Type of FFL needed to work on cosmetic gun issues?

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Precision
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Type of FFL needed to work on cosmetic gun issues?

Postby Precision » Tue Oct 09, 2012 4:39 pm

I did some research and the answer seems to be as clear as mud.

It looks like I need a 07 FFL. Which costs very little and last for 3 years , but I also have to pay the ITAR scam each year for $2250.

This gets me the right to do stock repair and refinishing the barrels, with the ability to ship directly back and forth as well as keeping the firearm overnight. The overnight thing is mandatory.

There is a way around (I think) if I use a compliant FFL and pay their fee both ways or if I do not hold the firearm overnight (kinda impossible).

Is this correct or am I overlooking something obvious (other than the need to disband the ATF)?
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Precision
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Re: Type of FFL needed to work on cosmetic gun issues?

Postby Precision » Wed Oct 10, 2012 2:45 am

That is what common sense told me (more or less) but ATF -not equal- common sense.

So basically I pay my money, wait my time, get an "ITAR not needed" plan and get a FFL 1 if I never plan to assemble / build guns, a FFL 7 if I may build or assemble some guns or a ffl 10 if I want to ever make destructive devices.

No interest in DD, but an occasional assembly or build would not be out of the question. Mission creep and all for loyal customers would probably go there in time.

Does that have any effect on my current C&R?

Do I need to have a store front to keep ATF out of the house with their midnight house tossings?
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Re: Type of FFL needed to work on cosmetic gun issues?

Postby HTRN » Wed Oct 10, 2012 9:20 am

I think there was a ruling not so long ago, maybe 3 or 4 years, that defined it as such - if a customer sends you a gun, it's gunsmithing. If you buy a gun, and refinish it for resale, then it's manufacturing...

But don't quote me on this - I'm going by vague memory here..
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Precision
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Re: Type of FFL needed to work on cosmetic gun issues?

Postby Precision » Wed Oct 10, 2012 12:02 pm

So to recap.

My initial goal is to accept guns (some via face to face - some via UPS) for refinishing of stocks and metal work. As an example, I took a sandblaster to my dad's J Higgins .22 barrel and action then gunkoted it up. I also sanded down the stock, re-stained it and put a few coats of poly on it.

I could do this with an 01, but if I wanted to build a custom rifle in the future (from components) it would be a better idea to go ahead and get the 07 now. Not to mention if I get an 80% reciever and complete it I would definitely need an 07 to do that.

Storefront will likely be required to get wholesale pricing on components, especially serial # ones but is not NEEDED for the license itself.
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Re: Type of FFL needed to work on cosmetic gun issues?

Postby HTRN » Wed Oct 10, 2012 5:15 pm

CByrneIV wrote:ITAR is not technically required unless you export,


A number of 07 FFL holders have reported that some BATFE agents are now asking about ITAR during IOI reviews..
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Re: Type of FFL needed to work on cosmetic gun issues?

Postby Precision » Thu Oct 11, 2012 1:53 am

HTRN wrote:
CByrneIV wrote:ITAR is not technically required unless you export,


A number of 07 FFL holders have reported that some BATFE agents are now asking about ITAR during IOI reviews..

I have heard that. Also when I was considering making ammo during the shortage, State demanded their ITAR tithe even though I was planning on producing .380 for domestic consumption. Their point was that I could not prove that someone else would not transport or resell it overseas.

:evil:
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Re: Type of FFL needed to work on cosmetic gun issues?

Postby FastRope71 » Wed May 08, 2013 2:24 pm

What Chris said.

I have my 07 FFL. I got it just for this very purpose. I only got the 07 instead of the 01 "just in case" I wanted to knock together some AR15s for sale to folks. My interviewer had no issues with that. She was also very cool (which surprised the Hell out of me).

Your greatest hurdle will likely be the fire department. Since part of my potential business model is ammunition manufacturing It caused me a slight amount of grief. In the end I have my FFL (good thing I am outside the ETJ of the local towns).

To answer your question: If all you are going to do is cosmetic, you need a FFL01. This gives you a substantial amount of leeway, some of it even codified in the regulations. (appointment only vs. standard hours open to the public).
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Re: Type of FFL needed to work on cosmetic gun issues?

Postby NVGdude » Tue May 14, 2013 7:36 am

Precision wrote: Their point was that I could not prove that someone else would not transport or resell it overseas.

:evil:


BS. ITAR deal with EXPORT. If you sell to an American and they export something THEY broke the law, not you.


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