Registration with department of state to sell a few projectiles?

[aaronraad]

OK, holy **** there is a lot of misinformation in this thread. Let me clear things up with facts.

An FFL is only required if you sell bullets you manufactured. If you buy and sell Winchester, Federal, etc there is no FFL required.

If you manufacture anything on the Munitions List that are Defensive Articles under ITAR, you must register as a manufacturer. It doesn't matter if you export or not, it doesn't matter if you make anything for the military or not, if it's on the list and you manufacture it, you must register. It's not a license or permit, it's a registration. The purpose of mandating the registration of all manufacturers is the government wants to know who is manufacturing these items in case they are eventually exported or used by a non-civilian entity.

There are a few very strict exemptions to ITAR that apply to the firearms industry. "Sporting shotgun and sporting shotgun ammunition" and research and development. The US State department is no longer approving commodities jurisdiction so don't waste your time trying to convince the State Department that cast bullets aren't a defensive article subject to ITAR registration. They will deny it and continue to deny it.

For the doubting Thomas' among us, here is the law for you to read yourself:

http://pmddtc.state.gov/regulations_..._official.html

I don't think there is any doubt as to the purpose of the ITAR's given their reaction to breaches. Not so many countries are so understanding about acts of treason. It's interesting they have one standard for the government and another for business or individuals. I guess Fox News Channel are the only ones that have to worry about Ollie now?

[Adam10mm]

Surely a risk based type cost system would be more beneficial to all parties. Simialar to what they do for business that pose an environmental risk and require a permit.

Example - based on projectiles sold/year 0-1000lbs $50/yr; 1000-5000lbs $250/yr; +5000lbs $2,500/yr.

Not sure about the weights but I think you get the idea.

I always get strange looks when I suggest starting a custom bullet makers guild or similar in Australia. Obviously the NRA puts a lot of effort into standing up for the big companies in the US. I don't see how the NRA would be too keen on standing up for the small custom manufacturers, given they're taking away sales/$ from the big companies contributing a lot more to the NRA kity.

We don't want the environmentalists to get involved. I like the easy way like for the SOT tax for manufacturers: gross sales more than a half million dollars you pay the full $1,000 annual tax. Less than a half million dollars in gross sales you pay a reduced fee of only $500.

The NRA represents individuals, not businesses. The National Shooting Sports Foundation, NSSF, is the only firearm industry advocate.

[jabilli]

When I first got into casting I bought a bunch of different things with the idea that I could sell/trade ammo... This without licencing is illegal. Unless something has changed recently that I don't know about (which I'm sure is completely possible), selling components is completely legal. I can go as far as taking brass, cleaning it, putting new primers in it, and selling powder and bullets along with it.... As long as they are not complete ready to fire cartridges, you're good to go. You cannot assemble them for the person- So say you want to give someone lessons on reloading- You can give them advice and pointers, but you cannot physically make the ammo for them. Someone please correct me if I am wrong, or if something has happened recently that I'm unaware of.

I don't illegally sell/trade complete cartridges either- Not so much for the "it's illegal" portion of it...It's more of a liability thing. If I sell some ammo that I loaded and for some reason (even if it's not my fault) his barrel blows up...That's going to be MY problem. Nothing I want to deal with, ever.

[Adam10mm]

I can go as far as taking brass, cleaning it, putting new primers in it, and selling powder and bullets along with it.... As long as they are not complete ready to fire cartridges, you're good to go.

What a waste of time. If you're going to sell all four components to someone that has the equipment and time to assemble them, just sell the damn components as components and let the customer do all the work.

If you want to get down to brass tacks, the ATF could opine that cleaning fired brass, depriming, and repriming is a manufacturing process and thus would require you to get an FFL. It happened with refinishing AR lowers, I wouldn't put it past them to start their nonsense with ammo stuff.

[kweidner]

When I first got into casting I bought a bunch of different things with the idea that I could sell/trade ammo... This without licencing is illegal. Unless something has changed recently that I don't know about (which I'm sure is completely possible), selling components is completely legal. I can go as far as taking brass, cleaning it, putting new primers in it, and selling powder and bullets along with it.... As long as they are not complete ready to fire cartridges, you're good to go. You cannot assemble them for the person- So say you want to give someone lessons on reloading- You can give them advice and pointers, but you cannot physically make the ammo for them. Someone please correct me if I am wrong, or if something has happened recently that I'm unaware of.

I don't illegally sell/trade complete cartridges either- Not so much for the "it's illegal" portion of it...It's more of a liability thing. If I sell some ammo that I loaded and for some reason (even if it's not my fault) his barrel blows up...That's going to be MY problem. Nothing I want to deal with, ever.

You need to contact the ATF. YOU MUST HAVE AN FFL even if you are selling just the boolit. You are manufacturing. Different if you are selling something someone else made.

[Adam10mm]

Correct.

[Low Budget Shooter]

I'm thankful for what I've learned here reading this thread. When I read up on this a few years ago, I understood wrongly. I thought that the licensing from ATF and the registration and fee for ITAR was only for manufacturing ammunition, not just projectiles.

[Adam10mm]

According to the Gun Control Act of 1968, the definition of ammunition includes components. This is how they "get" you for needing an ammunition manufacturing FFL to cast bullets and sell them. Many commercial bullet casters are not licensed by the ATF and sure aren't registered with ITAR-they've never heard of it. To the ATF and in statute definition, bullets are ammunition and a manufacturer is held to the same age requirements as firearms: long gun bullets/shot/slugs 18yo and handgun bullets 21yo.

ITAR encompasses a vast array of firearm related articles that require manufacturers to be registered. If you make firearm barrels, you need to be registered. If you make riflescopes, you need to be registered. If you make moon clips or magazines, you need to be registered.

[preachinpilot]

Yep. I was going to do the 06 but with the 07 I can do firearms coating etc. Same cost but more latitude. Still have the ITAR fine. Now to get the casting down. I have all teh permits, licensing(state) done. Now i am learning , waiting for a casting machine and building stock up before i start processing the ATF and State Dept stuff.

[ProfGAB101]

When did this change? When I got my 07 FFL back in the early 90's I was told specifically that cast boolits and projectiles did NOT require an 06 because there was NO FET due, They did say that ITAR would apply and I'm not arguing that.

Powder mfg was regulated under explosives and ITAR
Cartridge brass was under ITAR and had to have the head stamps registered. ( no ffl required for selling bulk brass without additional components.)
Projectiles were under ITAR, but again, unless loaded there was no FET due therefore did not require an FFL, just a biz lic, and ITAR reg.

ATF's whole base of power comes directly from tax law, they were part of the IRS, and moving them to Justice did not really legitimize them.

Edit: I believe I may still have the 89 "Red Book" the ATF agent marked up and highlighted and wrote notes in. I will have to do some digging as that book was replaced by later editions.

[Adam10mm]

When did this change? When I got my 07 FFL back in the early 90's I was told specifically that cast boolits and projectiles did NOT require an 06 because there was NO FET due, They did say that ITAR would apply and I'm not arguing that.

You were told the wrong information. Bullets are ammunition by definition in the GCA of 1968 and it's been that way since 1968.

Projectiles were under ITAR, but again, unless loaded there was no FET due therefore did not require an FFL, just a biz lic, and ITAR reg.

Components (brass, bullets, powder, primers) do not have FET, as FET is only for loaded ammunition. I've posted here and many other forums in the past on this but here it is again: Bullets are ammunition for purposes of the GCA of 1968 which require an 06 (or 07 or 10) type FFL to manufacture. Bullets are not ammunition for purposes of Federal Excise Tax under the Pittman-Robertson Act. FET has no bearing on whether you need an FFL or not. Bullets are ammunition according to the law (GCA 1968) and the law says you need the proper FFL as a manufacturer.

ATF's whole base of power comes directly from tax law, they were part of the IRS, and moving them to Justice did not really legitimize them.

Part of the ATF is still with the Treasury Department. Bush split them up. The enforcement part is DOJ. The revenue part is Treasury. In addition, ATF IOIs (industry operations inspectors) cannot give opinion or help with revenue issues. They can be answered by the TTB (Tax and Trade Bureau). IOIs handle the NFA and GCA. The TTB handles taxes. No one from ATF can advise on ITAR. That's State Dept jurisdiction.

[country gent]

Heres the kicker its not just firearms ammunition thats watched regulated. In the early 80s the little job shop I was working for bought a brand new bridgeport mill with all the bells and whistles, digital readout, key attachment for back of ram, power feeds, vises, rotary tables, ect ect. With this new machine in the paper work was a goverment form to be filled out as to machine and tooling then sent to some goverment agency. Reason being was in National emergency they would know what you were capable of when they took over your shop. With the way things are going with our current leadership Knowing who has the equipment is more important right now.

[Case Stuffer]

I have received PMs here stating that even primed brass is not regulated and can be sold no issues at all.
All of us here have seen post wanting to obtain a few cast bullets to try befre they purchase a mold.

I turned in my Class 06 FFL in the eighties. I have read many post on different forums and have read some of the Official Info posted on the web.
According to post here many of the 1986 rules were repealed.

http://smartgunlaws.org/ammunition-r...olicy-summary/

When socity has advanced(?) to the point that one needs Lawyer to fight a traffic ticket then what does one need to prevent being blind sided by the BATF and their kin?

[Adam10mm]

Yes, if you take brass, prime it it's not manufacturing by definition. However, I wouldn't put it past the ATF to say that even that step of assembling components is a manufacturing process and you need to be an FFL to do it. So far they haven't touched it and it's not regulated. Hopefully it stays that way.

Look at how they screwed over the small refinishing shops by stating them putting finishes on guns for other manufacturers is a manufacturing process and they need to be licensed as manufactures. Also puts them on the radar of ITAR, then they have to keep records and mark the firearms with their information. In order to leave it off, they need to submit a marking variance. That allows the refinishers to do their work and leave the actual manufacturer of the firearm's information on there.

[Adam10mm]

06s don't have to keep records anymore unless it's AP ammo sales. Pretty much besides AP ammo and you can't sell pistol bullets to anyone under 21yo or felons, there isn't regulation of the ammo industry with the ATF.

[Uptickk]

freakshow,

I thought I remember you saying in a post, maybe a while back you could get a commodity jurisdiction request and be exempted if you are just casting boolits with a FFL-06. Just wanted to confirm that it has changed and you can no longer do that.

Thanks

[jaxenro]

I was interested in making and maybe selling muzzleloading bullets only. Still need the license? Muzzleloaders aren't considered firearms by the ATF, no FFL is neded to buy them, so why would muzzleloader bullets be covered?

[w5pv]

If we could get some one with the cajoles in office to undo all laws that were made by mandate. I don't know if it could be done or not but it deems that if it was made by mandate it could be undone by mandate.

[fredj338]

I know everyone hates Obama, but give it a rest. All this **** was in place long before he was elected, and Bush/Chaney didn't do anything to aleviate the situation. from ATF who really cares.

Yeah but he has accelerated every BS agencies agenda. If you voted for PBO, you are a fool, enough said.

[smokeywolf]

One of the things I did not see mentioned is the fact that the more registrations and filings demanded by ATFE, DOJ and all other gov't entities that exist to infringe your Constitutional rights, the more fees and taxes they can extort which is in-turn used to further legislate more of your rights and liberties away from you.

Ironic that we are forced to fund the efforts to strip us of our rights and liberties.

smokeywolf