ITAR question

[Dolomite_Supafly]

I sell bolt lift kits for Savage bolt action rifles. I sell them for $20. Basically they reduce the drag and make the bolt lift feel smoother.

Question I have is I had someone from Canada want to buy one. Is it legal for me to sell and ship them to someone in Canada?

Thanks

 

[Sean the Nailer]

Just my opinion, but as it is DEFINITELY not an item that is in current use by the military, I'd lean towards "it's ok to sell to Canada" simply because the US military doesn't need to fear that it will be used against them.

But, I'm a biased Canadian, so what do I know? At the same time, it is illegal for Giraud to sell/ship one of his automated annealers up here.... so go figure. They're laws. There's no law that says any law made needs to make sense.

Go ahead, ask me my thoughts on any other ridiculous ITARd laws.

 

[Rthur]

@THEIS might be the guy to answer this question.

R

 

[308pirate]

Just my opinion, but as it is DEFINITELY not an item that is in current use by the military, I'd lean towards "it's ok to sell to Canada" simply because the US military doesn't need to fear that it will be used against them.

But, I'm a biased Canadian, so what do I know? At the same time, it is illegal for Giraud to sell/ship one of his automated annealers up here.... so go figure. They're laws. There's no law that says any law made needs to make sense.

Go ahead, ask me my thoughts on any other ridiculous ITARd laws.

No disrespect to you, but I have some exposure to ITAR regulations and compliance.

All I will say about this is that unless you have verifiable expertise on the subject (and I don't, I only have familiarity) you shouldn't dispense opinions on what is or is not subject to trade controls.

Someone may take you at your well-meaning word and end up in a shitload of legal trouble. In the end it's that person's responsibility, but a golden rule should be don't offer advice on legal matters that you don't know anything about.

 

[Sean the Nailer]

@308pirate
I absolutely agree with you. That would be why my first 3 words are:

JUST MY OPINION.

The main comment I was making, with examples and logic, is that there is practically NO logic involved with this whole new tome of ITARd laws. Some might even say that they are ITARded.

See what I did there?

And yes, as another has suggested, I second the point of wait until THEIS comes in here, if he wants to/gets a chance. There you have someone who has immediate and professional knowledge of the subject. He has much more than just an innerwebz 'opinion'.

Good advice.

 

[Renegade]

Just my opinion, but as it is DEFINITELY not an item that is in current use by the military,

How do you know "it is DEFINITELY not an item that is in current use by the military"? Are you also aware that even if it is in use by military, that does not mean it is ITAR controlled?

There is way too little info on this one to even speculate.

My internet advice would be to pass on a single $20 sale. My own policy is to not sell/ship to anyone I know is not a US citizen. YMMV.

 

[THEIS]

Hi,

The short answer is that your product is not ITAR controlled, it is actually exempt due to the type of part AND the price.
The long answer is that ITAR has a small parts exemption found in 22 CFR 123.17(A) that essentially states the following:
Canada has $500 single purchase order max, rest of non sanctioned countries have $100 single purchase order max.

Sincerely,
Theis

 

[Sean the Nailer]

Thank you THEIS for clarifying some details.

It would almost seem that members aren't allowed opinions in the Bear Pit. You know, that place where everyone goes for Official Legal Advice.

And, we all KNOW that the military is in constant use of Savage brand equipment on the front lines, right? So if opinion can't be had, you know for DAMN SURE that sarcasm and conjecture can't be had, either.

It's Canada Day right now, up here in Canada. Stat holiday and everything. So everyone enjoy your day, eh? And for the upcoming 4th of July Independence Day celebrations, ya'll enjoy them too. MmKay!

Ain't it great having such friendly, welcoming, and helpful neighbors. Can I borrow your lawnmower?

 

[kortik]

Hi,

The short answer is that your product is not ITAR controlled, it is actually exempt due to the type of part AND the price.
The long answer is that ITAR has a small parts exemption found in 22 CFR 123.17(A) that essentially states the following:
Canada has $500 single purchase order max, rest of non sanctioned countries have $100 single purchase order max.
View attachment 7104626

Sincerely,
Theis

I've spent 3-4 hours trying to figure out that shit like 3 years ago... The simple answer, as it seems, is if something you sell becomes a part of firearm, it may potentially be ITAR contolled. If not, it may be O.K. In any case, I just do not ship anything outside the U.S. any more. I'm not willing to deal with all that crap... When it comes to $20 item, it's certainly not practical to spend any extra time and effort to ship overseas, regardless of what it is.

 

[THEIS]

I spent 3 hours trying t0 figure out that shit like 4 years ago... The simple answer is if something you sell becomes a part of firearms, it may potentially be ITAR contolled. If not, it may be O.K. In any case, I just do not ship anything outside the the U.S. I'm not willing to deal with all that crap...

Hi,

@kortik
If you ever come across something in regards to ITAR you need assistance with in regards to Borka Tools, please feel free to contact me.
I have years upon years contracting to DDTC for ITAR investigations, audits and compliance, along with being a member of DTAG Chapter specific to USML Sec 121 Categories I, II, and III.

Sincerely,
Theis

 

[kortik]

Hi,

@kortik
If you ever come across something in regards to ITAR you need assistance with in regards to Borka Tools, please feel free to contact me.
I have years upon years contracting to DDTC for ITAR investigations, audits and compliance, along with being a member of DTAG Chapter specific to USML Sec 121 Categories I, II, and III.

Sincerely,
Theis

Hi,

@kortik
If you ever come across something in regards to ITAR you need assistance with in regards to Borka Tools, please feel free to contact me.
I have years upon years contracting to DDTC for ITAR investigations, audits and compliance, along with being a member of DTAG Chapter specific to USML Sec 121 Categories I, II, and III.

Sincerely,
Theis

Theis,

Thank you very much for your offer. I'll keep it in my mind for sure...

Best to you,

Boris

 

[Dolomite_Supafly]

Thank you @THEIS

I really appreciate you expertise in this matter. I always try to follow the law to the letter but unfortunately there are a lot more than 26 in the legal alphabet these days.

At least a Canuck will be happy.

 

[Renegade]

Can you post a pic of your product? I still am not sure exactly what it is/does, how it works?

 

[THEIS]

Can you post a pic of your product? I still am not sure exactly what it is/does, how it works?

Hi,

Here is one of his previous threads on the product.

https://www.snipershide.com/shootin...s-for-savages-2nd-batch.6948519/#post-7818789

Sincerely,
Theis

 

[Dolomite_Supafly]

Thank you @THEIS

It goes inside the bolt of a Savage rifle to smooth the bolt lift.

 

[Lapuapalooza]

Thank you THEIS for clarifying some details.

It would almost seem that members aren't allowed opinions in the Bear Pit. You know, that place where everyone goes for Official Legal Advice.

And, we all KNOW that the military is in constant use of Savage brand equipment on the front lines, right? So if opinion can't be had, you know for DAMN SURE that sarcasm and conjecture can't be had, either.

It's Canada Day right now, up here in Canada. Stat holiday and everything. So everyone enjoy your day, eh? And for the upcoming 4th of July Independence Day celebrations, ya'll enjoy them too. MmKay!

Ain't it great having such friendly, welcoming, and helpful neighbors. Can I borrow your lawnmower?

Take off, eh... Hoser!!!