Newly issued ITAR regulations

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    molonlabe

    Ultimate Member
    May 7, 2005
    2,760
    Mountaineer Country, WV
    Just received this from WVCDL. I searched the forum I don't see it. I'm posting this in the WV forum.

    Text here
    Executive Overreach (national)
    I apologize in advance for a rare deviation from our "WV only" policy, as we feel it is imperative that we highlight a national issue. We must pass some critical information to WV gun owners, gunsmiths, and manufacturers.

    President Obama has over-reached in a way that can, and if left to stand, will have a severe chilling effect on the exercise of our Second Amendment rights. And at present, based on our interpretation of a Department of State guidance letter, many of us may be considered felons as this is typed.

    Thus we must make you aware of this condition.

    ITAR (International Traffic in Arms Regulations) strictly regulates the export of technology that can be used for military purposes. It is broad ranging and covers many things from encryption technology, through weapons systems and training of foreign nationals. The penalty for violating ITAR regulations is severe. It includes a one million dollar fine, and 20 years in prison.

    Our interpretation of the guidance letter dated 7/22 (you can click above to read the actual document) is that anyone who drills and taps a scope mount, polishes a trigger, or modifies a firearm in any way that requires tools and improves the firearm's function or accuracy, could be prosecuted as a violation of ITAR.

    Further, the definition of "automated" reloading is sufficiently vague that we believe individuals may be prosecuted for the use of a progressive reloader.

    Also, it is critical to note that intent to export is not a factor in ITAR. Whether you intend to export an item out of the country or not, is completely irrelevant.

    Put short, this guidance letter is an abomination and a massive executive over-reach.

    The WVCDL is in touch with our national delegation, and we are doing what we can to help deal with this problem. At present, we have no action items for our membership. But please stay tuned, as that is subject to change. Regardless, the main purpose of this message is a notification of this change to gun owners, and especially gunsmiths within our membership and in West Virginia at large.

    Stay tuned. This is big, and this is bad.

    http://campaign.r20.constantcontact...22215&ca=96800ffe-441f-4c21-97e4-8a750ea4e032

    Link to the letter.
    http://pmddtc.state.gov/compliance/...ement to Firearms Manufacturers (Publish).pdf
     

    Indiana Jones

    Wolverine
    Mar 18, 2011
    19,480
    CCN
    Sounds like an exaggeration typical of WVCDL and similar organizations. Did they actually read it in it's entirety?
     

    BeoBill

    Crank in the Third Row
    MDS Supporter
    Oct 3, 2013
    27,058
    南馬里蘭州鮑伊
    ...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...

    I didn't need to read any farther. Also note that under the document scoping, the guidance directive applies to "Gunsmiths."

    :bs:
     

    swinokur

    In a State of Bliss
    Patriot Picket
    Apr 15, 2009
    55,394
    Westminster USA
    the email:

    shr_drw_left.png

    on.jsp


    [FONT=&quot]st Virginia Citizens Defense League, Inc.[/FONT]
    PO Box 11371 | Charleston, WV 25339-1371
    Defending Your Right to Defend Yourself
    news_flag_hdr1.jpg


    WVCDL-ALERT
    Update
    July 28, 2016
    Was this e-mail forwarded to you?
    [FONT=&quot]To join our free WVCDL-ALERT e-mail list, please (1) click the link to "Join Our Mailing List" in the right column, (2) enter your e-mail address in this form, or (3) text WVCDL to 22828 on your mobile phone.[/FONT]

    [FONT=&quot]Second, if you are on Facebook, please join the WVCDL group.[/FONT]

    [FONT=&quot]Finally, if you can afford to do so, we strongly encourage you to become an official, dues-paying WVCDL member.

    [/FONT]
    [FONT=&quot]Executive Overreach (national)[/FONT]
    [FONT=&quot]I apologize in advance for a rare deviation from our "WV only" policy, as we feel it is imperative that we highlight a national issue. We must pass some critical information to WV gun owners, gunsmiths, and manufacturers.[/FONT]
    [FONT=&quot] [/FONT]
    [FONT=&quot] President Obama has over-reached in a way that can, and if left to stand, will have a severe chilling effect on the exercise of our Second Amendment rights. And at present, based on our interpretation of a Department of State guidance letter, many of us may be considered felons as this is typed.[/FONT]
    [FONT=&quot] [/FONT]
    [FONT=&quot] Thus we must make you aware of this condition.[/FONT]
    [FONT=&quot] [/FONT]
    [FONT=&quot] ITAR (International Traffic in Arms Regulations) strictly regulates the export of technology that can be used for military purposes. It is broad ranging and covers many things from encryption technology, through weapons systems and training of foreign nationals. The penalty for violating ITAR regulations is severe. It includes a one million dollar fine, and 20 years in prison.[/FONT]
    [FONT=&quot] [/FONT]
    [FONT=&quot] Our interpretation of the guidance letter dated 7/22 (you can click above to read the actual document) is that anyone who drills and taps a scope mount, polishes a trigger, or modifies a firearm in any way that requires tools and improves the firearm's function or accuracy, could be prosecuted as a violation of ITAR.[/FONT]

    [FONT=&quot]Further, the definition of "automated" reloading is sufficiently vague that we believe individuals may be prosecuted for the use of a progressive reloader.[/FONT]

    [FONT=&quot]Also, it is critical to note that intent to export is not a factor in ITAR. Whether you intend to export an item out of the country or not, is completely irrelevant.[/FONT]

    [FONT=&quot]Put short, this guidance letter is an abomination and a massive executive over-reach. [/FONT]

    [FONT=&quot]The WVCDL is in touch with our national delegation, and we are doing what we can to help deal with this problem. At present, we have no action items for our membership. But please stay tuned, as that is subject to change. Regardless, the main purpose of this message is a notification of this change to gun owners, and especially gunsmiths within our membership and in West Virginia at large. [/FONT]

    [FONT=&quot]Stay tuned. This is big, and this is bad.[/FONT]
    [FONT=&quot]eith Morgan[/FONT]

    [FONT=&quot]President, [/FONT]

    [FONT=&quot]West Virginia Citizens Defense League, Inc.[/FONT]


    In This Issue
    [FONT=&quot]Was this e-mail forwarded to you?[/FONT]
    [FONT=&quot]Presidential Overreach[/FONT]



    Quick Links
    [FONT=&quot]WVCDL Home Page[/FONT]

    [FONT=&quot]WVCDL Legislative Tracking Service[/FONT]

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    [FONT=&quot]West Virginia Citizens Defense League, Inc.[/FONT][FONT=&quot],[/FONT][FONT=&quot] PO Box 11371[/FONT][FONT=&quot],[/FONT][FONT=&quot] Charleston[/FONT][FONT=&quot],[/FONT][FONT=&quot] WV 25339[/FONT]






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    MontaniSemperLiberi

    MD Survivor
    Nov 12, 2011
    378
    West By'God Virginia
    I didn't need to read any farther. Also note that under the document scoping, the guidance directive applies to "Gunsmiths."

    :bs:
    Have you considered how the ATF redefined what "in the business of" to mean to target private sales?
    Sounds like an exaggeration typical of WVCDL and similar organizations. Did they actually read it in it's entirety?
    Exaggeration typical of the WVCDL? Considering the WVCDL only deals with WV issues (this is the first national level issue that's been mentioned in YEARS) and has been spot-on and highly successful with their goals, you might want to re-check your statements. ;)
     

    zoostation

    , ,
    Moderator
    Jan 28, 2007
    22,857
    Abingdon
    Sounds like an exaggeration typical of WVCDL and similar organizations. Did they actually read it in it's entirety?

    Unfortunately, they aren't. The DDTC/State Department are serious. As comical as it sounds. People have been watching this issue for some time. Yes, according to State, if a local gunsmith threads just one barrel for a local customer, he just manufactured a controlled defense article and probably needs to be registered with DDTC. At a cost of $2250 every year. Even minute things like drilling and tapping for scope mounts or bedding a stock seem to be included. Anything that requires drilling, specialized tools, or increases the accuracy or magazine capacity of a firearm, or changes the caliber, is covered. They call that manufacturing. It's absurd.

    One thing it doesn't appear to me to affect is private gun owners not "engaged in the business" working on their guns. But I am not a lawyer.

    Here is an excerpt:

    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.
     
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