Armory Sponsor
Posted: 9/14/2006 7:43:37 PM EDT
| What is invloved in becoming one? I know that you have to be able to prove that the purpose of the license is not to better your collection. I guess what I'm wondering is how much volume in sales do you have to do to retain your license? Aren't the storage requirements a pain also? |
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There is no specific sales volume requirement listed by BATF. Instead, you may be asked for some proof that you have made an effort to make sales -- for instance, a serious advertising campaign, copies of correspondence with LE purchasers, records of LE demos, etc. A second factor would be what you have in inventory, and how you have used it. In other words, if your inventory gives the appearance of being a nothing more than a well-used one-of-each personal collection, you're in trouble. OTOH, if you have five identical-model NIB suppressors in-stock for each demo example, that is in your favor. Volume of third-party transfer activity helps, too -- if you've done a couple of interstate transfers for buyers or sellers everyy month, that is proof that you are making an effort as a viable business. |
Getting an 07/02 manufacturing FFL/SOT is much tougher and more expensive. First, you need to be zoned for manufacturing, and BATF does check with the zoning board (and they have a tendency to freak out when BATF arrives and asks them about a munitions plant). If your site is rented/leased, you'll also need an owner acknowledgement that the site is being used for firearms manufacturing. Second, you need to get get EPA approval for your waste-disposal system, and submit that approval to BATF. BATF also is generally more strict about security (safes, alarms, etc.) with manufacturers than with dealers. If you pass all that, you will need to register with the State Department and pay the annual ITAR fee of $1,750 (in addition to the $500 annual SOT fee and $50 annual 07 fee). So you're at almost $200 per month in federal fees alone. |
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"If you pass all that, you will need to register with the State Department and pay the annual ITAR fee of $1,750 (in addition to the $500 annual SOT fee and $50 annual 07 fee). So you're at almost $200 per month in federal fees alone." I looked briefly into the ITAR thing and it looks to me to be a international trafficing thing. If you aren't going to import/export, I don't see any reason that should compell you to pay this fee. |
No reason -- except that federal law requires you to register and pay the fee. It applies to every manufacturer, whether you export or not. Believe me, I wish it didn't, because I'd be an 07/02 myself if I didn't have to pay it. You've never heard of an "unreasonable" firearms law?  If you need a cite: From 22 CFR 122.1: §122.1 Registration requirements. (a) Any person who engages in the United States in the business of either manufacturing or exporting defense ar- ticles or furnishing defense services is required to register with the Office of Defense Trade Controls. Manufacturers who do not engage in exporting must nevertheless register. www.pmdtc.org/docs/ITAR/2006/ITAR_Part_122.pdf What is a defense article? See 22 CFR 121.1, at www.pmdtc.org/docs/ITAR/2006/ITAR_Part_121.pdf Note that the list begins with NFA items. If you read the entire .pdf document, you'll see it includes almost everything firearm-related, whether or not the manufacturer engages in exporting. 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 cal- iber inclusive (12.7 mm). *(c) Firearms or other weapons (e.g. insur- gency-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 de- signed, modified or adapted components and parts. |
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