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Comments Needed on Proposals to Update Export Rules, Ease Burdens on Firearm-Related Businesses

Friday, June 8, 2018

Comments Needed on Proposals to Update Export Rules, Ease Burdens on Firearm-Related Businesses

We recently reported on proposed rules announced by the Trump Administration to update the U.S. export regime for firearms and ammunition and to ease burdens and red tape on domestic firearm-related businesses, especially gunsmiths and manufacturers. Comments on these proposals are still urgently needed to help refine the final rules and ensure the voices of America’s small firearm-related businesses and gun owners are heard.

We have reported for many years on the difficulties that domestic firearm-related businesses and gun owners experience because ordinary guns and ammunition readily available on the open market and owned by many law-abiding people are classified as “defense items” for purposes of federal export laws.

For example, there is the annual registration fee, currently set at $2,250, that “manufacturers” of defense items must pay to the State Department, whether or not they export their products. This requirement falls especially heavily on small, non-exporting businesses, some of whom don’t even make complete firearms but are still required to pay the fee because their wares are considered parts, components, or accessories of regulated guns.

Then there are gunsmiths who merely work on existing firearms but are still considered “manufacturers” under the current export regime because they perform certain machining operations, which could be as simple as threading a muzzle or blueprinting the action of a firearm.

Hunters and competitors traveling overseas with personally-owned firearms have also been caught up in this regime because of Obama-era requirements to register “temporary exports” in an unwieldy government database designed around the needs of exporting businesses, not private travelers.

Bloggers, firearm writers, and handloaders posting online guides or tutorials have had their own worries about whether their activities constitute the “export” or unauthorized release of “technical data” on defense items, subjecting them to prison time and steep fines. 

Even firearm instructors teaching classes solely within the U.S. could be providing unauthorized “defense services” if their curriculums strayed into broadly-defined categories of “training” in the “use of defense articles” and their students happened to include individuals not considered “U.S. persons.”

Then, of course, there are the firearm and ammunition manufacturers who would like to compete for contracts to provide their goods or services to foreign militaries or law enforcement agencies but are stymied from competitive bids because of the considerable red tape imposed by the current rules.

In short, if your business or activities have been adversely affected by regulation of readily-available firearms and ammunition, or their components or accessories, under the Arms Export Control Act and the International Trafficking in Arms Regulations (ITAR), the government needs to hear from you.

Under the Trump proposals, most non-automatic firearms of .50 caliber or less, as well as their parts, components, accessories, and magazines of up to 50 rounds capacity, would be moved from the jurisdiction of the State Department under ITAR to the more business-friendly Commerce Department. Actual export of the items would remain closely controlled and still subject to licensing in most cases, but under more flexible rules consistent with their status as “dual-use” items that have well-established and lawful uses in non-military markets.

The easiest way to file comments is through the U.S. government’s online regulatory portal, Regulations.gov. The State Department’s proposed rule and comment form are available at this link. Use this link for the Commerce Department’s proposal. 

The most effective comments will clearly, succinctly, and respectfully relay real-world experiences with the current regime and the problems it presents. They will also address specifics of the current proposals, such as the omission of sound suppressors from the planned moves and the retention of complicated “temporary export” rules for private persons traveling abroad with personally-owned firearms. Form letters copied and pasted from the Internet are usually the least helpful type of comments, because they are not responsive to the specifics of the proposals or their real-world effects on stakeholders.

While it is fine to express general support for the proposals, the comment period is not a public referendum on whether or not they should be enacted but a chance to improve them by bringing up problems, ambiguities, or inconsistencies in the proposals themselves. In some cases, professional groups may want to pool their resources and hire outside experts to ensure their viewpoints and interests are clearly presented to the agencies. But less formal comments from individual stakeholders can also be very helpful. The Regulations.gov online portals make submitting comments as easy as sending an email.

The NRA itself has received many articulate, well-written letters and emails over the years from hunters, gunsmiths, firearm instructors, small businesses and other professionals negatively impacted by ITAR. These rulemakings are an ideal opportunity to present those same concerns and perspectives to the very officials who will be rewriting the rules to ensure they provide adequate protection to national and international security, without unduly burdening law-abiding American individuals and businesses.

Comments are due by Monday, July 9. These updates to America’s export control regime are among the most important pro-gun initiatives by the Trump administration to date. We urge you to ensure the best possible outcome with your own input.

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Established in 1975, the Institute for Legislative Action (ILA) is the "lobbying" arm of the National Rifle Association of America. ILA is responsible for preserving the right of all law-abiding individuals in the legislative, political, and legal arenas, to purchase, possess and use firearms for legitimate purposes as guaranteed by the Second Amendment to the U.S. Constitution.