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Thread: Barrel Threading

  1. #1
    Boolit Master
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    Barrel Threading

    If I had an FFL you can bet your sweet bippy I'd be set up to thread for suppressers in case the tides do change !
    Aaron

  2. #2
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    I agree this service will explode for a year or more for sure
    I carry a Nuke50 because cleaning up the mess is Silly !!

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  3. #3
    Boolit Master





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    Get you 07 Manufacture license first nothing changes there.

  4. #4
    Boolit Master Artful's Avatar
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    And pay your State Dept ITAR fee when you start threading barrels
    je suis charlie

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  5. #5
    Boolit Master
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    Quote Originally Posted by Artful View Post
    And pay your State Dept ITAR fee when you start threading barrels
    ?????

    Unless you are exporting items or you have knowledge that the items will be exported, why would you even worry about ITAR?

  6. #6
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    Because the BATFE mandated that all 07 manufacturers have ITSR regardless if they are making stuff for export.

    On another note, I know a 07 SOT that doesn't pay ITAR and hasn't ever paid.
    He is awaiting the letter any day shutting him down but it never comes.

  7. #7
    Boolit Master
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    Yep, the key word there is EXPORT.

    I have to see anyone convicted for an ITAR violation unless they were engaged in some type of export activity or had knowledge that the item would be exported. Furthermore, the item must be a controlled item on the USML (United States Munitions List) or other wise be a controlled item.

  8. #8
    Boolit Master Artful's Avatar
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    Quote Originally Posted by Petrol & Powder View Post
    ?????

    Unless you are exporting items or you have knowledge that the items will be exported, why would you even worry about ITAR?
    Not been paying attention again - good grief

    http://www.thetruthaboutguns.com/201...iths-business/
    je suis charlie

    It is better to live one day as a LION than a dozen days as a Sheep.

    Thomas Jefferson Quotations:
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  9. #9
    Boolit Master
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    This is the regulation and it does include the practice of manufacturing defense articles but I've yet to see anyone involved in purely domestic gunsmithing convicted of failing to register. :

    (a) Any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, is required to register with the Directorate of Defense Trade Controls under 122.2. For the purpose of this subchapter, engaging in such a business requires only one occasion of manufacturing or exporting or temporarily importing a defense article or furnishing a defense service. A manufacturer who does not engage in exporting must nevertheless register. (See part 129 of this subchapter for requirements for registration of persons who engage in brokering activities.)

    (b) Exemptions. The registration requirements of paragraph (a) of this section do not apply to:

    (1) Officers and employees of the U.S. Government acting in an official capacity;

    (2) Persons whose pertinent business activity is confined to the production of unclassified technical data only;

    (3) Persons all of whose manufacturing and export activities are licensed under the Atomic Energy Act of 1954, as amended; or

    (4) Persons who engage in the fabrication of articles solely for experimental or scientific purposes, including research and development........


    I suppose if a U.S. Attorney really wanted to go after someone for this they could but I've yet to see it happen. Most of the cases that I've read involve large companies exporting war materials, munitions, aircraft parts, etc.

  10. #10
    Boolit Master
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    And of course if I was in the business of threading barrels I might want to scare my potential competitors out of my lucrative niche.

  11. #11
    Boolit Master
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    In theory if a customer takes the gun to say Canada, isn't that export?

  12. #12
    Boolit Master
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    Quote Originally Posted by Minuteshaver View Post
    In theory if a customer takes the gun to say Canada, isn't that export?
    Not per the definition of Export used by ITAR.

  13. #13
    Boolit Master
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    Quote Originally Posted by Minuteshaver View Post
    In theory if a customer takes the gun to say Canada, isn't that export?
    In theory it could be but it would require the gunsmith to have knowledge of that future export.

    The real issue is the definition of "Manufacture". The Obama era executive order that attempted to expand the definition of manufacture to a gunsmith generated a lot of fear but few (if any) prosecutions.

  14. #14
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    Applicability of the ITAR Registration Requirement to Firearms Manufacturers and Gunsmiths Summary:
    The Directorate of Defense Trade Controls (DDTC) has reviewed and consolidated policy guidance about whether various activities related to firearms constitute manufacturing for International Traffic in Arms Regulations (ITAR) (22 CFR Parts 120-130) purposes and require registration with DDTC and payment of a registration fee. DDTC has found that many – but not all - traditional gunsmithing activities do not constitute manufacturing for ITAR purposes and, therefore, do not require registration with DDTC. The following guidance is confined to DDTC’s ITAR implementation. You must also comply with all other relevant laws. Background: The Arms Export Control Act (AECA) (22 U.S.C. 2751 et seq.) and the Gun Control Act (GCA) (18 U.S.C. 921 et seq.) are two distinct U.S. laws that concern manufacturing of firearms. The GCA requires firearm manufacturers to obtain licenses as manufacturers (known as Federal Firearms Licenses (FFLs)) from the Department of Justice’s Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF). The AECA, in relevant part, requires manufacturers of defense articles, including certain firearms, to register with the Department of State, Directorate of Defense Trade Controls. Because the GCA is intended to cover a broader scope of domestic activity than the AECA, the ATF regulations define the term “firearm” more broadly than the ITAR. As a result, not every firearm controlled by the ATF regulations is also controlled by the ITAR. The AECA’s statutory requirement for firearms manufacturers to register with DDTC is implemented in Part 122 of the ITAR: 122.1 Registration requirements. (a) Any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, is required to register with the Directorate of Defense Trade Controls under 122.2. For the purpose of this subchapter, engaging in such a business requires only one occasion of manufacturing or exporting or temporarily importing a defense article or furnishing a defense service. A manufacturer who does not engage in exporting must nevertheless register.
    ITAR registration is required of persons who engage in the business of manufacturing defense articles. Persons who do not actually manufacture ITAR-controlled firearms (including by engaging in the activities described below, which DDTC has found in specific cases to constitute manufacturing) need not register with DDTC – even if they have an FFL from ATF. As indicated above, the requirements for obtaining FFLs under the GCA are separate and distinct from the requirement under the AECA and ITAR to register with DDTC. The term “manufacturing” is not defined in the ITAR. In order to determine whether a firearmsrelated activity constitutes manufacturing for ITAR purposes, DDTC applies the ordinary, contemporary, common meaning of the term. Likewise, DDTC applies the ordinary, contemporary, common meaning for “gunsmithing,” which traditionally has broadly included designing, making, or repairing guns. Not all firearms (as defined by ATF regulation) are “defense articles” under the ITAR, however, and not all activities involving assembly of and repairs to firearms qualify as manufacturing for ITAR purposes. DDTC has found that many traditional gunsmithing activities do not constitute manufacturing for ITAR purposes and, therefore, do not require registration under the ITAR, particularly where such activities do not require cutting, drilling, or machining and do not improve the accuracy, caliber, or operation of the ITAR-controlled firearm beyond its original capabilities. Policy Guidance: The guidance below is limited to domestic (U.S.) activities involving firearms (as defined in Category I(j)(1) of the United States Munitions List (USML) (22 CFR 121.1)) and related ammunition that are .50 caliber (12.7 mm) or smaller - i.e., firearms in Category I, paragraphs (a) and (b), related items in paragraphs (e)-(h), and ammunition in Category III(a) for those firearms. Activities involving items elsewhere on the USML, including Category I, paragraphs (c) and (d), are not included in the scope of this guidance.
    1. Registration not Required – Not Manufacturing: In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is not required because the following activities do not meet the ordinary, contemporary, common meaning of “manufacturing” that DDTC employs in implementing the ITAR and, therefore, do not constitute “manufacturing” for ITAR purposes: a) Occasional assembly of firearm parts and kits that do not require cutting, drilling, or machining;
    b) Firearm repairs involving one-for-one drop-in replacement parts that do not require any cutting, drilling, or machining for installation; c) Repairs involving replacement parts that do not improve the accuracy, caliber, or other aspects of firearm operation;
    d) Hydrographic paint or Cerakote application or bluing treatments for a firearm; 2
    e) Attachment of accessories to a completed firearm without drilling, cutting, or machining—such as attaching a scope, sling, or light to existing mounts or hooks, or attaching a flash suppressor, sound suppressor, muzzle brake, or similar item to a prethreaded muzzle; f) Cosmetic additions and alterations (including engraving) that do not improve the accuracy, caliber, or other aspects of firearm operation beyond its original capabilities;
    g) Machining new dovetails or drilling and tapping new holes for the installation of sights which do not improve the accuracy or operation of the firearm beyond its original capabilities; and h) Manual loading or reloading of ammunition of .50 caliber or smaller. Activities limited to the domestic sale or resale of firearms, the occasional assembly of firearms without drilling, cutting, or machining, and/or specific gunsmithing activities that do not improve the accuracy, caliber, or operations of the firearm beyond its original capabilities (as described above) are not manufacturing within the context of the ITAR. If you are not manufacturing, exporting, temporarily importing or brokering defense articles or services, you are not required to register with DDTC. 2.
    Registration Required – Manufacturing: In response to questions from persons engaged in the business of gunsmithing, DDTC has found in specific cases that ITAR registration is required because the following activities meet the ordinary, contemporary, common meaning of “manufacturing” and, therefore, constitute “manufacturing” for ITAR purposes:
    a) Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms; b) Modifications to a firearm that change round capacity;
    c) The production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors);
    d) The systemized production of ammunition, including the automated loading or reloading of ammunition;
    e) The machining or cutting of firearms, e.g., threading of muzzles or muzzle brake installation requiring machining, that results in an enhanced capability;
    f) Rechambering firearms through machining, cutting, or drilling;
    g) Chambering, cutting, or threading barrel blanks; and h) Blueprinting firearms by machining the barrel
    Last edited by Smoke4320; 07-16-2017 at 07:09 PM.
    I carry a Nuke50 because cleaning up the mess is Silly !!

    http://www.bing.com/search?q=nuke50&...7ADE&FORM=QBLH

    Selling Hi Quality Powdercoating Powder and Sure-Kill deer and cover scents

    PULSAR night vision and thermal dealer !!!
    PM me for a good deal

    I am not crazy my mom had me tested

    Theres a fine line between genius and crazy .. I'm that line
    and depending on the day I might just step over that line !!!

  15. #15
    Boolit Master
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    Smoke 4320, I read the whole thing and it gave me a nauseating head ache that nearly sent me to the ER.
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  16. #16
    Boolit Master
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    The question remains, Have any gunsmiths that hold a manufacturing license but who have not paid the ITAR registration fee been prosecuted for purely domestic activity involving barrel threading?

    I have no doubt that the federal government would love to collect a fee if they can. The Directorate of Defense Trade Control [DDTC] has been given the authority to create regulation related to ITAR but I'm not sure they get to expand the definition of manufacturing. Of course I also don't wish to be the test case and find out. So, I will not be engaged in the business of threading barrels for suppressors.

    I've read cases involving persons exporting items and cases involving foreign nationals on our soil. I'd be interested to see if anyone has been prosecuted for purely domestic activity under ITAR regulations?

  17. #17
    Boolit Master Artful's Avatar
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    And P&P your saying it's not against the law if no one is prosecuted?

    What about the 922R parts when building an imported kit gun?
    Anyone ever arrested for that?

    What about removing the "State Dept Super Secret Squirrel" header on an e-mail and sending it to a private IT server? Anyone arrested for that?
    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."

  18. #18
    Boolit Master
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    No, I'm not saying that it's legal because no one has been arrested or successfully prosecuted for it. I'm saying the regulatory expansion of the definition of Manufacture hasn't been tested in the courts.

    I'm not willing to be that test case.

    If the law passed by Congress had clearly defined what constitutes manufacturing I wouldn't have an argument. The attempt to expand the scope of the law by an executive order or by the action of a regulatory agency doesn't necessarily make it law.
    I think the fact that federal prosecutors haven't attempted to enforce it is a strong sign that they feel the regulation isn't binding on domestic issues or at least they feel the definition is very shaky.

    Regulatory limits get challenged in courts all of the time. Sometimes they are incorporated into case law and sometimes they're not.

    We'll see.

  19. #19
    Boolit Master





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    Quote Originally Posted by Petrol & Powder View Post
    ?????

    Unless you are exporting items or you have knowledge that the items will be exported, why would you even worry about ITAR?
    So you don't go to jail perhaps. Whether you export or not.

  20. #20
    Boolit Master





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    I got lost in the license parts of this thread
    Anybody offering this service,I have a TC Contender barrel that needs to be threaded? I'm wanting to add a muzzle/flash suppressor to my 300 whisper.
    I started out with nothing and I still have most of it left.
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