Questions for the FFL/ gunsmiths on the board.

[txfireguy2003]

I've been working on my own guns for years and helped with a few jobs for friends (without pay, just favors) but I'm starting to get requests from folks to bed their rifles, replace their triggers etc and I'm not willing to do it with being paid for my time. I started looking into getting my FFL a while back but I'm struggling with the distinction between "gunsmith" and "manufacturer". Right now, I'm not equipped to do anything that would throw me into the manufacturer category, but I'd like to get there some day..... but then I have to pay the $2250 ITAR fee. I'm just confused about which license I should be applying for and was hoping someone who has been down this road before could help me out.

As an example of the type stuff I've been doing for free:
Bed actions/free float barrels
Replace/ adjust triggers
Load development
Mounting scopes
Lapping lugs

Of course, the occasional transfer for online buyers as well.


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[Samson]

For everything you list, except load development, a type 01 would cover it, no need to go 07. Manufacturing ammo, other than giving the customer the load recipe, will require an 06. Manufacturing is exactly that, making a firearm, not improving on them. Now if you are buying stripped actions, and making them into rifles or buying pistol frames and completing them, then you will need an 07 and to register with ITAR. There are several FFLS that have ITAR exemption letters for assembling AR-15 type rifles from receivers as long as no machining is done. I would most certainly no matter what buy a million dollar GL insurance policy if you are working on other people's guns. That will pay for your legal fees should something go wrong and you get sued. Hope that helps, I gave up my 01 this September and looking to refile my application.

[txfireguy2003]

Thanks. That's how I understood it, except a few things. As I read it, machining, so drilling, threading etc, even on a complete factory gun, say cutting and threading a rifle muzzle, requires an 07....I know it makes zero sense, but that's what I read. On other words, if I use a lathe or mill, I have to pay ITAR according to what I read a few months ago.
On the ammo issue, I read where a manufactures license (06 OR 07) was not needed for "manual loading" but only if an automated or systematic loading factory was used. By those standards, my single stage Rockchucker and beam scale should qualify as manual.

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