Exporting of firearms...

Mike Bryant

Mike Bryant

Active member
I thought I would pass on an e-mail that I received today from Virginia Thomson at Lilja Rifle Barrels. Virginia had been exporting the few rifles that I had exported in the past several years. This pretty well will end being able to export rifles out of the US as the cost of the export registration has become exorbitant.

Effective immediately. January 29,2009

We just got hit with the renewal of our export registration for this year. Our cost went to $12,000.00.

Yes, that is $12,000.

They are basing the rate on the number of license we obtained last year. We are being charged $2750 plus $250 per license processed. Doesn't matter if a license is for one item or fifty. We are going to have to increase our base license fee to $350 per license to absorb the cost. This is the fee for a license with barrels only on it.

Dan has decided because of the extra cost we will need to discontinue the exporting of completed rifles and actions. The number of licenses we process this year will increase our registration cost for next year. Also because the fee is based on past licenses and the fee can be increased in the future we have got to try to keep the numbers down.

Sorry for the bad news. It is going to hurt all of us.

Regards,
Virginia Thomson
Office Manager
Lilja Precision Rifle Barrels Inc


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BATF and Manufacturing...

Mike:

While building your house there have been a number of changes.

Since last summer the NRA, NSSF, FARA, and BATF through their letters and Bulletins have been notifing licensees that what type 001 FFL have been doing for years now requires a 007 FFL. They also have made it so person(s) and businesses that were not licensed before and now having to become type 007 licensees. If you make barrels, stocks, gun parts (non receivers) and do finishes on guns, the BATF now says you must have a type 007 Manufacture license. Type 007 licensees now have to register with the State Department (see the ITAR regulations). It is quite eye awakening. This has all been slipped in by the BATF as part of their regulatory control not governed by congress.

I talked to a gunsmith in yesterday who does a lot of custom rifles from scratch for sale to his customers. He was a type 001 FFL. He was totally un aware of the changes. I told him he needed to get familiar with the new regulations as the penalties are very severe.

Customers need to know the expenses involved in building custom rifles now. Then maybe they would write letters to their senators and congress. The Firearms Retailers Association says the goverment agenda with firearms and ammunition is the same as the tobbacco industry. Tax them out of business because you can legislate them out of business.

There were four anti gun bill introduced the day before yesterday. The nomination of Eric Holder for Attorney General is going to the senate and he is staunchly apposed to the second ammendment. He wrote the Amicus Brief for the District of Columbia in the Heller case.

I have been told Nancy Peloci is going to introduce a bill to increase the FET Federal Excise Tax on firearms and ammunition by 500% in March 2009. These funds will ot be used as Pittman Roberson Act monies.

Even the shooting community needs to wake up to what is going on.

Nat Lambeth
 
Gunsmiths and dealers in Canada are very aware of how restrictive the U.S. State Department have made it to export anything to do with firearms.

It just seems to get worse every month. Brownell's is unable to export hundreds of small parts and accessories.

...and we can not do a damn thing about it here in Canada. It all U.S. legislation.

How many customers here in Canada want to pay $350 for an export charge on top of the price of a Lilja or any other barrel...

It just plain stupid and the US manufacturers are losing in the end.
 
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Dennis Sorensen said:
How many customers here in Canada want to pay $350 for an export charge on top of the price of a Lilja or any other barrel...

It just plain stupid and the US manufacturers are losing in the end.
Click to expand...

Free Trade, remember now, Free Trade.

NAFTA, GATT, globalization........MMMMMM good!!!
 
There is a new set of definitions !

There is two new letters defining requirements of dealer and manufacturing. These letters are ATF Ruling 2009-1 and 2009-2. I have attached them here as PDF's.

HTH
John aka Bungalow Bill
 

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But there is another can of worms,,,,, It's called ITAR

And I bet it will be used by the new change / hope govt. to kill our industry !

John aka Bungalow Bill
 
To the guys , That are involved in the manufacture of actions/barrels/triggers Etc .. Do you believe that there still will be available someone that will EXPORT these products out of your country????.. In Australia at present with the AU dollar riding poorly against the US one ,a new BAT M action( no trigger) is Retailing for about AU $3600 .. So and extra $350 is not that much of a struggle but i just got a new Bartlien in at just under $1000 ,if it's the same increase then i don't think guys over here are going buy from America..At a time when i would have thought that the Govt would have been trying everything to support manufacturing , it beats the hell out of me that they would do this to the gun industry.. How do you think this will pan out ???..JR..Jeff Rogers..ps a $750 Jewel trigger is not what i wanted to hear either
 
Bungalow Bill said:
There is two new letters defining requirements of dealer and manufacturing. These letters are ATF Ruling 2009-1 and 2009-2. I have attached them here as PDF's.

HTH
John aka Bungalow Bill
Click to expand...
If I read this correctly a gunsmith can get by without a manufacturer's license?
 
How else do you think that government will shovel the rest of the $hit down the American peoples throat? They have to do all they can to stop the sale and trade in firearms. This is the change you can believe in.

Welcome to Agency law, no need to repeal the second amendment when you have control of the people by agencies. Not that this has not gone on for the last hundred years, after all this is all that is taught in law schools across the country.:mad:
 
From ATF FAQ

The below FAQ are from the ATF web site.

5. A company receives firearm frames from individual customers,
attaches stocks and barrels and returns the firearms to the
customers for the customers' personal use.

The operations performed on the firearms were not for the
purpose of sale or distribution. The company should be licensed as a dealer or
gunsmith, not as a manufacturer of firearms.

6. A company acquires one receiver, assembles one firearm, and
sells the firearm.

The company is not manufacturing firearms as a regular course
of trade or business and is not engaged in the business of
manufacturing firearms. This company does not need to be licensed as a
manufacturer.
 
Dennis Sorensen said:
How many customers here in Canada want to pay $350 for an export charge on top of the price of a Lilja or any other barrel...

It just plain stupid and the US manufacturers are losing in the end.
Click to expand...

I'd guess that anyone importing barrels would want to import more than one barrel at a time to help spread the export cost out a little.

Below are the statutes referenced in the atf ruling 2009-2. When I read the definition for gunsmith as saying it shall not include a person who makes occasional repairs of firearms, or who occasionally fits special barrels, stocks, or trigger mechanisms to firearms; I define it as meaning that a person who is not a FFL licensed can do those things on an occasional basis for themselves or for others without having to be licensed. Where the rub would come would be the point where you become part time and have to have a ffl or where you are occasional and don't have to have a ffl. Gunsmiths would be in better shape definition wise if it stated that a definition of a gunsmith included someone who routinely fits special barrels, stock or trigger mechanisms to firearms. IMO assembling parts is not manufacturing. Making the parts to assemble is manufacturing. ATF evidently doesn't see it that way.

18 U.S.C. 921 (a) (11)
(21) The term "engaged in the business" means -
(A) as applied to a manufacturer of firearms, a person who
devotes time, attention, and labor to manufacturing firearms as a
regular course of trade or business with the principal objective
of livelihood and profit through the sale or distribution of the
firearms manufactured;

(B) as applied to a manufacturer of ammunition, ....

(C) as applied to a dealer in firearms, as defined in section
921(a)(11)(A), a person who devotes time, attention, and labor to
dealing in firearms as a regular course of trade or business with
the principal objective of livelihood and profit through the
repetitive purchase and resale of firearms, but such term shall
not include a person who makes occasional sales, exchanges, or
purchases of firearms for the enhancement of a personal
collection or for a hobby, or who sells all or part of his
personal collection of firearms;
(D) as applied to a dealer in firearms, as defined in section
921(a)(11)(B), a person who devotes time, attention, and labor to
engaging in such activity as a regular course of trade or
business with the principal objective of livelihood and profit,
but such term shall not include a person who makes occasional
repairs of firearms, or who occasionally fits special barrels,
stocks, or trigger mechanisms to firearms;

27 CFR 47.11
(d) Gunsmith. A person who devotes time, attention, and labor to engaging in such activity as a regular course of trade or business with the principal objective of livelihood and profit, but such a term shall not include a person who makes occasional repairs of firearms or who occasionally fits special barrels, stocks, or trigger mechanisms to firearms;
 
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Mr. Coleman,

I agree, with the below quote and the Jan. 12 09 letter, things look alot better for us. Even if we machine a barrel; thread fit and chamber. It is just a part not a firearm. The Gunsmith is just "making" a drop in part. By machining the barrel to fit the action we are no more a firearm manf. then the barrel maker is. At the point the barrel is pulled from the lathe it is just a drop in part to that action that originated as a, New Rem 700 sps 243(for example).

Changing dimensions on the action though still looks a little gray.

Jim See

J. Pendergraft said:
The below FAQ are from the ATF web site.

5. A company receives firearm frames from individual customers,
attaches stocks and barrels and returns the firearms to the
customers for the customers' personal use.

The operations performed on the firearms were not for the
purpose of sale or distribution. The company should be licensed as a dealer or
gunsmith, not as a manufacturer of firearms.

6. A company acquires one receiver, assembles one firearm, and
sells the firearm.

The company is not manufacturing firearms as a regular course
of trade or business and is not engaged in the business of
manufacturing firearms. This company does not need to be licensed as a
manufacturer.
Click to expand...
 
Sub contractors and gun parts manufactures now have to be licensed as manufactures

If you don't beleive me ask Tim North at Broughton Barrels, ask Dave Kiff at Pacific tool and gauge. Neither manufacture actions. Both have become licensed in the last year as manufactures. I have not asked Jack Kreiger, Micke Rock, Dan Lilja, or any others if they have gotten licensed as a manufacture. I also recomend for any of you to read the State Department registration requirements see ITAR22. Manufactures are haveing to deal with 3 government agencies (BATF, TTB, STATE DEPARTMENT)who all have different agendas ands definitions.

Rustystud
 
It works both ways. We in Canada are being forced to look at other countries for both imports and exports as I suppose are others. I also received the email from Lilja. I have no problem buying from Canadian barrel makers, quality wise as I feel they are as good as any. I hope they add some bodies to handle the work load. We will soon be making biathlon stocks for Europe I guess.
 
Ian

how much hassle is it to send those wonderful stocks of yours south?

What is the comparison to bring actions up from the south?

In regards to barrels I would LOVE to try a US made barrel but the costs incurred to get them up here make it not worth my while.

I better place an order to Gaillard for a few more barrels.................. He is not getting any younger.
 
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