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  1. #1

    Arrow Question about a Type 07 FFL and ITAR

    Quick question guys, I am currently thinking acquiring my type 07 ffl. I have heard from many people and forums that I would have to register with ITAR. If I don't plan on any export do I still have to register with ITAR and pay the yearly fee of $2250? Thanks in advance!
    My Feedback

    Hi, my name is Shawn and I suffer from BRD. (black rifle disease)

  2. #2

    Default Re: Question about a Type 07 FFL and ITAR

    Yes. If you manufacture anything on the ITAR list you have to register. Whether you export or not does not matter. You will have a lot of 07's say you don't have to and they never did, but you are running a big risk if you don't. ATF does not enforce it as it is a State Department regulation.


    Sec. 122.1 Registration requirements.

    (a) General. Any person who engages in the United States in the business
    of either manufacturing or exporting defense articles or furnishing
    defense services is required to register with the Office of Munitions
    Control. Manufacturers who do not engage in exporting must nevertheless
    register.

    (b) Exemptions. Registration is not required for: ...

    (2) Persons whose pertinent business activity is confined to the
    production of unclassified technical data only. ...

    (4) Persons who engage only in the fabrication of articles for
    experimental or scientific purposes, including research and development.

    (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.
    My Feedback Link

    "How a politician stands on the Second Amendment tells you how he or she views you as an individual; as a trustworthy and productive citizen, or as part of an unruly crowd that needs to be lorded over, controlled, supervised, and taken care of." - Dr. Suzanna Gratia Hupp

  3. #3

    Default Re: Question about a Type 07 FFL and ITAR

    That's what I thought. Unfortunately the ITAR list says pretty much all guns. Thy love to tax small businesses out of existence i guess.
    My Feedback

    Hi, my name is Shawn and I suffer from BRD. (black rifle disease)

  4. #4

    Default Re: Question about a Type 07 FFL and ITAR

    You can thank the UN and the State Dept. for that insanity.
    Mike N
    Norman, OK

    Support the entire constitution.
    Not just the parts you like.

    My Feedback

  5. #5

    Default Re: Question about a Type 07 FFL and ITAR

    Do you actually plan on manufacturing guns? If you wont be doing manufacturing, just selling, you don't need it.
    My Feedback Thread

  6. #6

    Default Re: Question about a Type 07 FFL and ITAR

    Yes sir, mainly ar15 lowers. I have been playing around with a cnc machine alot lately. I had a wild hair one day to try and make an "80%" lower from billet. It came out great so i figured I would try my hand at that as a side business.
    My Feedback

    Hi, my name is Shawn and I suffer from BRD. (black rifle disease)

  7. #7

    Default Re: Question about a Type 07 FFL and ITAR

    Quote Originally Posted by ripnbst View Post
    Do you actually plan on manufacturing guns? If you wont be doing manufacturing, just selling, you don't need it.
    The OP asked about a type 07 FFL which is a manufacturing FFL. A dealer FFL is a type 01 FFL. You will also sometimes see someone who says they are an 01/03 or an 07/02. In case you are wondering what the xx/xx numbers mean, the first number is the type of FFL and the second is the Class of SOT (Special Occupational Taxpayer).

    Type 1 FFL is a Title 1 dealer or gunsmith
    Type 2 FFL is a Title 1 dealer doing business as a pawnbroker
    Type 3 FFL is a licensed collector of Curio & Relic (C&R) firearms
    Type 6 FFL is a licensed maker of ammunition and reloading components other than Armor Piercing ammunition
    Type 7 FFL is a Title 1 manufacturer of firearms, ammunition and ammunition components other than NFA, Destructive Devices and Armor Piercing ammunition
    Type 8 FFL is an importer of Title 1 firearms and ammunition
    Type 9 FFL is a dealer in Title 1 firearms including NFA destructive devices, but no other NFA
    Type 10 FFL is a manufacturer of Title 1 firearms, ammunition and ammunition components, including NFA Destructive Devices but no other NFA, and not including Armor Piercing ammunition
    Type 11 FFL is an importer of Title 1 firearms, ammunition and NFA Destructive Devices, but no other NFA

    Class 1 SOT importer is an importer of NFA firearms
    Class 2 SOT manufacturer is a manufacturer of NFA firearms
    Class 3 SOT dealer is a dealer of NFA firearms

    To get a Class 1 SOT status, you need an importer FFL, which includes Type 8, 11- and pay a yearly $1000 or $500 (reduced rate for small importers) tax due every July 1st.

    To get a Class 2 SOT status, you need a manufacturer FFL, which includes Type 7, 10 - and pay a yearly $1000 or $500 (reduced rate for small manufacturers) tax due every July 1st.

    To get a Class 3 SOT status, you need a dealer or manufacturer FFL which includes Type 1, 2, 7, 8, 9, 10 or 11 - and pay a yearly $500 tax due every July 1st.
    My Feedback Link

    "How a politician stands on the Second Amendment tells you how he or she views you as an individual; as a trustworthy and productive citizen, or as part of an unruly crowd that needs to be lorded over, controlled, supervised, and taken care of." - Dr. Suzanna Gratia Hupp

  8. #8

    Default Re: Question about a Type 07 FFL and ITAR

    making 80% lowers should require no ffl, no markings, no serial number as its not a completed item.
    thats the whole point to it. if you have to get an ffl and keep records you might as well finish them 100%.
    just remember those 80% makers always have uncle sam looking over their shoulder.
    watching, waiting for them to screw up and sell a completed one with no records, ser# or excise tax paid.

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