Working on Firearms? Be aware of ITAR registration... it may apply to you!

MidOhioHydrographicsMidOhioHydrographics Member, Moderator, Business Ninja Posts: 10,501 El Moderator
First, I'm not a lawyer or federal agent of any kind, so don't take any advice directly from me. This is just a heads up as we noticed some things on the firearms side that you may want to look into if you're doing firearm related activities. Also, this isn't necessarily geared toward hydrographics, but Firearms are a large part of the industry.

Here's a list of things that would require registration with ITAR (which is $2250 per year).

State has defined the following activities as manufacturing which require ITAR registration:
  1. Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms;
  2. Modifications to a firearm that change round capacity;
  3. The production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors);
  4. The systemized production of ammunition, including the automated loading or reloading of ammunition;
  5. The machining or cutting of firearms, e.g., threading of muzzles or muzzle brake installation requiring machining, that results in an enhanced capability;
  6. Rechambering firearms through machining, cutting, or drilling;
  7. Chambering, cutting, or threading barrel blanks; and
  8. Blueprinting firearms by machining the barrel.
So basically many "gunsmithing" activities would require ITAR registration, such as threading barrels. You do not have to be a Federal 07-FFL (manufacturing) to need to register for ITAR, and also the reverse. I have my 07-FFL, but do not do any of the above mentioned items, so no ITAR for me. Again, look into it if you are indeed performing any of these activities.

Just some friendly advice. Have a great day!


  • WileECoyoteWileECoyote Member, Moderator, Business Ninja Posts: 7,776 El Moderator
  • NWHNWH Member Posts: 98 ✭✭✭
    Before I gave up my 07FFL i was lucky enough to receive a audit and this came up with the ATF agent she did suggest I go to a 01FFL at the time as in 2012 they had a ruling that stated you did not have to have a 07 anymore to do hydrographic work for manufactures in the firearm industry but if we were to keep our 07 we would have to get a variance from the ITAR and that they were going to start enforcing this as part of the 07FFL.
  • MidOhioHydrographicsMidOhioHydrographics Member, Moderator, Business Ninja Posts: 10,501 El Moderator
    I just had an audit week before last and it wasn't mentioned. Doesn't surprise me that your agent brought it up. Each agent is a little different in their interpretation.

    ITAR requires at least 1 instance of manufacturing (all my reports have been 0's), or any of the above listed items, which I don't do. I have my 07 due to my close involvement with another firearms manufacturer in case I ever need that capability. So far I haven't, but I'm going to retain it in case.
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