manufacturing suppressors and ammo


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davidp
June 26, 2011, 08:13 PM
Hi everyone, I am interested in building suppressors for my personal guns, and possibly selling them if I can perfect a design. I know that I would need a form 1 to build one for myself, but I really dont want to pay $200 for each unit if I intend to make any sort of profit selling them. would I be able to avoid the $200 stamp if I were to get an FFL, and if so, what type/class would I need to apply for? I would also like to start reloading ammo for myself, and maybe sell some of the reloads at local gun shows or online. Do I need an FFL to sell ammo?

Sorry for all the newbish questions and thank in advance for any info.

David

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Sam Cade
June 26, 2011, 08:19 PM
Wikipedia. Its pretty handy.

http://en.wikipedia.org/wiki/Federal_Firearms_License

davidp
June 26, 2011, 08:27 PM
I read that earlier, but am a bit confused by the different types. Would a type 7 cover me or do i need to go with a type 10? I would only be reloading pistol and rifle ammo, no destructive device stuff.

Thanks again
David

kingpin008
June 26, 2011, 09:19 PM
Sam - go easy on him a little, eh?

Davidp - First off, welcome to THR. I'm by no means an expert in NFA issues, but from my understanding, no, a type 7 will not cover you as it does not involve ammunition. At first glance, a type 10 would do it. You would also need to become an SOT, and pay the necessary ITAR fees, insurance, etc.

I'm sure I've probably left something out, but luckily we've got quite a crew of folks much more knowledgeable than I who will be along shortly to fill in any gaps and possibly tell me to mind my own business. :D

davidp
June 26, 2011, 09:51 PM
Would the type 7 cover building/selling suppressors? When is the SOT needed? I saw no mention of NFA regulated accessories, just weapons or are they considered the same thing? I'm not set on selling ammo, but i would like to try to make an affordable suppressor. I already have the machinery to build them, its just the legal aspect I'm worried about.

Thanks
David

kingpin008
June 26, 2011, 09:54 PM
Would the type 7 cover building/selling suppressors? When is the SOT needed?

Yes, with a Class II SOT. The type 7 FFL covers the manufacturing of plain ol' firearms, the Class II SOT allows you to also manufacture NFA goodies.

I saw no mention of NFA regulated accessories, just weapons or are they considered the same thing?

Suppressors are considered NFA items.

HTH.

davidp
June 26, 2011, 11:45 PM
Ok, that doesn't seem too bad. What is the deal with ITAR? I have no interest in exporting anything I produce, would I still have to register? This post: http://www.thehighroad.org/showpost.php?p=6144914&postcount=21
makes it sound like if you intend to sell only domestically, that you might be able to avoid paying ITAR. Also, what kind of insurance would be required/recommended for a low volume manufacturer of weapon parts (primarily suppressors)

Again, sorry for all the newb questions, and thanks for the advise,
David

kingpin008
June 27, 2011, 12:16 AM
Those, I'm afraid I can't answer. FWIW, I'm pretty sure ITAR will still apply, but they've both been discussed before on this forum and the site in general, so you should be able to find some info with a search. :)

No worries about the questions, it's what this place is here for! Frankly, I'm suprised that none of the more knowledgeable folks have chimed in yet - I guess I've been getting it right so far. :what:

Shadow 7D
June 27, 2011, 12:30 AM
see that's the thing, there is NO money in low volume.
just the licensing and fees KILL you, so I would say, build your own, no need for extra special licensing, just pay your taxes. Get good, then see if it's worth it to try to break in.

kingpin008
June 27, 2011, 12:58 AM
I kinda had the same thought. Sure, the $200 sucks, but you'll be paying WAY more in fees, taxes & operating costs to maintain the necessary licenses to become a manufacturer.

Sam Cade
June 27, 2011, 03:54 AM
I would imagine that the amount of liability insurance that an entity involved in ammunition manufacture has to carry is staggering.

I bet $1,000,000 or more.

HD Fboy
June 27, 2011, 06:20 AM
Yes. You will have to register. Read the ITAR regs. I can strongly advise you hire an ITAR consultant. ITAR is painful.

I don't build firearms but spent $15000 on ITAR education and still hired a consultant. It is much worse than security classification regulations.

Even if you do the $200 per unit ITAR regs still apply. You need to educate yourself.

Zak Smith
June 27, 2011, 01:13 PM
ITAR registration is required for anyone who is in the business of manufacturing items on the munitions list (USML) -- whether or not you actually export or not.

A form 1 (the "$200 per unit") build does not require ITAR registration because by definition, if you are in the business of manufacturing silencers you have an SOT, and you aren't doing Form 1 builds.

This is not legal advice, just my opinion based on reading the ITAR documentation.

dprice3844444
June 27, 2011, 02:20 PM
just get a class 3 and be buddy buddy with a class 2

kingpin008
June 27, 2011, 02:32 PM
just get a class 3 and be buddy buddy with a class 2

Why? The OP wants to MAKE the suppressors himself. You can't do that commercially with a Class III. And what exactly is your definition of "buddy buddy"? Because depending on what it is, I'll bet money the ATF wouldn't look too kindly upon it.

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