Anyone recently get a type 07 FFL?

Anyone recently get a type 07 FFL?

This is a discussion on Anyone recently get a type 07 FFL? within the FFL Dealer Discussion forums, part of the Related Topics category; Hello Everyone, I hope everyone is having a wonderful weekend. I am in the process of filing for my FFL, I am trying to decide ...

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Thread: Anyone recently get a type 07 FFL?

  1. #1
    New Member Array paulwil6's Avatar
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    Anyone recently get a type 07 FFL?

    Hello Everyone, I hope everyone is having a wonderful weekend. I am in the process of filing for my FFL, I am trying to decide on the type of license I should get the type 01 or the
    type 07. I would love to be able to at one point be able to assemble AR15s and other firearms from parts, I have read about the possibility of having to pay an extra 2 grand a year
    for the 07 license, I have heard they do not enforce that anymore, I am wondering if anyone out there has dealt with this license recently. Any help or advice would be great, thanks for your time and reading.


  2. #2
    New Member Array IA_Mark's Avatar
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    It all depends on what you are going to do with it and how much money you have! According to the BATFE:

    Class 7

    Title 1 manufacturer of firearms and ammunition, who may also act as dealer; may not manufacture or deal in destructive devices, ammunition for destructive devices, or armor piercing ammunition. Must also register with the Department Of State under the ITAR Current registration costs start at $2,250 per year. Can also manufacture & deal in Title II NFA firearms with class 2 tax stamp.

    Class 1


    Title 1 dealer or gunsmith other than destructive devices. Can also deal in Title II NFA firearms with class 3 tax stamp.


    I hope that helps, be safe.

    Mark

  3. #3
    Member Array GrandBob's Avatar
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    ITAR is a function of the State Dept. not the ATF.
    I have never read anything from the ATF that even mentioned ITAR for anything other than importing or exporting.
    Where did you get that info?

    None of the 07's around me did the ITAR thing when their lawyers checked into it.

    I'm not a dealer so I dont know all the details but I understand that it is a subject of much controversy for some reason.

  4. #4
    VIP Member Array Tubby45's Avatar
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    ITAR is required whether you export or not. There have been a few FFL manufacturers that have been put out of business due to not being registered for ITAR. Blue Bunny Ammunition is one of them that comes directly to mind. They had to drop their 06 FFL and get an 01 FFL or the FBI would be coming with a warrant for the owner's arrest for not complying with ITAR registration.

    The State Department is not messing around anymore. They are enforcing ITAR registration.

    It's controversial because people read what they want to read. They don't think civilian sales equates to their products being "defensive articles" per ITAR code. They are very, very wrong. The ITAR itself clearly states "Manufacturers who do not engage in exporting must nevertheless register.". You can't deny the clarity in that statement. Everything firearms and ammunition is a defensive article no matter if it's for military or government. Even cast lead bullets are a defensive article.

    Here's the PDF of the ITAR registration requirements. First paragraph, last sentence.
    http://www.pmddtc.state.gov/regulati...r/Part_122.pdf
    07/02 FFL/SOT since 2006

  5. #5
    Member Array GrandBob's Avatar
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    From what I hear, ITAR is required if you manufacture a Defense Item.

    If it is manufactured for specific civilian use, it is not a defense item...and the reason that the only 07's that register with ITAR are the ones that are selling to the government, which classifies it as defense articles.

    Or so I've been told. I dont have a dog in this hunt so I dont care really, but I do know several 07's that arent ITAR and one that is, for years he was not and then he started sending stuff to the Middle East for the military and before he could do that, registering with ITAR was a prerequisite.
    There is enough crap on the net about ITAR to make your head spin, and most of it is wrong, sort of like Class 3 stuff.

  6. #6
    VIP Member Array Tubby45's Avatar
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    Quote Originally Posted by GrandBob View Post
    From what I hear, ITAR is required if you manufacture a Defense Item.

    If it is manufactured for specific civilian use, it is not a defense item...and the reason that the only 07's that register with ITAR are the ones that are selling to the government, which classifies it as defense articles.
    No. That's wrong information. It doesn't matter if the manufacturer sells to the government or military or export. They are a manufacturer and they must register. Period. A firearm manufactured for ultimate sale to a domestic civilian (ie an American citizen) is just as much of a defensive article as a firearm manufactured for ultimate sale to the military, government or for export. It doesn't matter one bit who the end user is. If you are a manufacturer, you MUST register.

    Here's more proof:

    From: Brian XXXXX [mailto:lbXXXXX@gmail.com]
    Sent: Tuesday, February 21, 2012 11:51 AM
    To: DDTC Response Team
    Subject: class 6 ffl bullet casting

    I am exploring the idea of starting a business engaging in the manufacture of cast lead bullets. These bullets would be constructed from raw lead. The company will not be importing or exporting any goods or services. The business will not engage in the manufacturing of complete ammunition.

    Do I need to register with the State Dept under ITAR

    If so what are the fees if any

    Brian XXXXX
    Their response:

    from: DDTC Response Team ✆
    February 21, 2012 12:28 PM
    to: me

    Yes, you will be required to register. Category III of the US Munitions list includes all ammunition components including the bullets. Manufacturers of the components are required to register with DDTC.

    Go to U.S. State Department - Policy - Directorate of Defense Trade Controls and on the Home Page click on the link to Registration. There you will find the application form and complete instructions for a complete submittal package.
    If this is a renewal of registration, please note that renewal is exactly the same as registering for the first time. You must submit a complete package.

    Send your documents by courier service (FedEx, DHL, or UPS) to:

    U.S. DEPARTMENT OF STATE
    PM/DDTC, SA-1, 12TH Floor
    Attn: Registration
    2401 E Street NW
    Washington DC 20037



    Stephen M. Geis
    DDTC Response Team
    Contractor, XL

    NOTE: Information in this message generally discusses controls and information contained in the Arms Export Control Act and International Traffic in Arms Regulations (ITAR), both of which are authoritative on this matter. The Response Team fields basic process and status questions, and assists exporters in identifying how to get answers to more complex questions handled by the Directorate of Defense Trade Control's licensing and compliance offices. The Response Team's services are not a substitute or replacement for the advisory opinion, general correspondence, and commodity jurisdiction processes delineated in the ITAR, which should be used to obtain authoritative guidance on export control issues, and do not in any way relieve exporters from their responsibilities to comply fully with the law and regulations.


    This email is UNCLASSIFIED.
    No US military or US government agency currently uses cast lead bullets. Therefore, they are only for manufacture to American citizens and not exported. The manufacturer is still required to register because cast lead bullets are a defensive article by definition in the ITAR regulations. Period.

    People that think ITAR is only for government, military, or export are sorely misinformed. Any lawyer that says otherwise should be the one to pay the fine and sit in prison on your behalf when they get the taste of crow in their mouth.
    07/02 FFL/SOT since 2006

  7. #7
    New Member Array mcoker's Avatar
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    I'm in the process of applying for my FFL and was going for the Type 07 before I started reading about ITAR. Those saying don't worry about it are generally focusing on whether or not it is enforced - not whether it is the law.

    I guess I'm going to switch to Type 01. Not complying with ITAR is a felony - meaning no guns and no job.

  8. #8
    VIP Member Array Tubby45's Avatar
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    The ATF is also well aware of ITAR. Read the latest FFL newsletter on the ATF website.
    07/02 FFL/SOT since 2006

  9. #9
    VIP Member Array blitzburgh's Avatar
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    This has me interested in the 07 FFL...
    "Rebellion against tyrants is obedience to God." - Benjamin Franklin
    "Experience: that most brutal of teachers. But you learn, my God do you learn." - C.S. Lewis

  10. #10
    New Member Array shawn2820's Avatar
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    What about a Hydrographics buisness?

    Im starting a hydrographics buisness and wanting to apply for my ffl licence to be able to dip firearms. Which ffl would be better in your opinion? 01 or 07? I really dont want to have to pay 2200 dollars to be able to have it. Thanks for any input.

  11. #11
    VIP Member Array Tubby45's Avatar
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    Yes, it's a manufacturing process and you must be licensed as a manufacturer. You will also have to register for ITAR.
    07/02 FFL/SOT since 2006

  12. #12
    New Member Array gstrunk's Avatar
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    FFL Type 01 or 07

    Quote Originally Posted by paulwil6 View Post
    Hello Everyone, I hope everyone is having a wonderful weekend. I am in the process of filing for my FFL, I am trying to decide on the type of license I should get the type 01 or the
    type 07. I would love to be able to at one point be able to assemble AR15s and other firearms from parts, I have read about the possibility of having to pay an extra 2 grand a year
    for the 07 license, I have heard they do not enforce that anymore, I am wondering if anyone out there has dealt with this license recently. Any help or advice would be great, thanks for your time and reading.
    I recently received my FFL Type 07 and cost $150 every three years. I think the 01 is around 200 every 5 years. I learned you will need to pay an additional Special Occupation Tax (SOT) of $500 every year to manufacture. I don't know if this is current since I just started. (This assumes quantity of 50 or less per year) and sales under $500,000).

    I'd like to get some additional information of this subject as well. ATF isn't real good at pointing these things out other than handing you a book of their requirements.

  13. #13
    VIP Member Array Tubby45's Avatar
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    Quote Originally Posted by gstrunk View Post
    I learned you will need to pay an additional Special Occupation Tax (SOT) of $500 every year to manufacture. I don't know if this is current since I just started. (This assumes quantity of 50 or less per year) and sales under $500,000).
    To manufacture NFA firearms like suppressors, short barreled rifles, short barreled shotguns, machine guns, yes that is true. The SOT tax is $1,000 per year for manufacturers, but if your gross sales receipts are less than $500,000 it's only $500 per year. If you are just manufacturing Title I firearms, then the Class 2 SOT doesn't apply.

    The 50 or less per year is not an SOT tax rule, it's an FAET (Firearms and Ammunition Excise Tax) rule. The ATF cannot advise on excise tax anymore since Bush split the ATF into two. The TTB (Tax and Trade Bureau) handles excise taxes. The ATF handles The NFA and GCA laws.
    07/02 FFL/SOT since 2006

  14. #14
    VIP Member Array Tubby45's Avatar
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    Quote Originally Posted by gstrunk View Post
    ATF isn't real good at pointing these things out other than handing you a book of their requirements.
    Your IOI (Industry Operations Inspector) was probably a moron. Welcome to dealing with the Federal government.

    PM me your number. I'll call you Saturday and bring you up to speed on questions you have.
    07/02 FFL/SOT since 2006

  15. #15
    Member Array john.shewchuk's Avatar
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    I recently applied for, and recieved my 07 FFL. I am waiting to get my 02 SOT back, but my check went out two weeks ago...

    Anyways, back to ITAR. It is required, but there are exceptions.

    For example, for at least the first few years I am in business, I will not be selling ANYTHING I manufacture. In other words, I will be manufacturing for Research and Development ONLY. This is an exception to ITAR, therefore I am exempt from paying.

    However, should I ever sell anything I have manufactured (keep in mind the ATF's definintion of manufacture.... even installing night sights on a pistol for the purpose of resale, for example) I must immediately register with ITAR...

    Kinda stinks, but it is what it is....
    Owner, Maple Leaf Firearms LLC (07 FFL/02SOT)

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