On Mon, Aug 1, 2016 at 2:00 PM, [email protected] <[email protected]> wrote:
> I won’t accuse the current administration of overreach … I don’t want to > stand in a line that long. > > > > My snarkiness aside, there is some wonderful Orwellian logic and wording > within the document Henry delivered. To my eye, the interesting broken > logic chain is: > > > > 1) Their claim that “DDTC applies the ordinary, contemporary, common > meaning of the term [manufacturing].” > > 2) That definition (copied from several dictionaries) includes: “the > *making > of goods or wares* by manual labor or by machinery”, “to process or make > (a product) from a raw material, esp as a large-scale operation using > machinery”, “build. Manufacture, assemble, fabricate apply to processes in > industry.” > > 3) Then the document provides a list of activities that not only > defy the “ordinary, contemporary, common meaning” but which often require > no tooling whatsoever, such as “modifications to a firearm that change > round capacity” (numerous kits available for this) and “the production of > firearm parts” and “blueprinting firearms by machining the barrel” > Much of what gunsmiths do is repair work, including corrective repairs which do improve the gun. Very often these involve using tools for "cutting, drilling, or machining" processes. Putting in a new barrel to replace a worn, corroded or damaged one most often involves threading the end of the barrel to match the threads in the receiver. Even if the replacement barrel comes threaded, it is often necessary to cut the end a bit to make a precise fit. > > > The other element that caught my eye, given the drive to license > ammunition buying here in California, was that “The systemized production > of ammunition, including the automated loading or reloading of ammunition” > now requires a license. Would two buddies multitasking, working a hand > reloading press while watching Sports Center, now be considered > “manufacturing” even if they were loading for themselves alone? It appears > so. > I read 1. Registration not Required–Not Manufacturing: ... h) Manual loading or reloading of ammunition of .50 caliber or smaller. as saying that unless the reloading press is motorized, then that's exempt. Hmm - what about shotgun shells? ".50 caliber" (1/2 inch) usually is applied only to pistols/rifles. But might the size be applied to shotgun shells - and bring reloading, e.g., 12 ga, under this ITAR Regulation? > > > > > Guy Smith > > [email protected] > > www.linkedin.com/in/gunfacts/ >
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