Vltor & LaRue AR Uppers
- Thread starter simpleton
- Start date
- Location
- East ontario
how does he do that where they are not aproved for export?
why don't you ask him directly instead of posting here?
ajayofcanada
Regular
Both LaRue and Vltor are REGISTERED with the US State Dept,fill out a DSP-83 form and you can have all the uppers you like.
- Location
- East ontario
So much bad info out there i guess, even the people that work at the companys dont know up from down.
bbb
There are 2 different registrations and most people confuse them. First, it is US law that ALL companies that make ANYTHING covered by ITAR are required to be Registered with US State Department as a "Manufacturer"... it doesn't matter how small they are or if they never plan to export any of their products, the Manuacturer Registration is legally required (though many small companies doen't realize this). Some avoid paying the manufacturer registration fee for a while but they do get "caught" eventually and when that happens US State Department sends them a rather intimidating letter and forces them to pay up... the fees are backdated so even if a company avoids paying for a few years, they end up paying all of those "missed" years.
The really interesting part is that US State Department in effect "uses" the exporters to find the delinquent un-registered manufacturers. When we (exporters) apply to export a product one of the first things State Department does is check their records to confirm that the manufacturer of the product is registered... if they are not then a letter goes out to the manufacturer forcing them to pay up.
The second type of registration is for export of ITAR items and in this case it is required only if a company wishes to export items covered by ITAR. If they are not planning to apply for export licenses to export products then they are not required to register as an exporter (an example of this is Larue). There are separate fees for these two registrations.
As long as the manufacturer is registered with State Department then any registered "exporter" can apply to State Department for an export license to export products made by that registered manufacturer. All of these registrations are annual so if a Manufacturer fails to pay their annual registration fee, then US State Department will stop approving export licenses for their products. We have had this happen quite frequently with some of the smaller manufacturers who often forget to send their renewal payment or simply are late doing so.
In our case we are a Registered Exporter and thus allowed to make application for DSP-5 Export Licenses. In the case of a company who makes AR parts (for example) the company needs to pay State Department annually to be a Registered Manufacturer of ITAR related goods (this is mandatory)... they would then have to pay an additional registration fee (optional) if that same company wanted to apply for an export license to export their ITAR controlled products from the US... or they could have another company (a "registered exporter") do handle the export process instead.
Brownells is NOT being candid when they state that certain companies are NOT registered with US State Department. An example of this is SIG Sauer... Brownells repeatedly claims that SIG Sauer is not registered with US State Department however, this is blatantly false. SIG is registered both as a Manufacturer and as an Exporter and that is a fact. They know this and when I pointed this out to them they changed their tune and admitted it is their own policy not to export SIG products.
Hope this clarifies a bit.
Mark
As always a fascinating reply. I take it you are a Registered Exporter by virtue of your partner in the US? For businesses that are not manufacturers, just wholesalers, they only apply for the DSP-5 Export Licenses? How much does that cost? I ask because I am trying to figure out why most US dealers will not touch Canadian orders. Thanks.
Yes, our US company (Questar International, LLC) is a US FFL (08-Importer), US Class III License Holder, a Registered Exporter with both US State Department and also with US Commerce Department, and licensed with US DOT to transport goods in the US and also across the border.
US State Department registration really consists of 2 totally separate requirements. There is legislation in the US that requires ALL companies that manufactures any item controlled by ITAR to register with the US State Department. Many companies have failed to do so (for years) and believed that they were only required to register if they were exporting their products. That is not accurate... the requirement to be registered is regardless whether the manufacturer (or anyone else) is actually exporting the product... it has nothing to do with exporting... it is so US State Department can know and control who exactly is making these "controlled" goods. By the way it's not just guns that are ITAR controlled... computer equipment, software and many other items are named and controlled under ITAR. Ever bought a DELL computer on-line? You would have had to accept their terms and conditions which include an end-user statement about the technology and your agreement not to re-export, etc., (it's there for US State Department approval of the export).
The other registration is the Exporter Registration. Even if a company is already registered as a Manufacturer, US law requires that to apply for a DSP-5 Export License the exporter must be Registered with State Department as an ITAR exporter... they must pay the associated fees (which can now run into the tens of thousands annually) and they must renew annually unless they plan to stop exporting and NEVER intend to export anything ITAR related again. The new rules that came into effect at State Department last year state outright that a company cannot stop paying the registration fee for a year or two and then start up again... in order to renew they would be charged for the years they missed as well as the current year.
All of this info is on the web... including how the exporter registration fees are calculated. It's actually now based on the volume and value of permits processed by an exporter during the 12 months preceeding the renewal date. So if a company did 100 export permit this year then their renewal fee would be 100 x $250 = $25,000.00 plus the base fee which I believe is $2,750.00 now... total in this example is $27,500.00 USD to renew the permit for 12 months and keep your current permits alive (and apply for new ones). If your registration lapses then all outstanding permits cease to be usable.
This works out okay for a new exporter... they pay the base fee and they're good for the first year... but when the renewal comes up they will see drastic increases in their fees. The only allowance for the really small exporter was the 3% ceiling. US State Department will also calculate the value of all of those permits applied for during that 12 month period and if the value x 3% is less than the amount calculated the other way then the exporter pays the lower value for their renewal. So if the exported did a bunch of $100 or $300 value permits then 100 x $300 value = $30,000 x 3% = $900.00 plus that base fee gives you a total of @ $3,050.00 so it's not so bad.
But... if just a few of those 100 permits are for a big wholesale orders then this kills the ability to use the 3% method... it drives the ceiling up to where you're effectively paying that $250.00 per permit rate. This is essentially why we were driven out of the small 3rd Party Purchase service. We can still do this on the higher end products for customers importing high end guns and collector pieces... but the low priced parts and items we simply can't compete with the small exporters since we can't get access to that 3% rate like they can.
Does this answer some of your questions
Mark
In a nutshell because the cost of doing business on export sales is so high that they can't make money at it.
- Most don't know the regulations and don't have the time or desire to learn all that's involved.
- Many Amercians don't like or trust their Federal government and agencies (wonder why)... so avoiding having to deal with them is a no-brainer.
- It takes hours of office work to process an export order... it only take minutes to process a domestic order.
- Margins on most US sales are unbelievably small... at US prices there isn't enough margin for many to justify the added costs in time and labour (and headaches) to warrant export sales.
- Just to list a few of the reasons
As a total aside...
Aren't Vltor and Midwest Industries (MI) both part of American Defense Manufacturing (ADM)?
I seem to recon seeing a patent application where employees of all three were listed as inventors.
Edit: US Patent Application #20080178511
Inventors: Storch; Troy; (Waukesha, WI) ; Gross; John; (Mukwanago, WI) ; Orne; William; (New Berlin, WI) ; Kincel; Eric Stephen; (Tucson, AZ)
Now, Kincel; Eric Stephen is Vltor, Storch; Troy is MI, William Orne is WS Machine & Tool Inc/ADM.
I mean, how likely is it for Ford, Toyota and Mercedes to be joint inventors on a patent application on how to affix wheels to a car?
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Spend alot of time on AR15 dot com do we?
