The comment period for this ends Aug 27th! Please make sure people in export or manufacturing get a link ASAP!
sorry if formatting gets mushed....
To: [email protected]
Sent: Wednesday, August 20, 2008 3:16 PM
Subject: ITAR Regulatory Change, 22CFR Parts 122 and 129
Gentlemen, August 20, 2008
I am writing this to comment on how the International Traffic in Arms Regulations will put many small business owners and firearms companies out of business.
You may not know this, but citizens in many foreign countries wish to buy and import sporting rifles, shotguns for bird hunting, and ordinary handguns.
There is a big trade going on now where Europeans want to do "cowboy shooting", and shotgun sports. Many of their historic guns were seized or destroyed during the World War, and under the Communists. The guns they want are coming from America, even some newly manufactured sporting rifles such as Finland's Tikka's, which are allocated 97% to the USA.
Folks world-wide want to get Winchesters, Marlins, Mossbergs, Rugers, Colts, Smith & Wessons, Glocks, Kahrs, Remingtons, and Kimbers. There are many dozens of American small arms companies serving the civilian market. You are proposing a severe regulatory tax on that whole business!
You need to make a provision for small arms, and situations where low priced items involve many separate export licenses.
You are adding a minimum of $250 to every attempted export of what might be a $175 dollar Marlin 22 rifle, even if that permit doesn't go through. Your proposed regulation concentrates the fee on businesses doing the export paperwork because they have the license. So if Joe Blow, a common gun
collector sells one hunting rifle on Gunbroker.com to a foreign buyer, his transaction clobbers the exporter who finds himself quickly at the third tier with prohibitive $250 per gun fees.
I hope you quickly see that this regulatory change was written for actual military weapons systems, and unfortunately would be applied to sporting arms. If this is not changed, one of America's important exports
will go out of business. And the value of American gun collections will fall, because the worldwide buyers are setting the top prices.
You could charge a lower fee, say $20 on each civilian arms transaction where the value if below $10,000.
Isn't the purpose of your law to keep weapons systems from North Korea and Iran and Syria? They don't buy Winchesters.
Respectively,
XXXXXXX
sorry if formatting gets mushed....
To: [email protected]
Sent: Wednesday, August 20, 2008 3:16 PM
Subject: ITAR Regulatory Change, 22CFR Parts 122 and 129
Gentlemen, August 20, 2008
I am writing this to comment on how the International Traffic in Arms Regulations will put many small business owners and firearms companies out of business.
You may not know this, but citizens in many foreign countries wish to buy and import sporting rifles, shotguns for bird hunting, and ordinary handguns.
There is a big trade going on now where Europeans want to do "cowboy shooting", and shotgun sports. Many of their historic guns were seized or destroyed during the World War, and under the Communists. The guns they want are coming from America, even some newly manufactured sporting rifles such as Finland's Tikka's, which are allocated 97% to the USA.
Folks world-wide want to get Winchesters, Marlins, Mossbergs, Rugers, Colts, Smith & Wessons, Glocks, Kahrs, Remingtons, and Kimbers. There are many dozens of American small arms companies serving the civilian market. You are proposing a severe regulatory tax on that whole business!
You need to make a provision for small arms, and situations where low priced items involve many separate export licenses.
You are adding a minimum of $250 to every attempted export of what might be a $175 dollar Marlin 22 rifle, even if that permit doesn't go through. Your proposed regulation concentrates the fee on businesses doing the export paperwork because they have the license. So if Joe Blow, a common gun
collector sells one hunting rifle on Gunbroker.com to a foreign buyer, his transaction clobbers the exporter who finds himself quickly at the third tier with prohibitive $250 per gun fees.
I hope you quickly see that this regulatory change was written for actual military weapons systems, and unfortunately would be applied to sporting arms. If this is not changed, one of America's important exports
will go out of business. And the value of American gun collections will fall, because the worldwide buyers are setting the top prices.
You could charge a lower fee, say $20 on each civilian arms transaction where the value if below $10,000.
Isn't the purpose of your law to keep weapons systems from North Korea and Iran and Syria? They don't buy Winchesters.
Respectively,
XXXXXXX
