

... and I believe, but do not know, that it is the completed ammunition that requires the Federal Excise Tax, not the components. If you reload for others with an FFL06 and use their brass you don't charge the tax, if you use new brass you do.

I believe that if you only sell boolits you need the FFL06 but do not need to collect the excise tax.

[Adam10mm]

Does this mean that casting boolits in your garage is technically illegal without an FFL?
Of course not neither is handloading your own ammunition. The FFL is a business license. If you cast bullets for personal, non-commercial use there is no FFL needed. No FFL is ever needed for personal purposes and certainly not issued for such (exception the C&R).


What is the number of boolits that puts a person in the realm of "manufacturing".
One single bullet manufactured for the use in ammunition for firearms as a regular course of business and profit. It is not so much that you actually made profit, as a sale, trade, barter, or consideration (is the legal term) will indicate you made an attempt at profit. Also if you make one single bullet for business use et al, you must register for ITAR and pay the $2250 fee to the US State Department since you manufactured a defensive article.

[Adam10mm]

... and I believe, but do not know, that it is the completed ammunition that requires the Federal Excise Tax, not the components. If you reload for others with an FFL06 and use their brass you don't charge the tax, if you use new brass you do.
Correct. Complete loaded ammunition has excise tax due. If you reload the customer brass, their exact brass, give it back to them as ammo, no excise tax is due. If the company (the 06 FFL holder) provides or sources brass, excise tax is due. Local government agencies are exempt from FET and only the Dept of Defense, including the US Coast Guard, is exempt also. All federal LE agencies are NOT TAX EXEMPT FROM FET.

[b]I believe that if you only sell boolits you need the FFL06 but do not need to collect the excise tax.[/QUOTE]
Correct. The FET is due on complete ammunition, not components.

[Adam10mm]

Not trying to mess with you man, just don't want you to get into trouble. I didn't believe this either when I first ran into it......

Art
And even after living this nightmare for three years I still get people who try to tell me I don't know what I'm talking about.:groner:

[Tazman1602]

And even after living this nightmare for three years I still get people who try to tell me I don't know what I'm talking about.:groner:

I also freak, I think some people just don't WANT to believe but those are the FACTS.....

Art

[fredj338]

Like Freak, I had a ammo/bullet business back when CAS shooting started. I pretty much just did lead cowboy ammo. It's a lot of work for very little profit margin & that was when lead alloy was cheap & pimers were available. It would be a nice part time business for a retired guy, but you will spend a ton of time for littel financial gain. Your initial upfornt cost for equip & alloy will set you back several $1000, before you sell a single bullet.

[Adam10mm]

I also freak, I think some people just don't WANT to believe but those are the FACTS.....

Art
Yup, because, of course I'm only 28 years old so what do I know? LOL

[Recluse]

Greetings fellow boolit maniacs! I have decided that I am going to venture into casting commercially. I would like to hear from the fine folks on this forum I would also love to hear from anyone who might have suggestions for me as a newcomer to commercial casting. Thanks folks.

Cricco

I would rather pound my wee-wee with a meat-tenderizing hammer, soak it in au-jus then dangle it in the middle of a pack of crazed and starving pit bulls than get into the commercial casting business.

The fact that you're here and asking the questions you're asking indicate that you haven't done your homework.

I volunteer with SCORE (Service Core Of Retired Executives) and have seen many small businesses come and go. The ones that came and stayed are the ones who did their homework and began life cash solvent and with reserves to handle payroll, inventory purchasing, rent, insurance and intangibles for a minimum of twelve months.

In THIS economy with THIS bunch of incompetent bozos running the country (into the ground, mind you), I strongly suggest to up & comers to make that eighteen months, with twenty-four being even better.

Starting and successfully operating/building your own business has never been easy, but it has also NEVER been as difficult as it is today. There are a myriad of laws, rules, regulations, permits, fees, ordinances, taxes, etc etc to consider.

The fact that you don't even know the law in regards to what you will need in terms of what type of FFL speaks hugely.

The fact that you're here on the world's pre-eminent bullet-casting website, asking us if we would buy from you speaks to your naiveté and ill-preparedness. Why should I buy from you? Why? I'm HERE because I cast my own, not because I want to buy from someone I've never heard of, has no reputation, no experience, etc etc.

Harsh? You betcha.

But you haven't seen harsh until you've seen the inside of a U.S. Bankruptcy Courtroom. If your dreams begin with the SBA, then they end with the USBC hearings.

And as a volunteer with the SBA, I can speak with authority and experience in saying that just from what you've posted here, you ain't gonna make it in the commercial casting biz.

• Where's your lead supply?

• How much lead do you have? Have access to?

• Who is your backup and third/fourth/fifth tier supply side providers for lead?

• Lube? Your own, commercially produced or what?

• What kind of lubesizer will you use? Remember, we're talking volume output and every bullet has to be perfect.

• Labels? Logo? Branding? Marketing? Or are you going to simply rely upon word-of-mouth? If so, do remember that word-of-mouth is totally beyond your control and can be used just as easily to spread the message how lousy your product is as well as how great it is. Truth has no say in word-of-mouth--it's all about perception versus reality. So how are you going to control the message about you, your brand and your product?

• Have you got all your permits and fees and EPA concerns addressed? After all, you are dealing with a hazardous substance now for the purposes of producing a product for profitable re-sell.

And on and on and on.

Tough questions, but being a business owner is a tough challenge. Launching a start-up in today's business climate and economy is even tougher.

:coffee:

[cricco]

Jeebus Cripes guys. I asked a few questions, and now I feel like I've been assaulted by the boolit Nazis! I would like to address a few things here:
1) I never said I was going to sell everything I own and quit my job to finance a full-time casting operation. My intent is to start a small scale, part-time business.
2) I am already president of my own corporation.
3) I fully intend to get something in writing from the BATFE, however, the way some folks are blasting me for not believing some anonymous folks on the interwebs over a BATFE industry operations Field Officer is a bit astonishing.

Relax guys. This is supposed to be an enjoyable hobby. If I can make a few bucks or even break even doing something I love, then why shouldn't I?

[Tazman1602]

Jeebus Cripes guys. I asked a few questions, and now I feel like I've been assaulted by the boolit Nazis! I would like to address a few things here:
1) I never said I was going to sell everything I own and quit my job to finance a full-time casting operation. My intent is to start a small scale, part-time business.
2) I am already president of my own corporation.
3) I fully intend to get something in writing from the BATFE, however, the way some folks are blasting me for not believing some anonymous folks on the interwebs over a BATFE industry operations Field Officer is a bit astonishing.

Relax guys. This is supposed to be an enjoyable hobby. If I can make a few bucks or even break even doing something I love, then why shouldn't I?

Hey Cricco,

Don't take Recluse personally man, he states that he is an ill-tempered Texan and he just states it like it is, he didn't mean any personal insult, on the other hand he's trying to keep you from getting into the trouble we've seen other guys get into.

If you've got the disposable cash to get into doing this, and it's something you want and love to do, AND you get the REQUIRED FFL's and ITAR documents in place there's not a one of us that doesn't want to see you make it.

As a small business owner I have to tell you Recluse's advice is priceless. I don't have a huge business but it's growing -- and it's growing at a rate I can handle and it's going to stay that way.

We know guys on this forum that have done the same thing you're doing and some of them have lost homes, wives, and familys due to the amount of debt they piled up because of lack of planning.

We WANT to see you make it. We DON'T WANT to see you go broke is all................

Respects,

Art

[wmitty]

RECLUSE

Thanks for your honest and blunt warning regarding this business venture. I am

seriously reconsidering retiring as soon as I'm eligible. Owning one's own business

looks like serious work... perhaps remaining with my present job and keeping the

hobby just a hobby is the wise way to go.

[snuffy]

Here's somebody that's living his dream of providing boolits to the masses. It LOOKS like Brad's making a go of it. At least he keeps buying new magma casting machines to keep up with demand.

http://www.missouribullet.com/

He's a frequent poster over on THR, has a 5% discount for members on that forum. He also has direct sales to a major shooting/reloading supply house, IIRC it's Grafs.

Cricco, if what you're proposing doing is using manual molds, even 6 cavity molds will be very labor intensive. A great way to make an enjoyable hobby into a dreaded task.

[cricco]

Cricco, if what you're proposing doing is using manual molds, even 6 cavity molds will be very labor intensive. A great way to make an enjoyable hobby into a dreaded task.

I am hoping to purchase a Magma machine. I found a very good deal on a Mark VII machine, and I'm trying to hash out the logistics of getting it here from across the Atlantic.

[Recluse]

RECLUSE

Thanks for your honest and blunt warning regarding this business venture. I am

seriously reconsidering retiring as soon as I'm eligible. Owning one's own business

looks like serious work... perhaps remaining with my present job and keeping the

hobby just a hobby is the wise way to go.

I've had so many people tell me I should just get my commercial rating and start charging people to fly them places the airliners and commuters won't.

No way. Not even for discussion.

The minute I HAVE to start doing something, it is no longer a hobby or enjoyable past time. It is a job. And I already have one of those.

There is a difference between casting a boat load of boolits and then maybe auctioning them off on Gunbay or whatever it is, or listing them on the For Sale boards at other websites. . . and investing in equipment and mass-production molds, sizers, etc etc and selling on demand to the masses.

Not saying one is better than the other, just saying that one bloody well needs to know exactly what they are getting into. Used to be that starting up a business wasn't too bad and you could find some forgiveness now and then.

No longer. It is as vicious a thing as there is thanks to the hostile environment the government has created. Any competitor can call and make anonymous OSHA or EPA complaints on you--legitimate or not--and you have to fork over your dollars to defend yourself. Thanks to whistleblower laws, you can't even find out who the SOB is that filed the bogus complaint in order to sue them.

Late on your sale taxes? Bend over and take a deep breath because here it comes.

Whizz off a customer? Get ready to see your name slandered on dozens upon dozens of websites like Ripoff.com and others. Almost no way you can keep up with them all.

God help you if someone's gun blows up or goes kaboom and has one of your bullets in it. Get ready to be part of the lawsuit. YOU have to prove you did nothing wrong, not the other way around.

Just ain't worth it to me. Not making bullets or components. High volume, high labor, low yield (profit). Some folks do it, however. . .

:coffee:

[bearcove]

I agree with Recluse, selling ammo or components of your manufacture is a road full of potholes.

I'm in the pipe business, pipefitting, plumbing, gasfitting that stuff has a good profit margin. I'm slowly getting set up to start my business. But I have 20+ yrs experience, my tools, and a good financial standing to start from.

Cast some boolits and go shoot them. Share with your friends...

Sell for profit, I wish you luck.

Its the profit part that will be tough.

[S.R.Custom]

It is not the casting that requires an FFL. It is the "selling".


As a type 07 manufacturer FFL holder, let me clarify things a bit:

1. You do NOT need an FFL to manufacture boolits for your own personal use.
2. You do NOT need an FFL to sell boolits (or ammunition, for that matter) provided someone else did the manufacturing.
3. You DO, however, need an FFL (either an 06 or 07) to manufacture boolits with the intent to sell for profit, whether that sale be wholesale or retail.
4. FAET (Federal Ammunition Excise Tax) is only due on completed ammunition. Unassembled components are not subject to said tax.

So cricco, what the ATF lady told you is technically correct; you do not need an FFL to (merely) sell boolits. You do, however need one to manufacture and sell them.

I suggest you order ATF publication 5300.4, the "Federal Firearms Regulations Reference Guide." That tome has all the answers. The federal ones, anyway. Since you're in New England, however, God help you with the local bureaucrats and the tribute they demand.


...Also if you make one single bullet for business use et al, you must register for ITAR and pay the $2250 fee to the US State Department since you manufactured a defensive article.

Only if you import or export that bullet.

[kentuckycajun]

Jeebus Cripes guys. I asked a few questions, and now I feel like I've been assaulted by the boolit Nazis! I would like to address a few things here:
1) I never said I was going to sell everything I own and quit my job to finance a full-time casting operation. My intent is to start a small scale, part-time business.
2) I am already president of my own corporation.
3) I fully intend to get something in writing from the BATFE, however, the way some folks are blasting me for not believing some anonymous folks on the interwebs over a BATFE industry operations Field Officer is a bit astonishing.

Relax guys. This is supposed to be an enjoyable hobby. If I can make a few bucks or even break even doing something I love, then why shouldn't I?

No one's telling you to BELIEVE these "anonymous folk" (who probably have more experience than some of the idiots the Feds hire) - they're just warning you to GET IT IN WRITING.
Case in point: I hold a USCG License as a boat captain, which comes up for renewal every five years. Every five years, the rules & requirements change, as well as who is actually "running" things (used to be D.O.T., now it's D.H.S.). Requirements and background checks have gotten more stringent, and at my last renewal, I spoke to half a dozen very "high-ranking and knowledgable" individuals - none of which gave me correct information. If I would have listened to any of these "high-ranking and knowledgable" individuals, I'd still be waiting on my renewal to be processed. Only after talking to the CWO did I find out the ignorance of the others. The rules change faster than the average govt worker can keep up with them, especially with the current administration. Just because this lady works for the govt doesn't mean she's infallible. Some of the posts by these "anonymous folk" were even news to me (I don't profess to know anything about FFL licensing - don't really care cause I'm not in it for profit or resale, just a money-saving hobby). Don't take it so personally - matter of fact, I'd be thanking them for the information and giving you a heads-up on the difficulties you can expect to encounter.

You asked - don't get upset cause you don't like the answer you got.:shock:

And it's not nice to call people "Nazis". 'Specially people who will give you their wealth of a lifetime of experience and information, expecting nothing in return but perhaps a "thank you".

[Frozone]

My suggestion would be the same one you give people who want to start in the SCUBA business -

To make a million dollars, start with 2 million and know when to quit.

[Adam10mm]

Only if you import or export that bullet.
Absolutely false. All manufacturers must register and pay the fee regardless if they import or export. Look it up. Nevermind, I'll do it for you.

Here is a PDF copy of the ITAR section by section for you to download.

http://www.pmddtc.state.gov/regulations_laws/itar_official.html

Here is a text based copy of the ITAR
http://www.fas.org/spp/starwars/offdocs/itar/index.html

Part 122 is the section that deals with manufacturers and exporters.

Direct download link: http://www.pmddtc.state.gov/regulations_laws/documents/official_itar/ITAR_Part_122.pdf

Read this line, emphasis mine.


§ 122.1 -- Registration requirements.

(a) Any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register with the Office of Defense Trade Controls. Manufacturers who do not engage in exporting must nevertheless register.

Before you try to tell me that bullets aren't a "defensive article" as many others have done, I will provide you with this little piece of information which once again proves me right in this matter.


Category III-Ammunition

*(a) Ammunition for the arms in Categories I and II of this section. (See § 121.6.)

(b) Components, parts, accessories, and attachments for articles in paragraph (a) of this category, including but not limited to cartridge cases, powder bags, bullets, jackets, cores, shells (excluding shotgun shells), projectiles, boosters, fuzes and components therefor, primers, and other detonating devices for such ammunition. (See § 121.6.)

(c) Ammunition belting and linking machines.

*(d) Ammunition manufacturing machines and ammunition loading machines (except handloading ones). [such as the Camdex and Ammoload automated machinery. This is why Dillon Precision won't sell a power drive with their presses as they would fall under ITAR then.]

(e) Technical data (as defined in § 120.21 of this subchapter) and defense services (as defined in § 120.8 of this subchapter) directly related to the defense articles enumerated in paragraphs (a) through (d) of this category. (See § 125.4 of this subchapter for exemptions.) Technical data directly related to the manufacture or production of any defense articles enumerated elsewhere in this category that are designated as Significant Military Equipment (SME) shall itself be designated SME.

So it pays to do your research. You being an 07 FFL are a manufacturer. As such you need to register with the US State Department under ITAR no matter if you export or not. Since bullet casting is manufacturing bullets and doing so for resale you will need an 06 or 07 (or 10) FFL and register with ITAR.

[Adam10mm]

Jeebus Cripes guys. I asked a few questions, and now I feel like I've been assaulted by the boolit Nazis! I would like to address a few things here:

1) I never said I was going to sell everything I own and quit my job to finance a full-time casting operation. My intent is to start a small scale, part-time business.
It doesn't matter if you are going to run it part time or full time. Heed the advice given. You are being advised by people who have been in your shoes and have a few years experience in the industry. I wish I had people that told me the things I'm telling you when I wanted to start my business. I would have done it a completely different way and would not be in the mess I'm in right now.


2) I am already president of my own corporation.
That's great. What I see is you have a lot of experience running a business, which is good, but next to no experience casting bullets and doing that part of it. I was/am the opposite. I'm damn good at making ammunition but my business management sucks big time. In my case I should have hired an executive to help manage my business while I did the work. In your case, I'd hire a caster that knows what they are doing while you handle the business aspect of it while learning about casting from them. There is no shame in not knowing, only in not wanting to learn.


3) I fully intend to get something in writing from the BATFE, however, the way some folks are blasting me for not believing some anonymous folks on the interwebs over a BATFE industry operations Field Officer is a bit astonishing.
We aren't trying to blast you, we are trying to help you by providing you with factual information. There are many people here that have experience and credentials despite being a "username on a forum". I have my company listed in my sig line. That's who I am. I have never hid my association with my company even in the chaos I'm dealing with now.[/quote]


Relax guys. This is supposed to be an enjoyable hobby. If I can make a few bucks or even break even doing something I love, then why shouldn't I?
Realize quickly once you do something for money, the rules change. That's all we are saying. Casual side business quickly turn into a chore. We are trying to let you know what you are getting yourself into.

[felix]

Never convert a hobby into a business! It's OK to convert a business into a hobby. Talking successful odds here, nothing else. ... felix

[S.R.Custom]

Absolutely false. All manufacturers must register and pay the fee regardless if they import or export. Look it up. Nevermind, I'll do it for you...

You're missing the major distinction that defines the applicability of this law, specifically, is the purpose of the item in question military or civil? That determination is made by the State Department on a case by case basis (commodity jurisdiction determination, 120.4).

The "manufacturers" to which your citation refers to (that have to register with the State Department) are Type 10 FFL MFRs. That is, those MFRs who manufacture those items as determined by the State Department as having a military purpose. Indeed, type 10 and type 11 FFL holders are specifically required to register with the State Department under ITAR. By definition, type 06 and 07 FFL holders are manufacturers of civil commodities, and specifically exempt.

In other words, you can register with and pay your money to whomever you like. I, on the other hand, will continue to make my custom Blackhawks and cowboy bullets in accordance with the requirements of my 07 FFL until such time as the State Department makes the determination that those items are of a military nature and a strategic concern of the United States. At that point, maybe I'll get my type 10 FFL and register with the State Department.

[Adam10mm]

You're missing the major distinction that defines the applicability of this law, specifically, is the purpose of the item in question military or civil? That determination is made by the State Department on a case by case basis (commodity jurisdiction determination, 120.4).
Which you have to do in order to not register legally. You just can't make up your mind for them and not go through the motion. You need to submit to a commodity jurisdiction determination to determine if you qualify for the exemption.


The "manufacturers" to which your citation refers to (that have to register with the State Department) are Type 10 FFL MFRs. That is, those MFRs who manufacture those items as determined by the State Department as having a military purpose. Indeed, type 10 and type 11 FFL holders are specifically required to register with the State Department under ITAR. By definition, type 06 and 07 FFL holders are manufacturers of civil commodities, and specifically exempt.
No, you are dead wrong. I suggest you sit down and read the ITAR real good with an attorney that can talk some sense into you. The type of FFL does not mean a pinch of ****. It applies to all manufacturers, including manufacturers of items not requiring an FFL. A type 06 and type 07 FFL are not bound to civilian manufacture only. You have no clue what you are talking about. As a type 07 FFL I can manufacture items for anyone I choose be it a civilian, government agency, or military. A type 10 FFL is a manufacturer of destructive devices. They can make them for a civilian, government agency, or military.


In other words, you can register with and pay your money to whomever you like. I, on the other hand, will continue to make my custom Blackhawks and cowboy bullets in accordance with the requirements of my 07 FFL until such time as the State Department makes the determination that those items are of a military nature and a strategic concern of the United States. At that point, maybe I'll get my type 10 FFL and register with the State Department.
See, you're missing the point. You as a manufacturer need to register. If your item is exempt from such because of predominant civilian use, you need to submit a commodities jurisdiction for an official determination. Just because your product or service may quality under this doesn't mean it's not automatically exempt. You have to prove it to the State Department for your registration to be waived.

[deltaenterprizes]

Freakshow, there is a difference between "sporting" and "military" arms and ammunition. That is why certain guns are not allowed to be imported, they do not meet the "sporting" definition ATF has put in place. I would venture that one characteristic of "military" vs "sporting" ammunition would be brass cases with crimped primers and sealed FMJ bullets in calibers in common use for military firearms such as 9MM, 5.56NATO, 7.62NATO, 7.62x39 etc. It would be kind of hard to fight a war with arms chambered for 6PPC, 222 Remington, 22LR, 25 ACP etc., that is why these meet the "sporting" definition.

[Adam10mm]

I would venture that one characteristic of "military" vs "sporting" ammunition would be brass cases with crimped primers and sealed FMJ bullets in calibers in common use for military firearms such as 9MM, 5.56NATO, 7.62NATO, 7.62x39 etc. It would be kind of hard to fight a war with arms chambered for 6PPC, 222 Remington, 22LR, 25 ACP etc., that is why these meet the "sporting" definition.
What you fail to realize is the ITAR does not differentiate between "sporting" and "military" calibers or cartridges. If it is .50 caliber or smaller, it comes under control of ITAR regulations.

What you also fail to realize is the ITAR's only mention of a "sporting use" is for "sporting shotguns". They have always been exempt from ITAR due to Olympic Games issues. Their manufacture, import, and export have always been left alone. Beyond "sporting shotguns" ITAR does not recognize mention anything "sporting" with regards to determination of whether an item is a defensive article or not.

If you manufacture 2mm pinfire ammunition, of which has never been used in any military capacity nor designed for such, you would be required to register with ITAR. It's that simple.

It doesn't matter what ammunition you manufacture, the simple fact that you have manufactured one single round of ammunition means you must register with the US State Department under ITAR. One occurence of manufacturing is the threshold to be registered for ITAR. It doesn't matter if you are an 01 dealer that manufactured the single and sole firearm the ATF allows per year without being a licensed firearm manufacturer. If you make one of anything, you need to be registered as a manufacturer. Again, it's that simple.

I have been down this road and speak from actual, personal experience as the founder of an 07 FFL Class 2 SOT firearm, NFA weapon, and ammunition manufacturer. I've been down this road with my company's manufacture of machine guns, silencers, cast bullets, and ammunition. I doubt anyone on this forum has gone through as much as I have with regards to ITAR. That being said, if you guys want to play expert, go ahead. I'm done giving advice based on facts.


:coffeecom

[felix]

Business questions should be addressed to a "business" board. This is a cast boolits board. As a businessman, you must not EXPECT expert answers from anyone on this board. Opinions, yes, but not advice you can take to the bank. You need to be talking to a lawyer having experience in all areas of your endeavor. Just why would you think otherwise given the proof of your entanglements? Besides, "freakshow" is not a very appropriate business name. ... felix

[Adam10mm]

Besides, "freakshow" is not a very appropriate business name. ... felix
I didn't pick the name to cater to soft men.

[cricco]

Wow. Now I don't feel so bad. Board members scold me for believing the "stupid BATFE agent", and then preceed to argue among themselves. Now you can see a bit of what I am going through. I do appreciate all of the advice, however, I am going to ask the BATFE to clarify for me, in writing, exactly what I need to manufacture cast boolits.

[cricco]

Update:
After reading the ITAR guidelines, it appears that this applies ONLY to those who will export items. My intent is NOT to export, so I don't think ITAR applies to me.

[Avery Arms]

(a) Any person who engages in the United States in the business of either manufacturing or exporting defense articles or furnishing defense services is required to register with the Office of Defense Trade Controls. Manufacturers who do not engage in exporting must nevertheless register.

Ammunition components (casing, primer, powder, bullet) are defense articles for the purpose of this law. Darned near anything that relates to firearms is regulated under ITAR unless specifically exempted. There was a small company making moon clips for revolvers that got in trouble for non-registration even though they never exported and no military would ever dream of using their products. There is nothing sensible, just or moral about these laws it's just a greedy US dept of state which doesn't care who they put out of business.

The ATF will not allow you to operate unless you abide by all federal, state, county and city laws. Get a written letter of approval from your county/city zoning boards and your landlord (if renting) before you even talk to the feds.

Your post makes about as much sense as:


I'm in 9th grade. I've decided to become a surgeon. Hoping to start with small surgeries. Would any of you let me practice on you? What kind of surgery is most popular? Are there any specific hard to find, or custom surgical procedures I can pioneer with your unlucky backside?

Then our fictional high school student proceeds to argue with a board certified surgeon about the basic state requirements. He gets angry when the surgeon bluntly tells him his plan is foolhardy.


PP

[sturf]

CRICCO, you will find that anytime you try to help someone on this board; there is almost always some D%#@head that thinks he knows everything that will come on with an attitude and try to cut you off at the knees. Usually he dosn't know what he is talking about. This time others did. I have been casting for over 45 years; shooting in competition for 39 years with the N-SSA and the Cast Bullet Assoc. and the NRA. Have been an FFL holder and a gunsmith. I think I know a little bit. Thats why I have just about stopped posting here and will probably completly quit now. Ban me if you want; but I got it out. Rant over.

[sundog]

wow, talk about attitude. advice is worth what you pay for it - sometimes...

[cricco]

Guys, I'm sorry I ever posted this thread. One of the things I love about this forum is that folks here are very caring, willing to help, and generally just good natured. This thread has brought out the bad side of some people, and I don't like it. Mods, could we either lock this thread, or delete it? Thanks, and sorry I started all of this.