Kamikaze11
CGN Regular
- Location
- Gatineau Qc
This
Good news on ITAR
- Thread starter Prophet River
- Start date
Rockmcdock
New member
- Location
- Calgary, AB
From reading the legislation online, if I read it correctly, many parts, including barrels, if the total value is less than $500.00, can be exported from the US to Canada without an export license. I am not a lawyer or the son of one. Nor am I an importer/exporter/broker. So, I could be mistaken. Here is the direct quote:
“Under this proposed rule, complete firearms controlled under ECCN 0A501 would not be eligible for License Exception LVS, 15 CFR 740.3. Firearms “parts,” “components,” “accessories,” and “attachments” controlled under ECCN 0A501, other than receivers (frames), and complete breech mechanisms, including castings, forgings or stampings thereof, would be eligible for License Exception LVS, with a limit of $500 on net value per shipment. In addition, receivers (frames), and complete breech mechanisms, including castings, forgings or stampings thereof, would be eligible for License Exception LVS if the ultimate destination is Canada.”
“Under this proposed rule, complete firearms controlled under ECCN 0A501 would not be eligible for License Exception LVS, 15 CFR 740.3. Firearms “parts,” “components,” “accessories,” and “attachments” controlled under ECCN 0A501, other than receivers (frames), and complete breech mechanisms, including castings, forgings or stampings thereof, would be eligible for License Exception LVS, with a limit of $500 on net value per shipment. In addition, receivers (frames), and complete breech mechanisms, including castings, forgings or stampings thereof, would be eligible for License Exception LVS if the ultimate destination is Canada.”
Rockmcdock
New member
- Location
- Calgary, AB
I also believe that magazines between 17 and 49 rounds are exportable. Find the legislation for ECCN 0A501 and read the description of what is now covered under the Commerce area of the US government. Again, I am not a lawyer and could be reading things incorrectly, but that is what I read. The quote:
“New ECCN 0A501 would apply national security (NS Column 1), regional stability (RS Column 1), Firearms Convention (FC Column 1), United Nations (UN), and anti-terrorism (AT Column 1) reasons for control to the following firearms, the following enumerated parts and components and to “specially designed” “parts,” “components,” “accessories” and “attachments” for those firearms and “parts” and “components:”
- Non-automatic and semi-automatic firearms (other than shotguns) with a caliber of less than or equal to .50 inches (12.7 mm);
- Non-automatic and non-semi-automatic rifles, carbines, revolvers or pistols with a caliber greater than .50 inches (12.7 mm) but not greater than .72 inches (18.0 mm);
- Detachable magazines with a capacity of greater than 16 rounds but less than 50 rounds that are “specially designed” for the firearms listed above;
- Receivers (frames) and complete breech mechanisms, including castings, forgings, or
stampings thereof, “specially designed” for the firearms listed above; and
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- Barrels, cylinders, barrel extensions, mounting blocks (trunnions), bolts, bolt carriers, operating rods, gas pistons, trigger housings, triggers, hammers, sears, disconnectors, pistol grips that contain fire control “parts” or “components,” and buttstocks that contain fire control “parts” or “components” (e.g., triggers, hammers, sears, or disconnectors) if “specially designed” for the firearms listed above or for firearms listed in USML Category I (unless the part or component itself is listed in USML Category I(g) or (h) as specified in the Department of State proposed rule entitled “Amendment to the International Traffic in Arms Regulations: Revision of U.S. Munitions List Categories I, II, and III,” also published in this issue).”
“New ECCN 0A501 would apply national security (NS Column 1), regional stability (RS Column 1), Firearms Convention (FC Column 1), United Nations (UN), and anti-terrorism (AT Column 1) reasons for control to the following firearms, the following enumerated parts and components and to “specially designed” “parts,” “components,” “accessories” and “attachments” for those firearms and “parts” and “components:”
- Non-automatic and semi-automatic firearms (other than shotguns) with a caliber of less than or equal to .50 inches (12.7 mm);
- Non-automatic and non-semi-automatic rifles, carbines, revolvers or pistols with a caliber greater than .50 inches (12.7 mm) but not greater than .72 inches (18.0 mm);
- Detachable magazines with a capacity of greater than 16 rounds but less than 50 rounds that are “specially designed” for the firearms listed above;
- Receivers (frames) and complete breech mechanisms, including castings, forgings, or
stampings thereof, “specially designed” for the firearms listed above; and
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- Barrels, cylinders, barrel extensions, mounting blocks (trunnions), bolts, bolt carriers, operating rods, gas pistons, trigger housings, triggers, hammers, sears, disconnectors, pistol grips that contain fire control “parts” or “components,” and buttstocks that contain fire control “parts” or “components” (e.g., triggers, hammers, sears, or disconnectors) if “specially designed” for the firearms listed above or for firearms listed in USML Category I (unless the part or component itself is listed in USML Category I(g) or (h) as specified in the Department of State proposed rule entitled “Amendment to the International Traffic in Arms Regulations: Revision of U.S. Munitions List Categories I, II, and III,” also published in this issue).”
This could be a game changer for Boyd's stocks if I can get em sent to a US PO box and just drive it across!
It almost sounds like you could bring barrels, bolts, receivers, triggers, stocks all across the border if value is under $500 USD. Like you could walk them across, drive them, or ship them, no paperwork or other restrictions. Basically anything except a "complete firearm" and under $500 is just like candy crossing the border to Canada.
Very interesting if no export license required and probably U.S. businesses will start shipping to Canada. We probably don't even need to drive across.
Although I can't imagine how is this good for export/import companies like Borderview, since their business model is import broker. But apparently Borderview welcomes the ITAR changes, which makes me think you guys saying "free export" can't be right. lol
Although I can't imagine how is this good for export/import companies like Borderview, since their business model is import broker. But apparently Borderview welcomes the ITAR changes, which makes me think you guys saying "free export" can't be right. lol
Unfortunately No, read up on the Export Clearance Requirements in the new rules— AES EEI filing by an exporter to generate an ITN, etc. It’s much easier than getting a full Export License in most cases, but to export without this filing is a violation. The good news is many more US sellers will likely do it in-house as they don’t have to pay the $2250/year minimum to register under ITAR. And for others, established importers/exporters can do it more efficiently for you.
Good questions and thoughts
First off, Prophet River has been importing into Canada for many years, and will continue to be an excellent resource as they are very much on top of this all. They want what is good for the Canadian collector, sport shooter and gun owner.
You're totally right - on it's surface this is not "good" for export/import companies like us, as it makes it easier and less costly for others to start exporting. BUT - we don't see it that way, for a few reasons.
First and foremost, we are fellow gun enthusiasts. While we understand sensible controls on cross-border firearm movements, the ITAR was not the proper place to control these at the same level as fighter jets, tanks and nuclear weapons. It was too burdensome on everyone involved to export grandpa's bolt action .22 rifle made in 1901 under ITAR. Anytime the governments move in the right direction on these control issues, we are in favor, regardless of how it impacts our sales. It's a matter of principle. It's where our roots are - our founder's grandfather started exporting guns to Canadians in the 1950's, long before the rules got the point they've been in the last 20 years post-9/11. That legacy lives on through Dave's Sports Shop, which spun off the export division into Borderview in 2011 to focus exclusively on the complex realities of international firearm logistics. All of that said, we've always been - and always will be - in favor of regulation that helps the average gun owner and collector.
Secondly, we understand that even though things get "easier" for others to get involved (a good thing in our view, even though it may hurt sales - see above), there will still be people who want to hire a professional. Same as we do for our taxes, wills, real estate transactions, and other complicated government matters than a person can in theory do on their own, but may opt to hire a professional. For those cases, we'll be here as always!
Lastly, even if these changes have a dramatic impact on our historic business channels, we can always find new channels and ways to serve people. We've already begun consulting with other U.S. based manufacturers and dealers to share our experience and help them get into selling and shipping internationally.
We've been in favor of these changes since they were first proposed ten years ago, and have tireless advocated for their implementation ever since. If it helps the legitimate gun owner even a bit, we're all for it! Will it totally de-regulate? No way. Can parts/components now be driven across without any filings? No - a proper AES filing is still required. Does it get less burdensome overall, for everyone involved? Yes - and that's a win in our books! I know the same is true for Prophet River, too.
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Good questions and thoughts
First off, Prophet River has been importing into Canada for many years, and will continue to be an excellent resource as they are very much on top of this all. They want what is good for the Canadian collector, sport shooter and gun owner.
You're totally right - on it's surface this is not "good" for export/import companies like us, as it makes it easier and less costly for others to start exporting. BUT - we don't see it that way, for a few reasons.
First and foremost, we are fellow gun enthusiasts. While we understand sensible controls on cross-border firearm movements, the ITAR was not the proper place to control these at the same level as fighter jets, tanks and nuclear weapons. It was too burdensome on everyone involved to export grandpa's bolt action .22 rifle made in 1901 under ITAR. Anytime the governments move in the right direction on these control issues, we are in favor, regardless of how it impacts our sales. It's a matter of principle. It's where our roots are - our founder's grandfather started exporting guns to Canadians in the 1950's, long before the rules got the point they've been in the last 20 years post-9/11. That legacy lives on through Dave's Sports Shop, which spun off the export division into Borderview in 2011 to focus exclusively on the complex realities of international firearm logistics. All of that said, we've always been - and always will be - in favor of regulation that helps the average gun owner and collector.
Secondly, we understand that even though things get "easier" for others to get involved (a good thing in our view, even though it may hurt sales - see above), there will still be people who want to hire a professional. Same as we do for our taxes, wills, real estate transactions, and other complicated government matters than a person can in theory do on their own, but may opt to hire a professional. For those cases, we'll be here as always!
Lastly, even if these changes have a dramatic impact on our historic business channels, we can always find new channels and ways to serve people. We've already begun consulting with other U.S. based manufacturers and dealers to share our experience and help them get into selling and shipping internationally.
We've been in favor of these changes since they were first proposed ten years ago, and have tireless advocated for their implementation ever since. If it helps the legitimate gun owner even a bit, we're all for it! Will it totally de-regulate? No way. Can parts/components now be driven across without any filings? No - a proper AES filing is still required. Does it get less burdensome overall, for everyone involved? Yes - and that's a win in our books! I know the same is true for Prophet River, too.
Wow. Didn't expect to see you here. I totally didn't know BDVW is Borderview.
That was well said. I can totally see the de-regulation will both benefit gun owners and gun businesses in the long run. There might be some short term turbulence, but it's definitely a win-win for both of us. I totally support Prophet River and Boderview, and appreciate their honesty.
p.s. I have an import order with you atm, will appreciate if you can check emails more frequently lol. Just kidding, I know you guys are doing your best.
Hehe, we keep a pretty low profile on here to try and focus on running the day-to-day... maybe with a little less ITAR complexities in the future we'll be able to come back on here more. Used to be a CGN site sponsor (~2008-2013ish?) then paused and have been busy keeping up with all the piles of paperwork ever since
Changed our CGN username from 'borderview' to 'BDVW' to keep that low profile and let others on the site do their thing. Still pop on here once in a while just to provide informational updates (rather than promote), such as lately with these big changes going on. Always lots of dangerous misinformation out there, figure since we read these regs for a living we can at least help clarify and hopefully keep some people out of trouble. (It does get a bit tiring sometimes answering the "so I can just drive down and buy XYZ and bring it back right?" questions over and over, but I digress... lol)Clay at Prophet River has been awesome at focusing on what's best for the customer since day one, and we have no doubt that will continue to be the case. Just now with things hopefully freeing up a bit and clearing the backlog of ITAR exports stuck since last year, hopefully everyone (including the awesome Melissa at Prophet River) will have a bit more time with less of the "where's my stuff" emails.
I read that Commerce is going to start allowing aliens to use AES. In which case we might be able to AES submit ourselves.
I read it on a summary of comments re: Form 6 NIA. Apparently a Form 6NIA is no longer enough to get your guns back into Canada, you may to file with AES to get an export permit for your temporarily imported guns.
See comment 78: https://www.federalregister.gov/doc...es-the-president-determines-no-longer-warrant
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