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Posted: 11/21/2019 1:17:04 AM EDT
[#1]
COC prevents us from sharing that specific information with you on this forum, publicly, even though your conversion would be legal once you have your Class 2 SOT in hand.
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Posted: 11/21/2019 1:36:34 AM EDT
[#2]
Midwest used to sell FA trigger packs for like 250. I can't remember for sure, but I think at some point FN started using a semi auto carrier that didn't have the cutout to trip the sear, so that's something you want to check into before you haul off and buy a PS90. You might have to find an older one.
After the trigger pack, you'll have to find an FA selector, but those are all over, or at least they used to be. Have fun. Just don't mortgage your house to buy ammo. 
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Posted: 11/21/2019 9:17:31 PM EDT
[#3]
Quoted:
Happy to receive PM's. ATF just cashed my sot check and have the FFL in hand. I saw a 550 select fire trigger pack on GunBroker and 850 for a PS90 conversion kit sold by another online store. Also, if so did you pay your REQUIRED ITAR annual tax? $2,250.00 a year. |
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Posted: 11/22/2019 12:36:15 AM EDT
[#4]
Quote HistoryQuoted: If you’re planning on doing the conversation I hope you have an 07/C II. Also, if so did you pay your REQUIRED ITAR annual tax? $2,250.00 a year. |
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Posted: 11/22/2019 2:18:05 PM EDT
[#5]
Quote HistoryQuoted:
COC prevents us from sharing that specific information with you on this forum, publicly, even though your conversion would be legal once you have your Class 2 SOT in hand. |
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Posted: 11/22/2019 3:36:20 PM EDT
[#6]
Quote HistoryQuoted:
He wouldn't necessarily be required to join ITAR. And the annual tax is $2,250.00 1. Failure to Register with the State Department “Every firearms, ammunitions, or firearms component manufacturer needs to register with the DDTC. You have to register whether you intend to export your products or not. If you plan to export anything, you have to get approval from the DDTC first. LINK |
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Posted: 11/22/2019 3:42:32 PM EDT
[#7]
Quote HistoryQuoted:
I recently moved from 01 to 07 with SOT in progress. So with that said, is there a place we hang out and share that info? |
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Posted: 11/22/2019 7:33:47 PM EDT
[#8]
Quote HistoryQuoted: It’s REQUIRED if you are an 07. It’s NOT an option! And the annual tax is $2,250.00 1. Failure to Register with the State Department “Every firearms, ammunitions, or firearms component manufacturer needs to register with the DDTC. You have to register whether you intend to export your products or not. If you plan to export anything, you have to get approval from the DDTC first. LINK |
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Posted: 11/23/2019 1:04:48 AM EDT
[#9]
Quote HistoryQuoted:
I don't think there's a rule that says that every single one has to register. If you're not doing any machining I don't see why you would. |
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Posted: 11/23/2019 2:15:10 AM EDT
[#10]
Quote HistoryQuoted: As to the original OP question, there is ZERO machining required to convert an FN PS90 to a P90. If you aren’t paying ITAR you WILL be in violation for manufacturing a Machine Gun. |
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Posted: 12/20/2019 6:00:53 PM EDT
[#11]
Quote HistoryQuoted:
ITAR and the ATF don't have the same definition of manufacturing. As long as he's not doing any machining he should be fine as far as ITAR is concerned. Quote HistoryQuoted:
Quoted: As to the original OP question, there is ZERO machining required to convert an FN PS90 to a P90. If you aren’t paying ITAR you WILL be in violation for manufacturing a Machine Gun. Either way, you are doing physical work to make it happen. Its stupid, but it is what it is. OP, check out the MG section down the Armory forum, or as mentioned, WeaponsGuild. FFLsOnly is another one, albeit less busy that here or WeaponsGuild. |
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Posted: 12/20/2019 6:29:52 PM EDT
[#12]
Quote HistoryQuoted: Yeah, but technically, to make a FA group fit, you will be doing some kind of physical modification to the firearm or the pack to make it the conversion device. Either way, you are doing physical work to make it happen. Its stupid, but it is what it is. OP, check out the MG section down the Armory forum, or as mentioned, WeaponsGuild. FFLsOnly is another one, albeit less busy that here or WeaponsGuild. Even then, it might not be manufacturing under ITAR if he had to shave some plastic. There's also a lot of debate as to whether it applies to doing it for personal use. It's generally accepted that you don't need to register as long as you're just doing it for your own consumption. There's nothing about being an SOT that means you have to register. If he's just doing it for his own jollies and not going into business then it's no different than me milling an 80% receiver or pinning a gas block. Actually, either one of those things would clearly fall under ITAR if they wanted to apply it to things made for personal use as a hobbyist, whereas shaving some plastic off a trigger module would be a gray area. It's been a while since I read the thing, but I'm pretty sure it actually uses the words machining and metal. |
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Posted: 12/20/2019 11:03:30 PM EDT
[#13]
Quote HistoryQuoted:
I'm pretty sure they just drop in. I've never noticed any dimensional differences between the two, and the older PS90s have the sear notch in the MPG. Even then, it might not be manufacturing under ITAR if he had to shave some plastic. There's also a lot of debate as to whether it applies to doing it for personal use. It's generally accepted that you don't need to register as long as you're just doing it for your own consumption. There's nothing about being an SOT that means you have to register. If he's just doing it for his own jollies and not going into business then it's no different than me milling an 80% receiver or pinning a gas block. Actually, either one of those things would clearly fall under ITAR if they wanted to apply it to things made for personal use as a hobbyist, whereas shaving some plastic off a trigger module would be a gray area. It's been a while since I read the thing, but I'm pretty sure it actually uses the words machining and metal. He cannot be because a SOT cannot make machineguns for personal use or for his own consumption. They are made for demonstration for sale and in expectation of future sales. There is no other legal way to make post 86 machineguns. By making machineguns, he is in the business. And that is what DoS expects you to register for. ATF expects you to follow all applicable law and licenses. As for the trigger group, a FA group is NOT the same as a SA group. It cannot be. For a conversion either the pack is modified (registered conversion device) or the stock is modified to the unmodified pack (anothe rconversion device). Forgive me if I dont go into details. |
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Posted: 12/21/2019 1:04:50 AM EDT
[#14]
Quote HistoryQuoted: The thing is he is in the business of doing it, he is not doing it for himself or for personal use. He cannot be. He cannot be because a SOT cannot make machineguns for personal use or for his own consumption. They are made for demonstration for sale and in expectation of future sales. There is no other legal way to make post 86 machineguns. By making machineguns, he is in the business. And that is what DoS expects you to register for. ATF expects you to follow all applicable law and licenses. As for the trigger group, a FA group is NOT the same as a SA group. It cannot be. For a conversion either the pack is modified (registered conversion device) or the stock is modified to the unmodified pack (anothe rconversion device). Forgive me if I dont go into details. That's another thing you're not thinking of. He can take whatever to a machinist that's registered and not have to register himself. As long as he's not doing his own machining on products for commercial resale he doesn't have to register. So for example he could just send it to Morgan for machining and be done with it. He wouldn't be doing any manufacturing under ITAR, and he would be covered on the ATF side. This is probably all moot, though, because everybody says the hammer packs are interchangeable, at least with the early gens. So OP isn't likely to have to do any cutting or even hire anyone to. |
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Posted: 12/21/2019 8:16:10 AM EDT
[#15]
Quote HistoryQuoted:... everybody says the hammer packs are interchangeable, at least with the early gens. So OP isn't likely to have to do any cutting or even hire anyone to. |
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Posted: 12/21/2019 8:32:13 AM EDT
[#16]
Quote HistoryQuoted: I think “everybody” looks to be mistaken. There’s pics of the differences if you search. |
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Posted: 12/21/2019 11:03:15 AM EDT
[#17]
Quote HistoryQuoted:
Probably the majority of people who have SOT status are hobbyists. And even if what you say were true, the ATF has a completely different definition of manufacturing than ITAR. Just because you're a manufacturer according to the ATF doesn't mean you're a manufacturer according to ITAR. And he can deal all day long in factory guns and suppressors and still have his own toys. As long as he's not manufacturing P90s to sell and doing the machine work himself. That's another thing you're not thinking of. He can take whatever to a machinist that's registered and not have to register himself. As long as he's not doing his own machining on products for commercial resale he doesn't have to register. So for example he could just send it to Morgan for machining and be done with it. He wouldn't be doing any manufacturing under ITAR, and he would be covered on the ATF side. This is probably all moot, though, because everybody says the hammer packs are interchangeable, at least with the early gens. So OP isn't likely to have to do any cutting or even hire anyone to. Quote HistoryQuoted:
Quoted: The thing is he is in the business of doing it, he is not doing it for himself or for personal use. He cannot be. He cannot be because a SOT cannot make machineguns for personal use or for his own consumption. They are made for demonstration for sale and in expectation of future sales. There is no other legal way to make post 86 machineguns. By making machineguns, he is in the business. And that is what DoS expects you to register for. ATF expects you to follow all applicable law and licenses. As for the trigger group, a FA group is NOT the same as a SA group. It cannot be. For a conversion either the pack is modified (registered conversion device) or the stock is modified to the unmodified pack (anothe rconversion device). Forgive me if I dont go into details. That's another thing you're not thinking of. He can take whatever to a machinist that's registered and not have to register himself. As long as he's not doing his own machining on products for commercial resale he doesn't have to register. So for example he could just send it to Morgan for machining and be done with it. He wouldn't be doing any manufacturing under ITAR, and he would be covered on the ATF side. This is probably all moot, though, because everybody says the hammer packs are interchangeable, at least with the early gens. So OP isn't likely to have to do any cutting or even hire anyone to. I dont understand the part in red. The only way he can get a MG is to make it himself for demo or in expectation of future sale, or to buy it as a demo gun on a demo letter. If he takes it to another machinist, he has to have it transferred to him on a demo letter (with a couple of exceptions, but not common). Just sending a gun to be made by another SOT is not an answer because technically the submitter of the F2 has to be the one creating or reactivating the MG. And thus they are the manufacturer. Again, as far as I have been able to tell, the only grey area for ITAR is assembling guns, where the ATF says manufacturing and State does not. The difference you will see from ATF and ITAR on manufacturing is largely that ATF holds that if you buy an upper and buy a lower and put them together, you have manufactured a firearm. ITAR and State restrict it to actual modification or creation of parts. A lower exists as a firearm before the rifle is manufactured. This is not the case for a MG. Physical modification has to be completed to create a MG (and thus all the "readily convertible" stuff you have to deal with in making semi autos). AFAIK, There is not a MG that you can make just by assembling parts. If that is the case the parts themselves are the MG and you are manufacturing when you make them (DIAS, etc). |
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Posted: 12/21/2019 11:26:57 AM EDT
[#18]
Quote HistoryQuoted: We are getting a bit far afield from the original post, so Ill knock it off after this. I dont understand the part in red. The only way he can get a MG is to make it himself for demo or in expectation of future sale, or to buy it as a demo gun on a demo letter. If he takes it to another machinist, he has to have it transferred to him on a demo letter (with a couple of exceptions, but not common). Just sending a gun to be made by another SOT is not an answer because technically the submitter of the F2 has to be the one creating or reactivating the MG. And thus they are the manufacturer. Again, as far as I have been able to tell, the only grey area for ITAR is assembling guns, where the ATF says manufacturing and State does not. The difference you will see from ATF and ITAR on manufacturing is largely that ATF holds that if you buy an upper and buy a lower and put them together, you have manufactured a firearm. ITAR and State restrict it to actual modification or creation of parts. A lower exists as a firearm before the rifle is manufactured. This is not the case for a MG. Physical modification has to be completed to create a MG (and thus all the "readily convertible" stuff you have to deal with in making semi autos). AFAIK, There is not a MG that you can make just by assembling parts. If that is the case the parts themselves are the MG and you are manufacturing when you make them (DIAS, etc). |
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Posted: 12/21/2019 2:51:03 PM EDT
[#19]
Quote HistoryQuoted:
AFAIK, There is not a MG that you can make just by assembling parts. If that is the case the parts themselves are the MG and you are manufacturing when you make them (DIAS, etc). ATF has been mildly schizophrenic, especially in the past, about the differences required to make a receiver "not a machinegun", especially from back in the pre-1982 open-bolt semi-auto era. FWIW modifying a hammer pack for full auto use would make the hammer pack a machinegun by itself, if it would drop into an unmodified semi PS90 receiver and allow full auto function thereafter. |
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Posted: 12/21/2019 8:11:04 PM EDT
[#20]
Quote HistoryQuoted:
There are actually quite a few though I won't go into specifics in a public forum. ATF has been mildly schizophrenic, especially in the past, about the differences required to make a receiver "not a machinegun", especially from back in the pre-1982 open-bolt semi-auto era. FWIW modifying a hammer pack for full auto use would make the hammer pack a machinegun by itself, if it would drop into an unmodified semi PS90 receiver and allow full auto function thereafter. The receiver itself though is identical to a P90 receiver, so OP wouldn't have to modify the serialized part. I still don't think he would have to modify any parts, as long as he had an early gen PS90. He would just have to source the P90 trigger and stock, which I used to see listed all the time for about 500 bucks a set. So OP could either just buy the real P90 components to install on his PS90 receiver, or send the PS90 stock and or hammer pack to Morgan. I don't see any reason he couldn't do that since those parts are unregulated. It's not like on an AR15 where you can make a DIAS and just drop it in and suddenly it's full auto. Probably about the closest you could come to that is if you just made it FA only, but if you want the long pull FA feature you're going to have to do more than just drop in a different hammer pack. You're going to need the real P90 stock and selector. |
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Posted: 12/22/2019 8:58:38 AM EDT
[#21]
Quote HistoryQuoted:... or send the PS90 stock and or hammer pack to Morgan. I don't see any reason he couldn't do that since those parts are unregulated. |
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Posted: 12/22/2019 11:01:42 AM EDT
[#22]
Quote HistoryQuoted: Question: wouldn’t it be because that’s making a machinegun conversion device which in itself is a machinegun? Just like a low shelf lower isn't controlled, neither is a P90 stock. You could have an entire warehouse of P90 stocks. |
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Posted: 12/22/2019 2:10:54 PM EDT
[#23]
Quote HistoryQuoted:
I don't think so. It would be like sending a lower to have the shelf milled out, but not having the third hole drilled, because P90 stocks aren't regulated. Like if you sent a PS90 stock to be converted into a P90 stock, that wouldn't be a machinegun (and I'm pretty sure that's all he would have to do, assuming he couldn't find a real P90 stock online). Just like a low shelf lower isn't controlled, neither is a P90 stock. You could have an entire warehouse of P90 stocks. Just because a component is not registered or regulated in its original form doesn't make modifying it for full auto use not the creation of a machinegun conversion. Modifying what and what modifications are made is a determination made on a case by case basis by the BATFE. |
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Posted: 12/22/2019 2:16:24 PM EDT
[#24]
Any and all machinegun conversion devices regardless of what they’re made from are machineguns. Steel isn’t regulated, but stamping steel into HK sears makes them machineguns, even without a host.
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Posted: 12/22/2019 3:52:58 PM EDT
[#25]
It's also possible to make a MG without modifying anything.
I don't know if a P90 stock will fit a PS90 receiver, but if it will then you'd just need the stock assembly and P90 pack to convert an earlier PS90 (when they still shipped with the FA bolt carrier). That's what 6GUNZ pointed out above, and I agree that wouldn't be manufacturing as far as ITAR is concerned, therefore it shouldn't invoke the registration requirement. I know you can omit a part from a gen 1 PS90 and it'll fire full-auto (not select-fire). You can also take the FA stock, hammer pack, and bolt carrier assembly from a FA Steyr AUG parts kit (which are all unregulated parts), remove something from the stock, and slide a SA AUG barreled receiver right into it, and it'll be select-fire. (You'll have to hold the rifle together using the VFG, but it'll still work fine). Those would be examples which don't even require any Dremel work. I'm not sure where ITAR stands on "manufacturing," as it relates to cutting plastic with hand tools. Obviously if you F2 a new MG, you "manufactured" it as far as ATF is concerned, whether you physically modified any parts or not. |
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Posted: 12/22/2019 7:54:06 PM EDT
[#26]
Quote HistoryQuoted:
Consider this, then. notching an HK trigger box to fit a shelf receiver is creating a machinegun, even though the unmodified box is not itself a registered or regulated component and you can have a warehouse full of them. Ditto notching a full auto Uzi bolt so that it will fit a blocking-bar equipped semi auto Uzi receiver. Parts swaps and other component modifications may still be required to make the guns functions properly as full autos, but those two individual steps are de jure considered to be making a machinegun conversion. Just because a component is not registered or regulated in its original form doesn't make modifying it for full auto use not the creation of a machinegun conversion. Modifying what and what modifications are made is a determination made on a case by case basis by the BATFE. I fail to see how making a PS90 stock a P90 stock, if that's even possible, is illegal. |
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Posted: 12/22/2019 7:58:43 PM EDT
[#27]
Quote HistoryQuoted:
It's also possible to make a MG without modifying anything. I don't know if a P90 stock will fit a PS90 receiver, but if it will then you'd just need the stock assembly and P90 pack to convert an earlier PS90 (when they still shipped with the FA bolt carrier). That's what 6GUNZ pointed out above, and I agree that wouldn't be manufacturing as far as ITAR is concerned, therefore it shouldn't invoke the registration requirement. I know you can omit a part from a gen 1 PS90 and it'll fire full-auto (not select-fire). You can also take the FA stock, hammer pack, and bolt carrier assembly from a FA Steyr AUG parts kit (which are all unregulated parts), remove something from the stock, and slide a SA AUG barreled receiver right into it, and it'll be select-fire. (You'll have to hold the rifle together using the VFG, but it'll still work fine). Those would be examples which don't even require any Dremel work. I'm not sure where ITAR stands on "manufacturing," as it relates to cutting plastic with hand tools. Obviously if you F2 a new MG, you "manufactured" it as far as ATF is concerned, whether you physically modified any parts or not. As for ITAR, ITAR doesn't know where ITAR stands on anything. And if you send them a letter they'll just ignore you, despite being required by law to give you a response. They're nothing but mafioso thugs extorting people and terrorizing hobbyist level gunsmiths. |
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Posted: 12/22/2019 8:56:39 PM EDT
[#28]
Quote HistoryQuoted:
Okay, so would converting an AR15 carrier into an M16 carrier be manufacturing a machinegun? What abut welding a spur on a semi hammer to make it a full auto hammer? I fail to see how making a PS90 stock a P90 stock, if that's even possible, is illegal. As for the last - only ATF can determine that. But if it lets a semi PS90 fire full auto with no receiver modifications, they will (probably) take notice and make a determination, if they haven't done so already. |
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Posted: 12/23/2019 1:31:18 AM EDT
[#29]
Quote HistoryQuoted:
No to your first question. Yes to your second (but that does not constitute manufacturing a machinegun, per se). As for the last - only ATF can determine that. But if it lets a semi PS90 fire full auto with no receiver modifications, they will (probably) take notice and make a determination, if they haven't done so already. And, no, putting a P90 stock on a PS90 receiver wouldn't make it full auto. You would need at least three more FA parts. It would be like putting an M16 carrier in an AR15. Or more like an M16 upper receiver, actually. The P90 stock doesn't actually interact with any FA parts, it just provides the clearance for the FA parts to do their thing. So it's really very much analogous to an M16 upper receiver in that way. To be honest, I don't see what the problem would be if someone put a P90 stock on their PS90. I imagine the only reason the PS90 stock exists in the first place is back in the day FN was shipping them with auto sears and FA bolts intact, so the ATF probably pulled the whole readily convertible line on them. |
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Posted: 12/23/2019 3:02:44 AM EDT
[#30]
Quote HistoryQuoted: If you’re planning on doing the conversation I hope you have an 07/C II. Also, if so did you pay your REQUIRED ITAR annual tax? $2,250.00 a year. |
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Posted: 12/23/2019 4:03:23 AM EDT
[#31]
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Posted: 12/23/2019 4:47:20 AM EDT
[#32]
Quote HistoryBut how are they achieving select fire in a PS90 stock? That seems unlikely. |
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Posted: 12/23/2019 10:12:35 AM EDT
[#33]
Quote HistoryQuoted:
But how are they achieving select fire in a PS90 stock? Quote HistoryQuoted:
But how are they achieving select fire in a PS90 stock? It is notched to bypass the blocking tabs in a PS90 stock. A SELECT FIRE TRIGGER PACK THAT FITS INTO A PS90 STOCK. NO MODIFICATIONS NEEDED TO YOUR PS90 |
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Posted: 12/23/2019 10:16:28 AM EDT
[#34]
Quote HistoryQuoted:
How would making an FA AR hammer be illegal? |
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Posted: 12/23/2019 10:18:45 AM EDT
[#35]
Quote HistoryQuoted:
You asked in your second question if welding a hook on would make it a full auto hammer, not if making a full auto hammer was illegal (which it's not). |
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Posted: 12/29/2019 2:58:33 PM EDT
[#36]
Quote HistoryQuoted:
I don't think there's a rule that says that every single one has to register. If you're not doing any machining I don't see why you would. It's partly as way to allow DoS to get a handle on who is making defense articles they may need to be worried about, but I think its mostly another way to add barriers to entry to keep little guys out of the game. The big boys making, importing, and exporting defense articles have always had to deal with AECA and the DoS paperwork so it really isnt an issue to them other then another layer of bureaucracy and set of paperwork when doing exports or temp imports. |
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Posted: 12/29/2019 4:57:03 PM EDT
[#37]
Quote HistoryQuoted:
If you are a type 7 or 10 with an SOT 2 (or an 11/1 importer for that matter) you MUST register with DDTC. Quote HistoryQuoted:
If you are a type 7 or 10 with an SOT 2 (or an 11/1 importer for that matter) you MUST register with DDTC. I don’t think there’s a registration requirement if you aren’t manufacturing per the DDTC definition (or intending to import/export). There are also DDTC exemptions to the manufacturing registration requirement (which are generally not applicable to most 07/02 SOTs). I believe ATF has added it their inspection criteria as well, I dont remember off the top of my head. This isn’t something that ATF enforces. |
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Posted: 12/29/2019 7:27:50 PM EDT
[#38]
Quote HistoryQuoted:
Can you cite that? I don’t think there’s a registration requirement if you aren’t manufacturing per the DDTC definition (or intending to import/export). There are also DDTC exemptions to the manufacturing registration requirement (which are generally not applicable to most 07/02 SOTs). I don’t believe they have. They mention DDTC registration, maybe have a flyer, but that’s it. This isn’t something that ATF enforces. Quote HistoryQuoted:
Can you cite that? I don’t think there’s a registration requirement if you aren’t manufacturing per the DDTC definition (or intending to import/export). There are also DDTC exemptions to the manufacturing registration requirement (which are generally not applicable to most 07/02 SOTs). I don’t believe they have. They mention DDTC registration, maybe have a flyer, but that’s it. This isn’t something that ATF enforces. §122.1 Registration requirements.
(a) Any person who engages in the United States in the business of manufacturing or exporting or temporarily importing defense articles, or furnishing defense services, is required to register with the Directorate of Defense Trade Controls under §122.2. For the purpose of this subchapter, engaging in such a business requires only one occasion of manufacturing or exporting or temporarily importing a defense article or furnishing a defense service. A manufacturer who does not engage in exporting must nevertheless register. (See part 129 of this subchapter for requirements for registration of persons who engage in brokering activities.) (b) Exemptions. The registration requirements of paragraph (a) of this section do not apply to: (1) Officers and employees of the U.S. Government acting in an official capacity; (2) Persons whose pertinent business activity is confined to the production of unclassified technical data only; (3) Persons all of whose manufacturing and export activities are licensed under the Atomic Energy Act of 1954, as amended; or (4) Persons who engage in the fabrication of articles solely for experimental or scientific purposes, including research and development. Note to paragraph (b): Persons who qualify for the exemptions in paragraphs (b)(2) or (b)(4) of this section remain subject to the requirements for licenses or other approvals for exports of defense articles and defense services and may not receive an export license or approval unless registered under §122.2. (c) Purpose. Registration is primarily a means to provide the U.S. Government with necessary information on who is involved in certain manufacturing and exporting activities. Registration does not confer any export rights or privileges. It is generally a precondition to the issuance of any license or other approval under this subchapter, unless an exception is granted by the Directorate of Defense Trade Controls. [78 FR 52686, Aug. 26, 2013] Category I—Firearms, Close Assault Weapons and Combat Shotguns
*(a) Nonautomatic and semi-automatic firearms to caliber .50 inclusive (12.7 mm). *(b) Fully automatic firearms to .50 caliber inclusive (12.7 mm). *(c) Firearms or other weapons (e.g. insurgency-counterinsurgency, close assault weapons systems) having a special military application regardless of caliber. *(d) Combat shotguns. This includes any shotgun with a barrel length less than 18 inches. *(e) Silencers, mufflers, sound and flash suppressors for the articles in (a) through (d) of this category and their specifically designed, modified or adapted components and parts. (f) Riflescopes manufactured to military specifications (See category XII(c) for controls on night sighting devices.) *(g) Barrels, cylinders, receivers (frames) or complete breech mechanisms for the articles in paragraphs (a) through (d) of this category. (h) Components, parts, accessories and attachments for the articles in paragraphs (a) through (g) of this category. (i) Technical data (as defined in §120.10 of this subchapter) and defense services (as defined in §120.9 of this subchapter) directly related to the defense articles described in paragraphs (a) through (h) of this category. Technical data directly related to the manufacture or production of any defense articles described elsewhere in this category that are designated as Significant Military Equipment (SME) shall itself be designated SME. (j) The following interpretations explain and amplify the terms used in this category and throughout this subchapter: (1) A firearm is a weapon not over .50 caliber (12.7 mm) which is designed to expel a projectile by the action of an explosive or which may be readily converted to do so. (2) A rifle is a shoulder firearm which can discharge a bullet through a rifled barrel 16 inches or longer. (3) A carbine is a lightweight shoulder firearm with a barrel under 16 inches in length. (4) A pistol is a hand-operated firearm having a chamber integral with or permanently aligned with the bore. (5) A revolver is a hand-operated firearm with a revolving cylinder containing chambers for individual cartridges. (6) A submachine gun, “machine pistol” or “machine gun” is a firearm originally designed to fire, or capable of being fired, fully automatically by a single pull of the trigger. Note: This coverage by the U.S. Munitions List in paragraphs (a) through (i) of this category excludes any non-combat shotgun with a barrel length of 18 inches or longer, BB, pellet, and muzzle loading (black powder) firearms. This category does not cover riflescopes and sighting devices that are not manufactured to military specifications. It also excludes accessories and attachments (e.g., belts, slings, after market rubber grips, cleaning kits) for firearms that do not enhance the usefulness, effectiveness, or capabilities of the firearm, components and parts. The Department of Commerce regulates the export of such items. See the Export Administration Regulations (15 CFR parts 730-799). In addition, license exemptions for the items in this category are available in various parts of this subchapter (e.g., §§123.17, 123.18 and 125.4). It's almost purposefully kept vague and difficult to stay within compliance in all regards so they have something to hammer you with if you end up on their radar. |
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Posted: 1/9/2020 2:36:12 AM EDT
[#39]
So it’s not cheaper and easier to just go buy a gen 1 or 2 pack, do whatever the little modification is on it (something to do with the disconnector or something), and leave it at that? Not sure which part you’d register...maybe whatever you have to jam in the pack or whatever to make it work.
That’s the reason those packs command a premium, from what I hear. Those “conversions” aren’t legal for the average joe, but for an SOT I would have thought that to be the easiest method. |
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Posted: 1/11/2020 4:36:04 PM EDT
[#40]
 PS90/P90 Full Auto Trigger Group, and how it works.  FN PS90 Auto Disconnector (P90). |
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Posted: 1/11/2020 4:43:52 PM EDT
[#41]
For a discussion supposedly against the COC, there seems to be a lot of very specific talk on converting a PS90 to full auto in this thread.
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Posted: 1/12/2020 12:28:12 AM EDT
[#42]
Quote HistoryQuoted:
For a discussion supposedly against the COC, there seems to be a lot of very specific talk on converting a PS90 to full auto in this thread. |
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Posted: 1/12/2020 12:00:29 PM EDT
[#43]
I'm trying to sort through the two or three threads in this discussion.
First- read the conduct code before posting again. Second - ITAR is about export and import. Export can be physical articles or intellectual property. The loose, custom rule interpretation for the government's convenience is an extra layer of bullshit. ITAR is regulated by the State Department and the Commerce department. Third - an 07 license is not a ticket to do whatever the hell you want, it's one of the steps. Fourth - holding an FFL, except an 03, indicates the holder in conducting business, not building guns for personal use. ITAR or not, that's an effective way to get jammed by the ATFE, and I'll bet they get extra special surveillance. I'll go back through then make a decision about whether edit, lock the thread, or sanction members. |
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Posted: 1/12/2020 12:18:50 PM EDT
[#44]
Lacking proof of a type 07 licence and other details, this thread is locked.
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