Manufacturing and licensing questions

[Pappy1600]

I would like to say thank you for the add first of all, a little back ground about myself, I am recently retired Law Enforcement Officer and Police Firearms and general topics instructor for over 20 years, I have been a FFL Type 01 and SOT 03 NFA dealer since 1999, since I have retired and have plenty of time on my hands I was considering possibly getting my 07/02 license as well. I have some questions relating to manufacturing, the majority of my NFA dealings are with Law Enforcement, and I am considering manufacturing Post Samples for demos.

 

My SOT is coming up on renewal and I would like to know if the Class 02 manufacturer covers dealer as well? or am I required to pay for the 03 as well as the 02 SOT?

 

Since I only hold a type 01 FFL and considering a 07 manufacturers license I was told that I would have to reapply for the 07, since my type 01 is up for renewal this upcoming November figured I would start it now, my sales are less than $500k a year.

 

I would like to hear back from anyone that has gone this route and if you have anything to add that would be helpful in understanding this process it would be greatly appreciated, any pros and cons? obviously not looking to get rich but would like to have something that keeps me busy and actually help local LE with purchasing. If you have anything else to add please let me know. I will not be manufacturing in volume probably a couple of guns a year if that makes a difference.

 

Regards,
​Terry

[Black River Militaria CII]

If you want to manufacture NFA and regulated items, register and sell them, then an SOTII is required with the FFL07 manufacturer's license. The SOTII covers dealing NFA and some other privileges. Your EIN remains the same and you can apply to ATF Licensing for the SOT2 payment/receipt form. You will have to apply for the FFL07. FWIW

[Rich.Urich]

Don't forget the $2250.00 fee to State Department yearly for "manufacturers":

https://blog.princelaw.com/2012/08/10/department-of-state-is-stepping-up-enforcement-of-itar-related-to-manufacturers/

 

I know of licensed manufacturers / gunsmiths who thought they could get away with not paying this fee... they got caught and had to pay the fee and back assessments they missed.

[Pappy1600]

Don't forget the $2250.00 fee to State Department yearly for "manufacturers":

https://blog.princelaw.com/2012/08/10/department-of-state-is-stepping-up-enforcement-of-itar-related-to-manufacturers/

 

I know of licensed manufacturers / gunsmiths who thought they could get away with not paying this fee... they got caught and had to pay the fee and back assessments they missed.

Well that just put a damper on my parade..

[Rich.Urich]

Time for the Trump Administration to get involved with removal of "Burdensome Regulations" such as this!

Contact the White House and find out who you should direct a letter about requesting these ITAR regs be changed... also check with NRA-ILA.

[HB of CJ]

Not much to add. Years ago I was a Class 3 Dealer. Be sure to legally separate the business in every possible fashion from your very private person. Be sure to research the hidden business costs such as security, zoning, local licenses and insurance. Good luck. Respectfully.