Rant" Ammunition manufacturing regulations and their effect on firearms industry

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  • Benjamin

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    Note: This post is about "General Firearms Discussion" although I got on the kick while researching ammunition manufacturing regulations.

    I recently looked into requirements for manufacturing (for profit) common ammunition (not legally defined as armor piercing, explosive, etc…) and here is what I found:

    Requirement to manufacture ammunition for sale: Type 6 FFL (I'm not sure if this is only required if the manufacturing is for profit, or if this would be, for example, required to reload for a friend at cost (no profit), but monetary transaction. Obviously, reloading common ammunition for personal use is unregulated.

    The real problem: To manufacture ammo for profit, in addition to holding Type 6 FFL, you must register with the U.S. State Dept. under ITAR (International Traffic in Arms Regulations), even if you don't buy/sell ammunition internationally. Minimum cost for this is $2100, and cost increases with scale of manufacturing. This is for "liability insurance".


    Implications for small scale ammunition manufacturing: Say I want to open a small business handloading match ammunition for percision rifles, I am required by law to get a type 6 FFL (reasonable in my opinion), BUT, I am also required to register with State Dept. under ITAR, which effectively costs a minimum of $2100 per year. Conclusion: Due to ITAR incurred costs, small scale ammunition manufacturing for profit cannot be undertaken practically. ITAR creates too much of a barrier of entry.

    Essentially, these laws and regulations cater to large companies and government owned facilities, who produce ammunition in enormous quantities, and can do enough business to justify paying the yearly ITAR costs.

    This also means that, since ammunition ends up coming from only a few facilities producing 10s of millions of rounds per year, the ammunition that these facilities produce is the only readily available ammunition on the market. Since many of these facilities are owned by large arms companies, there is incentitive for them to only produce ammunition for use in their profitable line of firearms.

    This means a cartridge cannot "catch on" and become widely available unless an "Arms manufacturing giant" wants to produce it. Even if a small company wanted to start producing a specific cartridge for an uncommon firearm platform, they could not do so profitably on a small scale.

    Implications for the general firearms industry: When you shop for a firearm, you are limited to firearms that are chambered in a cartridge that is widely produced by one of a few "Arms manufacturing giants", many of whom only want to produce ammo on a mass scale if it is for firearms that they sell. Otherwise, you must reload.

    I believe if the ITAR could not regulate manufactures unless they were selling/buying internationally, we might see firearms readily available in a wider variety of calibers, with more access to ammunition. Then a cartridge like the .300 whisper might catch on and become widely produced, rather than it taking years and having to be picked up by AAC and Remington and tweeked to the new .300blk before getting SAAMI approved.

    My thought is that these regulations really inhibit firearms chambered in new or less popular cartridges from becoming popular.

    Thoughts?




     

    danielson

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    SO, your surprised that government and some big businesses are locked in a mutually beneficial partnership, that limits and directs where you spend your money? HMMMM......

    This has been going on for decades.... In many other realms than firearms... Its why our country needs an enema....
     

    jy951

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    IMHO $2100 isn't that much if you are going to start a business. Its hardly much of a barrier to entry.
     
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    netsecurity

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    IMHO $2100 isn't that much if you are going to start a business. Its hardly much of a barrier to entry.

    Agreed. It isn't that much for a serious business. That amount would weed out the ones that aren't very serious, and probably wouldn't make it anyways. If it truly includes all the liability insurance you need to cover explosions, then it sounds quite fair even.
     

    Seancass

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    If you can't afford the $2100 per year, do it as a "hobby". Only problem there is that you can't make too much money and you probably can't have the same level of insurance(which could be a very big deal!).

    And as others have said, even for a smal business, $2100 isn't all that much. The upsetting part would be knowing that you're just paying extra tax for no good reason.
     

    Westside

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    Inquire about Insurance Cost if you think $2,100.00 is a lot.

    or the electricity required to run the machines to produce ammunition in large quantity.

    my company has 600V 2,000amp service and our power bill averages around $10,000 a month.

    you are also going to want to be an ISO9000 certified manufacturer. this certification cost around $2,500 a year, plus we have a full time guy who does nothing but make sure our documentation and records are kept in compliance. so actually it is more like 50K+ a year for ISO certification. a start up smaller business could probably get by without the quality guy.

    And that is just the start.
     

    Benjamin

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    Right, I agree with what has been said previously about $2100 per year not being a lot for a large scale (high volume) ammunition manufacturing business. My problem is, I don't want to be large scale. I would like to be able to hand load match rifle ammunition on my single stage press, and sell it to friends by the box. After all, factory match ammunition is expensive and you don't necessarily get exactly what you want when you buy factory match ammo.

    As I understand the law, if I load a few boxes of ammo to sell to my friends, who do not have presses of their own, then I cannot charge an additional $5.00 per box above my cost, unless I register with the ITAR, like a large scale ammunition company does. It is absurd to think that someone hand loading small quantities of ammunition to sell to friends should have to pay $2100 per year to do so legally.
     

    Leo

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    I worked the figures over and over and never could develop a business model for a cottage industry sized reloading business to be profitable and legal at the same time. To overcome some of the overheads, you need LOTS of volume.

    Don't fool yourself, a lot of this is carefully legislated by you government so they can keep you out of businesses that they do not like.
     

    ckcollins2003

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    Right, I agree with what has been said previously about $2100 per year not being a lot for a large scale (high volume) ammunition manufacturing business. My problem is, I don't want to be large scale. I would like to be able to hand load match rifle ammunition on my single stage press, and sell it to friends by the box. After all, factory match ammunition is expensive and you don't necessarily get exactly what you want when you buy factory match ammo.

    As I understand the law, if I load a few boxes of ammo to sell to my friends, who do not have presses of their own, then I cannot charge an additional $5.00 per box above my cost, unless I register with the ITAR, like a large scale ammunition company does. It is absurd to think that someone hand loading small quantities of ammunition to sell to friends should have to pay $2100 per year to do so legally.

    You dont' have to charge them extra... they are your friends, and they could simply "tip" you.

    If you're not selling it to people who are going to sue you if something goes wrong then you don't need the insurance and liability coverage. It's pretty simple, you wouldn't be assed enough to get the licenses required for brewing beer and selling it to your friends for a cheap profit would you? So what exactly are you complaining about? Are your friends going to call the ATF on you for loading ammo for them that is already hard to find? If so then they aren't your friends. Just don't go selling it online or to strangers. :n00b:
     

    danielson

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    I worked the figures over and over and never could develop a business model for a cottage industry sized reloading business to be profitable and legal at the same time. To overcome some of the overheads, you need LOTS of volume.

    Don't fool yourself, a lot of this is carefully legislated by you government so they can keep you out of businesses that they do not like.
    There it is.....

    You dont' have to charge them extra... they are your friends, and they could simply "tip" you.

    If you're not selling it to people who are going to sue you if something goes wrong then you don't need the insurance and liability coverage. It's pretty simple, you wouldn't be assed enough to get the licenses required for brewing beer and selling it to your friends for a cheap profit would you? So what exactly are you complaining about? Are your friends going to call the ATF on you for loading ammo for them that is already hard to find? If so then they aren't your friends. Just don't go selling it online or to strangers. :n00b:
    Yes sir.... Thanks to the gubmint, this has been the American way for some time.
     
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