Just for the record, I installed this stunning Turnbull Retro Thumb safety the other day:
It functions perfectly and it did not require any fitting, machining, grinding or even any light engraving...
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Just for the record, I installed this stunning Turnbull Retro Thumb safety the other day:
It functions perfectly and it did not require any fitting, machining, grinding or even any light engraving...
Last edited by Pyrenean; 1st August 2016 at 11:24.
122.1 Registration requirements.(a) Any person who engages in the United States in the business of manufacturing orexporting or temporarily importing defense articles, or furnishing defense services, isrequired to register with the Directorate of Defense Trade Controls under §122.2. Forthe purpose of this subchapter, engaging in such a business requires only one occasion ofmanufacturing or exporting or temporarily importing a defense article or furnishing adefense service. A manufacturer who does not engage in exporting must neverthelessregister.
I probably am reading this section wrong but nonetheless..... As i read it all you have to do to be a manufacturer is to accomplish one of the tasks listed or insinuated in the body of the text. and now since you are a manufacturer you now have to have an ffL License. Its even worse than I had initially posted.
I am sure I will be reprimanded harshly for my silliness but this is the section that worries me in particular. But I also understand how this affects the trade as a whole and this EO is even sillier than I am.
Last edited by tom c; 1st August 2016 at 22:50.
Merriam-Webster defines "Manufacture" as:
Full Definition of manufacture
1
: something made from raw materials by hand or by machinery
2
a : the process of making wares by hand or by machinery especially when carried on systematically with division of labor
b : a productive industry using mechanical power and machinery
3
: the act or process of producing something
Modifying an existing part by filing ("fitting") certainly doesn't meet the definition of "manufacture".
And yes, I think this whole discussion has gotten silly. Even if I began with a 1911 frame and built it up with parts already made - even if they required fitting - would not meet the definition of "manufactured".
I suspect the DOS has their own, rather broad, definition of manufacturing in mind.
Regardless of what the business is, one is not in "business" if one performs the affected operations only for him/herself and there is no exchange of money or other valuable considerations.
When I was in high school, I cut lawns for some of the neighbors, and I received monetary compensation for doing so. It could be argued that I was in the business of providing lawn care services. Today, when I mow my own lawn and don't charge myself anything, I am not in the business of providing lawn care services. If I hire one of the many companies who leave advertising in my mailbox, I would have to pay them. They ARE in the business.
Hawkmoon
On a good day, can hit the broad side of a barn ... from the inside
This article defines "engaging in the busines of manufacturing". It aint my words. But i hope they go by your definition.
I hope you're right. However, DOS might take the position "manufacturing" on a thumb safety is no different than "manufacturing" on your own parts attempting to perform some full auto conversion.
I was involved at one time in a project with ITAR considerations; some pretty astounding rules/regulations. Logic didn't seem much involved in these.
The State Department has their OWN definition of manufacturing that has no relation to BATFE rules.
Being bureaucrats at the State Department they have no actual idea what many things take to accomplish.
They promulgate rules with no understanding.
They are busily trying to alter their order having kicked the hornets nest out of ignorance.
Amen, bridkeyee, Amen.
" I'm your huckelberry".
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