We need to start "feeding the pigs".
We need to start "feeding the pigs".
Marty-hiding out in the hills.
What ever you decide, you should call or write your State Reps and both Senators.. Will it do any good, I don't know, but how else will they know whats going on. Explain to them your dilemma.
ITAR is nothing new. They've been requiring it for years. I'm not saying it's right, because it's not. I wish you luck but you will have to pay it if you want to stay in business.
je suis charlie
It is better to live one day as a LION than a dozen days as a Sheep.
Thomas Jefferson Quotations:
"The strongest reason for the people to retain the right to keep and bear arms is, as a last resort, to protect themselves against tyranny in government."
I think the $2500 "fee" is the key item. Now what amounts to about $200 a month tax that only applies to commercial (for resale) production of cast bullets will only really impact the small local suppliers. Not so much the big outfits such as Winchester or Remington. I think it is just as likely that some lobbyist got that added in to help keep down competition from local producers of reloading components as it is to be back door gun control. With modern equipment available for home use and the high demand/price for components selling at the local gun shows or online collectively the small suppliers could easily cost the industry big guys a large chunk of profits.
The fact that you have to be licensed at any production level is just stupid BUT just a person might brew beer at home legally up to a certain quantity as soon as they sell it they become a "Brewer" subject to bunches of red tape and license requirements in an attempt to prevent bad booze getting sold. The number of people that went blind during prohibition from bad booze was staggering so some regulation makes sense, not necessarily the regulations we end up with however.
I think this FFL rule on casting like many rules and laws take a legitimate concern, in this case people who might create ammo for terrorist or rebels groups (think Bay of Pigs) and sell it black market. Take that case and come up with a totally useless rule or law that will supposedly prevent it. When one can without permit or paperwork create the exact same cast bullet if it is not for resale. Do the people that come up with this stuff consider that people casting for evil purposes are not going to get the permits?
I'm with the suggestion of broaden your market, sell enough that the $2500 additional tax (cost) of doing business is more than offset by increased sales. Then buy a bite me tee shirt.
GOOGLE the ITAR requirements. The 2500 a year fee is for exporters. Manufacturers still need a registration for producing"war materiel" . Information is your friend. Find the facts and do what you need to do to comply. Good luck.
Fox
"§ 120.3 Policy on designating and determining
defense articles and services.
An article or service may be designated
or determined in the future to
be a defense article (see § 120.6) or defense
service (see § 120.9) if it:
(a) Is specifically designed, developed,
configured, adapted, or modified
for a military application, and
(i) Does not have predominant civil
applications, and
(ii) Does not have performance equivalent
(defined by form, fit and function)
to those of an article or service
used for civil applications;"
The U.S. Military does not use cast bullets, so I am unsure how it could be construed to fall under their guidelines?
Here it is 10pm and am still researching. I hope it only applies to exporting, which I do none of. I greatly appreciate all the good words. I was thinking about trying to sell some on the web but not sure now. Will keep everyone up to date.
Interesting to note that the ITAR was established in 1976, and underwent a major change in 1999...
As a suggestion, if you do follow through, and do get set up on the web, make note all over the site that your products are "Not for Sale or Use outside of the United States" and make certain not to ship outside the US.
From the quick research I did, cast boolits fall under "ammunition components" on the USML listing as "projectile". No where does it state it must be for Military Use Only.
GRANDPARENTS AGAINST RETINOBLASTOMA, BECAUSE NO CHILD SHOULD HAVE CANCER
Raise a few million bucks and fight ITAR as a violation of our constitution.............
Posted in another thread also. 22 cfr 121.1(f)(1). ammunition
Fox
BP | Bronze Point | IMR | Improved Military Rifle | PTD | Pointed |
BR | Bench Rest | M | Magnum | RN | Round Nose |
BT | Boat Tail | PL | Power-Lokt | SP | Soft Point |
C | Compressed Charge | PR | Primer | SPCL | Soft Point "Core-Lokt" |
HP | Hollow Point | PSPCL | Pointed Soft Point "Core Lokt" | C.O.L. | Cartridge Overall Length |
PSP | Pointed Soft Point | Spz | Spitzer Point | SBT | Spitzer Boat Tail |
LRN | Lead Round Nose | LWC | Lead Wad Cutter | LSWC | Lead Semi Wad Cutter |
GC | Gas Check |