Mr AR15:
Just so you know, it was never my intent to step on your toes.
I had no idea anyone else was doing anything like this, and I had no idea that anybody in Canada would ever want these types of products. I was contacted by many Canadians who asked for the Kits so I gave it a try, mostly in the spirit of good will as opposed to profit. Sales volume to CA was never expected to be high, I just wanted to get the Kits to fellow shooters. Any increase in sales volume is, of course, helpful when working toward reducing production and retail costs.
I know this is good news to you, as regards your Canada sales, as the less competition the better.
Our products would have ultimately been at two different price points, perhaps more complimentary than competitive. Your product does look terrific, however, it certainly will have a higher selling price due to all the extra pieces and machine time. It's when you start business with the distributors and dealers that pricing will get strange, plan ahead carefully. I know you are a grown up so please don't take this the wrong way.
It's a dog-eat-dog world out there...
Given what has occurred with my product classification, I suspect that your Kits will be considered by the US Gov't almost the same as a complete firearm and be subject to the same regulations for import into the US as would a shipment of handguns or rifles from a European country. I may be wrong but it sure does seem like the wind is blowing the wrong way right now. The fact that the current, recently revised regulations for the import and export of these products are not even available to the public months after the Obama administration has taken control does not bode well.
I wish you the best of luck with your Kits.
Max Owner:
9 copies of the Export Application had to be included in the initial mailing to the State Dept. They were distributed to at least three different US Gov't agencies, each with their own agenda. The criteria for decisions and how the "votes" are tallied is not available to the public. An appeal could be tried, but to who, on what grounds, and if the decisions were not based on facts, but on political agendas, the use of logic or common sense in the appeal will be a moot point.
Here's the real kick in the head for me, per the US Gov't reply letter, my reward for playing by the rules:
My Kits have been classified as "Military Equipment".
This means I am now officially a "Manufacturer of Military Equipment".
The fact that the guns or Kits are rimfire not centerfire has no bearing.
"Manufacturers of Military Equipment" must be registered with and their activities monitored by the US Dept. of Defense. Registration is required by law, registration is detailed and complex, has to be renewed every year, and costs $2,500 for the first year, subsequent years go higher based on sales volume, regardless if I manufacture or export or not. Once I have demonstrated the capabilities to design and manufacture "Military Equipment", I must be watched, and I must pay for the watchers' time.
This is what I have to appeal now. I'll be looking for an attorney starting Monday.
This is my reward for stepping up to bat for CA requests and playing by the rules.
Now I think we can all understand why US vendors are reluctant to export to CA or anywhere.
Please don't yell at the vendors, yell at the US Gov't.
Mr AR15, my good-willed fellow-small-businessman advise to you: better check into this stuff on the CA side and see what land mines may be out there waiting for you. The US side / DoD / Customs is guaranteed to have a few.
Best regards to all.
- Fun Gun