Gunsmithing Type 1 vs 7 FFL

flyfisherman246

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Minuteman
May 26, 2017
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I have read all I can on which license you need to provide services to customers supplied rifle parts. Everything is pointing towards type 7 manufacturers license, even for simple stuff like threading a muzzle or chambering a barrel. And once you have the type 7 even though your not manufacturing firearms, you also need to pay 2,250 a year to ITAR even though your not exporting anything. And then after 50 rifles a year, you need to pay the exile tax on every rifle built that year.

Is this right? Is there anyone getting by with a type 1 and no ITAR tax?

Thanks
 
I believe the ITAR fee is no longer a requirement.

Hi,
That is incorrect. The proposed ITAR revisions have not taken affect and there is no timeline as to when they actually will.
Per DDTC current website information:

When the Federal Register is updated to show effective date of new ITAR policies is completely up in the air right now.

Sincerely,
Theis
 
ITAR is being looked at as we speak. Who knows when or if it will change. It is "required" but it isn't something that the ATF is in charge of or looks for. I started with a type 01 and fairly quickly found out that it is a pain in the butt for out of state customers to purchase a new actions from us.
I'd say bite the bullet and go with an 07. Its just easier in the long run. It does end up being a bit more expensive due to marking and all that but otherwise much easier to go with an 07 and be able to save the customer a hassle of shipping 3 times before you can start the work.

You're correct otherwise. I just had my "interview" for my 07 2 days ago.

As i said earlier, I had an 01 and you can get by with an 01 and no ITAR (sorta... grey areas there). If your customer base is local and you plan on doing very little out of state work, then an 01 is definitely feasible. I would call you local IOI or ATF field office and ask any questions you may have. I've found that each IOI inturprates the laws different, its a pain in the ass, but they aren't there to throw you in jail. They want to help and want you to be successful, but within the old outdated laws.