State Dept. Cracks Down on Moon Clips
by Dave Workman
Senior Editor
Gun accessories manufacturer Steven Crawford has a problem, and anyone familiar with revolvers designed to chamber rimless pistol cartridges may find his sad tale simply astonishing.
Crawford is apparently in trouble with the US Department of State for manufacturing, and offering for export, moon clips—the thin, flat accessory into which rimless pistol cartridges are clipped so they may be used in revolvers. Even that isn’t quite accurate, because not all of the moon clips he produces under the Ranch Products banner are considered taboo, just some of them. All of this leaves Crawford scratching his head nervously, and his moon clips classified as “munitions” under the State Department’s International Traffic in Arms Regulations (ITAR).
Topping off his woes, Crawford fears the State Department could actually declare him to have been out of compliance with the regulation since Ranch Products first began stamping out the innocuous metal cartridge clips, and that was way back in 1975. If that is the case, the agency could assess his company for “unpaid fees” dating back over 25 years.
Crawford’s problem with the State Department began in July of last year when the agency’s Office of Defense Trade Controls notified Ranch Products by mail that, “This office has reason to believe that Ranch Products is involved in the manufacture and/or exporting of defense articles.” What led that office to reach its conclusion was a visit to the Ranch Products website.
In the July letter signed by Delores T. Kinard for Branch Chief Deborah Carroll, Crawford was warned, “The failure of manufacturers and/or exporters to register and maintain their registrations with this office constitutes a violation of the Arms Export Control Act and the International Traffic in Arms Regulations and could result in criminal penalties of 10 years imprisonment and/or $1,000,000 in fine plus administrative penalties of $500,000. It is recommended that your firm register immediately.”
Crawford quickly fired off a reply to Carroll, noting, “As far as Ranch Products can determine, none of our civilian after-market loading tools, accessories, or cleaning/disassembly items have any connection or use with defense articles or defense services.”
Kinard responded to that letter, advising Crawford that, “I would advise that products manufactured and/or exported do not have to be be Significant Military Equipment to require registration and licensing. Accordingly, this office still strongly believes that registration is required and recommends that Ranch Products register immediately.”
Gun Week’s calls to the State Department were not returned by press time.
Ranch Products is based in Malinta, OH. Since 1975, the company has produced a full selection of moon clips for 9mm, 10mm, .45 ACP and .38/.357-caliber revolvers. Moon clips have been around since early in the last century, when they were used to adapt large-frame Colt and Smith & Wesson Model 1917 revolvers to accept .45 ACP cartridges. The company also produces a line of specialty loading and unloading tools, a complete selection of magazine releases for Ruger firearms, slide releases for Glock pistols, and specialty scope mounts for Ruger 10/22, Mini-14 and Mini-30 rifles, plus Mauser and SKS rifles.
According to a letter sent to Crawford by the State Department’s Carol B. Basden, Ranch Products’ moon clips, extended releases and scope mount bases are “subject to the licensing jurisdiction of the Department of State. . . .” The letter also stated that, “The items are designated as defense articles under Category I(h) of the United States Munitions List.”
When Gun Week checked the Munitions List on the State Department’s website, Category I(h) was listed only on a somewhat obscure link to the Federal Register. It was apparently added as an amendment to the List in April of last year. That subsection specifically refers to “Components, parts, accessories and attachments for. . .” arms as defined in earlier subsections. Included in those definitions are “firearms or other weapons . . . having a special military application regardless of caliber.”
The .45 ACP moon clips were originally designed to fit Model 1917 revolvers, which were military handguns early in the last century.
Crawford told Gun Week that he had sent the State Department nine copies of a nine-page report—apparently as required by the agency—explaining exactly what his products are, along with samples. Enroute, he said, the US Postal Service irradiated the package to check it for anthrax. He sent this “request for commodity jurisdiction determination” on Sept. 30, 2002. He did not get a reply until Jan. 22 of this year.
Under the State Department guidelines, according to Basden’s letter, Ranch Products needs to register with that agency under the tenets of the Arms Export Control Act and ITAR, which requires such registration of “anyone who engages . . . in the business of either manufacturing or exporting defense articles. . . .”
Ranch Products offers these moon clips and other accessories for international sale. This is where their products fall under the State Department’s jurisdiction.
Crawford contended that the term “accessories” is “very loosely defined” by the State Department. Curiously, the agency does not require licensing of loading tools for .22-caliber pistols and an unloading tool for the removal of empty cartridges from moon clips, explaining that “These accessories do not enhance the usefulness, effectiveness, or capabilities of the firearm.”
Evidently, the agency is only concerned with accessories or after-market parts that may be “critical to the proper functioning/operation of the firearm.”
Crawford has contacted attorney Stephen Halbrook at the suggestion of the National Rifle Association in an effort to straighten out this problem.