You Might Have To Pay $2,250 ITAR Tax For Threading Barrels And Reloading Ammo

Adam Kraut posted about the Directorate of Defense Trade Controls (DDTC) Issuing Guidance on ITAR regulations. Last week the DDTC issued a letter on the requirement of firearm manufacturers and gunsmiths to register with DDTC under the International Traffic in Arms Regulations (“ITAR”). Click here to check out the letter.

According to the letter these do not require registration for ITAR.

a)  Occasional assembly of firearm parts and kits that do not require cutting, drilling, or machining;

b)  Firearm repairs involving one-for-one drop-in replacement parts that do not require any cutting, drilling, or machining for installation;

c)  Repairs involving replacement parts that do not improve the accuracy, caliber, or other aspects of firearm operation;

d)  Hydrographic paint or Cerakote application or bluing treatments for a firearm;

e)  Attachment of accessories to a completed firearm without drilling, cutting, or machining—such as attaching a scope, sling, or light to existing mounts or hooks, or attaching a flash suppressor, sound suppressor, muzzle brake, or similar item to a pre- threaded muzzle;

f)  Cosmetic additions and alterations (including engraving) that do not improve the accuracy, caliber, or other aspects of firearm operation beyond its original capabilities;

g)  Machining new dovetails or drilling and tapping new holes for the installation of sights which do not improve the accuracy or operation of the firearm beyond its original capabilities; and

h)  Manual loading or reloading of ammunition of .50 caliber or smaller.


Those involved in these activities are required to register with ITAR:

a)  Use of any special tooling or equipment upgrading in order to improve the capability of assembled or repaired firearms;

b)  Modifications to a firearm that change round capacity;

c)  The production of firearm parts (including, but not limited to, barrels, stocks, cylinders, breech mechanisms, triggers, silencers, or suppressors);

d)  The systemized production of ammunition, including the automated loading or reloading of ammunition;

e)  The machining or cutting of firearms, e.g., threading of muzzles or muzzle brake installation requiring machining, that results in an enhanced capability;

f)  Rechambering firearms through machining, cutting, or drilling;

g)  Chambering, cutting, or threading barrel blanks; and

h)  Blueprinting firearms by machining the barrel.


Some of those are things people can do in the garage. Like people with Dillon 1050s they can get autodrive mechanism where they just push a button and all they need to do is oversee that the reloader has enough components. There are people with lathes and Mills. It should apply to people who are doing this for a business but this will put a burden on the small time gun smith businesses having to pay $2,250 every year to ITAR.

To learn more about this, check out the article by Adam Kraut.

Nicholas C

Co-Founder of KRISSTALK forums, an owner’s support group and all things KRISS Vector related. Nick found his passion through competitive shooting while living in NY. He participates in USPSA and 3Gun. He loves all things that shoots and flashlights. Really really bright flashlights.

Any questions please email him at


  • Mufasa

    This sounds like someone is trying to write laws on things they know next to nothing about. Also ITAR is stupid.

    • Dave

      Must have come from an Australian politician then.

      • David Harmon

        It’s a Ford era law. The current issues started under the lady running for President right now.

    • aka_mythos

      This sounds like someone knows exactly what they’re doing. The administration is not a friend to the firearm industry and this is a way to force an even more burdensome bureaucracy on it. This extra burden of regulation can kill any company not generating the millions in revenue that can afford the lawyers necessary to deal with it.

      • David Harmon

        This admin is not friendly to anything that is associated with America.

  • UninfringedTech

    I don’t understand why your headline says we might have to pay a fee to reload, then the article specifically says we wouldn’t have to for any caliber under .50.

    • Klaus Von Schmitto

      Motorise your Dillon 650 and now you have “automated” reloading equipment. That applies to any caliber.

      • Nicholas C


      • raz-0

        Except you aren’t a business. If you start selling your reloads willy nilly, you have more problems than just ITAR.

  • Riot

    So a replacement trigger could fall under this?
    Or even changing magazine…..

    • aka_mythos

      Yes. Consider the large number of US manufactured weapons that we have given other countries. If there were a civil war or a change in government in one of those countries it could well be in our best interest to cut off the flow of replacement parts for the US made weapons.

    • Harry’s Holsters

      It’s not clear. It’s a point that has much room for argument on both sides from what I’m seeing.

    • Paul B.

      Or putting a magazine extension on your Rem. 870?

  • thedonn007

    I do not understand why ITAR would apply if you only provide your services with in the USA.

    • aka_mythos

      I think it’s government over reach to so broadly demand it.

      It doesn’t matter if your services are wholely in the USA. ITAR isn’t simply a registry. Seperate from any other licenses a company producing what can be considered “defense articles” must register. The registration is a control system not just to restrict the company from exporting its products but to restrict any third parties from doing it either. Failure to register is grounds for revoking of ATF issued licenses or inability to renew.

    • Kyle

      Came to ask that myself. Why would ITAR apply to Johnny in BFE USA because he can thread a Glock for Cletus? There are several very small gunsmithing operations around here that don’t need a $2,250 fee just to do their job.

    • DeathFromTheShadows

      Legally, per the US Constitution, it DOES NOT. We are NOT Beholden to any international organization, what so ever, nor any treaty covering business under which we do not deal in… This is akin to being taxed annually for selling cake to france when you are a lawn care service.

  • Mystick


  • Paul O.

    With the stroke of a pen, there are now a whole lot more felons in the U.S.

    • Nandor

      Let me tell you a few things about New York…

  • Bob

    So… If I carry out my plan to make a wooden stock for my single shot Little Badger .22, I am looking at jail time and massive fines? Great. Just great. I suppose next if I try to fix a rust spot on my car I need to register as an auto machanic…

  • Bob

    Wait, is this only for FFLs, or everyone?

    • Nicholas C

      I’m not sure if it applies to only FFLs. That is the part that concerns many people.

      • Harry’s Holsters

        Don’t gunsmiths have a watered down FFL of sorts that’s meant to be cheaper to obtain and renew?

    • PK

      It should only apply to businesses, but it has yet to be clarified. There may be attempts to apply it to all individuals as well, although I highly doubt it would stand up in court.

      • Harry’s Holsters

        Depends on which court. Judges aren’t as apolitical as they are supposed to be.

  • Road

    They’re just trying to whittle away the little guys on the fringes. They’re attacking this stuff because they know it’s low hanging fruit; they know the people who will actually be effected are few and far between, and do not have a strong voice. This needs to stop.

    • Harry’s Holsters

      People need to remember that a couple Supreme Court spots are likely to be filing by the next administration. We don’t know what we will get with one but we definitely know what we will with the other.

      • Not just a couple. Possibly as many as half of the court. Ginsburg has said she is leaving the country if Trump is elected. I’ll help her pack and up the stairs onto the plane.

        • Harry’s Holsters

          She also said she’s staying in the court if Hillary isn’t elected. The old cook doesn’t know what she’s doing.

    • Don’t just vote, man the polls. Anonymous put out a video telling that the Dems are already planning on stealing the election. They have said that the Dems have already identified precincts that can be easily rigged with fraud ballots and illegal voting and that the Media is already reporting fraudulent poll results to back up their planned theft of the election. They have recommended that Trump place a three person observation team, to include an attorney to file a legal objection to the votes in numerous precincts. They are recommending that Trump do this so that a legal objection to voter fraud can be filed ON ELECTION DAY in order to prevent the vote count from being certified.

      I think that they may have realized that once Hitlery gets in the White House, she will turn all of the assets at her disposal towards their destruction and they won’t be getting short jail sentences. Julian Assange’s attorney was recently killed in England by being hit by a train when he fell off the platform at the station in front of it, and an intruder breached the security of the embassy where Assange is hiding to avoid extradition. The intruder fled when discovered. Reportedly an intruder with an unserialized Glock with a suppressor was recently caught by Secret Service after attempting to breach the security on the first level of Trump towers in order to access the service elevators. When the NYPD checked the intruders finger prints in the system, they supposedly belonged to an FBI agent killed in the line of duty in 2007. If this story is true, this was a full on long term black bag wet work operation. Faking a death, establishing a new identity and providing this kind of hardware is almost assuredly the work of a rogue government agency. It’s also the kind of thing that could be done to make Trump want to soften his stance on various issues. Even if it failed, it would be used as a warning that even in his own building he wouldn’t be safe. Then there are his kids. These people are NOT beyond going after someone’s family as a warning. Trump has a number of children and grandchildren.

      • Road

        I don’t even know what to say about that.

  • alabubba

    So installing an aftermarket trigger, that would improve the accuracy, or swapping out an upper on an ar to a different caliber or a more accurate barrel would now fall under itar

    • PK

      Or using a magazine that didn’t come with the gun…. “Modifications to a firearm that change round capacity” is exceptionally broad.

      • Harry’s Holsters

        I didn’t understand is if was stating the capacity of the round it’s self like changing from 308 to 6.5 creedmore or actual magazine capacity. It’s very unclear how the mean it to be interpreted.

        • De Facto

          That’s very deliberate. They’re leaving it open to litigation in the future, and will likely push for the broadest possible interpretation in court over time.

          • Harry’s Holsters

            I agree. It certainly wasn’t a mistake.

    • Harry’s Holsters

      A trigger doesn’t change mechanical accuracy but there is vague enough to be argued in court.

  • ReadyorNot

    I’m sure this falls in line with the Democratic mantra of “reasonable restrictions” which we’ve learned equals GUN CONTROL. The war of a thousand cuts to our rights continues. ITAR itself is a joke considering the types of US/Western weapons, accessories, and uniforms we see circulating in the battlefields of Ukraine, Syria, and Iraq which ironically is provided by the US gov itself!

  • Varix

    Just because of this, I’m going to motorize my Dillon and not tell anyone.

  • Charlie

    Seems like this would impact 80% lowers if we’re applied to individuals.

    • Charlie

      Sorry about the auto correct. *if it was applied

      • Cory C

        If it were. 😉

  • Reading and Comprehension FAIL

    The really sad part is that looks like not even one of those making comments here, nor Nicholas, took two seconds to actually READ the letter – which clearly says (and quoting): ”

    Registration Required– Manufacturing In Response to questions from persons engaged in the business of gunsmithing,”

    Is any of you “engaged in the business” ? Do you install triggers, reload ammo, and what not, as a BUSINESS ? NO? Then what are you complaining about ?

    • n crawford

      What about those of us that do? What are you saying? F us?!?

    • concernedcitizen1982

      Your comprehension may be adequate but your logic sucks. Many of the small operators in gunsmithing will have to pass the cost of the tax onto the customer like you and I…probably just me though since you are likely a troll. Those in the manufacturing business as well will have to offset the costs plus added man hours for the paper work/red tape. Go pack sand and stay away from our sport.

    • De Facto

      Because Government penalizing and shutting down shade tree gunsmiths who do small jobs in their spare time as a hobby hurts us all. Those small time smiths are who you can go to for custom, small jobs that the big shops don’t want to waste time with or will charge an arm and a leg for. Since they don’t usually have a shingle out or overhead, they can do small jobs for quite cheap in their spare time, especially if you don’t have an urgent timetable.

      Because installing triggers, milling 80% lowers, reloading ammo, and other low skill aspects of gunsmithing are within reach of the lay person, and being done more and more. I’m good with my hands, and I don’t mind spending time on my hobby, so will I be subject to an ITAR tax if I reload 5.56 for my friend and sell it to him at cost? If I fabricate a trigger part out of billet steel with a dremel and a file for a friend’s old .22 because he can’t find replacement parts? Am I going to be “in the business of gunsmithing” because I decided to mill an 80% lower for myself, or weld an AK receiver together? The Government can change it’s definition of who is “in the business” of gunsmithing at a moments notice. Don’t think they won’t. They’ve already made ominous statements about changing who they deem to be “in the business” of selling firearms. You really think they won’t abuse this new interpretation of the rules for gunsmiths?

    • Bob

      Define the necessary requirements to be considered “in the business” please. How many guns or gun parts are needed to be “in the business”? How recently? Etc, etc. If I sell a Glock I personally threaded the barrel on, can I be considered “in the business”? What if I sold a couple? What if I have a motorized reloading press I’ve been known to reload for friends and famjly with? At what point can I expect trouble from over zealous lawyers? The last thing I want to do is go from a traffic ticket or something equally mundane that draws attention to me and suddenly have the law going after me for something so stupid.

      TLDR version: How will the law be used and abused?

      • If you’re breathing (and possibly after death depending on who you leave your stuff to in your will) you can expect trouble from the Ivy League educated leftists who have gone into government not to serve the public but to push an agenda.

    • benjamin gardiner

      Driver: one ’employed’ in conducting a coach, wagon…or other contrivance for for fee or hire.
      Motor vehicle The term “motor vehicle” means every description of carriage or other
      contrivance propelled or drawn by mechanical power and used for
      commercial purposes on the highways in the transportation of passengers,
      passengers and property, or property or cargo.

      The vast majority of people do not meet this criteria, yet, we all have had to get a license to control our automobiles down the road. Insurance is required upon motor vehicles, yet, I doubt you will ever find a company that sells insurance for motor vehicles! ‘Home, Auto, Boat, etc’. So you know, I used these definitions, and the judge told me that if i spoke on them during the trial, I’d be in contempt.

  • Sasquatch

    Hmm you know some colonists rose up and over through a radical government for crazy taxes and other stuff. They formed a really strong country. Hmm wonder who that could have been…..

    • David Harmon

      Actually, they rose up because the British were coming to disarm them.

      • When the leftists claim that the Second Amendment doesn’t apply to military grade weapons, tell them to look up the Supreme Court decision in Miller V. US that says that the Second Amendment ONLY applies to weapons of military utility.

        You’re right. The colonists fought the government troops at Lexington and Concord because the government was coming to confiscate privately owned firearms, and ammunition that included a CANNON and the ammo for it. Now if the founders were fighting to keep a privately owned CANNON, why would they not want the people to own military capable rifles and carbines?

        • David Harmon

          Leftists don’t care about history. They merely want to hand the power over to the communists without question. They basically only care about not having to be responsible for their own life.

          • Those that will choose to hand control of their lives over to others are destined to lose them. Unlike the first revolution, there will be very few innocent bystanders in the next one. Those who choose to side with the government will have to be eliminated, not simply allowed to choose to aid and abet the enemies of liberty unpunished. They will have to be treated the same as the French Collaborators were during WWII in order to discourage others from following their lead.

          • David Harmon

            I think the second American Revolution has already started, just not the open shooting yet, and WWIII is coming very soon.

            I’m not innocent, so I have no issues losing my “innocence” for any kids to keep theirs.

          • As IIRC Ben Franklin put it “Those who choose security over liberty deserve neither and will lose both.”

          • David Harmon

            Yes, and he was right about a lot of things, including that.

  • Christian Hedegaard-Schou

    Friend of mine and I were working together on putting together a very small business. We wanted to have an 07/02 FFL/SOT. Even here in CA, the combined fees for EVERYTHING but ITAR came in to about 1/3 of the total cost of JUST the ITAR registration.

    It’s ridiculous.

    • David Harmon

      That’s just to get the license. It’s insane. They are even pushing it onto the R&D guys now too.

  • Joshua

    there is a lot of weird, almost specific wording there, for instance;
    “Blueprinting firearms by machining the barrel.”
    by that definition you could blueprint a a firearm so long as you don’t machine the barrel, well, usually blueprinting is done by lapping, which requires no machines, and is done by hand so not a “Machining” operation. so can we blueprint or not?

  • Michigunner

    So for curiosity’s sake, what about putting a magazine tube extension on a Remington 870 shotgun? Where does this fall under these regulations? The reason I ask is that it appears to be permissible under section 1 (b): Firearm repairs involving one-for-one drop-in replacement parts that do not require any cutting, drilling, or machining for installation; but taxable under 2 (b): Modifications to a firearm that change round capacity. Before anyone adds that sometimes you need to drill out the dimples on an 870 mag tube for the extension, I am aware of this fact. But, the extensions don’t always require drilling for installation. I wonder where this falls under the new ITAR tax? Is now theoretically taxable if you have to drill it?

  • DeathFromTheShadows

    ITAR IS NOT From the US, it is a foreign (international) based trade agreement solely intent on small arms registration and control. to be held to its rules is a direct violation of the US constitution on several points, the most obvious being the Second Amendment, However the more important are those regarding the fact that the US is a Sovereign Nation, and can not be held to tow by any outside nation or organization.

  • MrEllis

    I’m honestly shocked people here don’t know what ITAR is for and isn’t for.

  • rc_vic_kerman

    Sounds like whatever you might do to your firearm do not admit doing it and do not let anyone see you do it! Answer all questions with the stock answer of; “I don’t know how it got done or who might have done it!”

    • Yeah, the local gunsmith was rather impressed with the job I did cutting my shotgun’s barrel from 26 to 21 inches. I had him install a new front sight since the old one went with the other 5 inches of barrel. He said that it was square and flat which he doesn’t see on many owner done jobs. I had taken great care to insure that the end result was right. I didn’t just cut it off with a hack saw, I had used a file to square it up and remove any uneven spots.

  • Oldtrader3

    This is what happens to a great country which turns “Commie Stupid”!!!!! This is what passes for law when a douche bag, did not attend law classes, lawyer, becomes pResident! Vote for Trump! I think Oblamer may have elected Trump today!

  • DIR911911 .

    “g) Machining new dovetails or drilling and tapping new holes for the installation of sights which do not improve the accuracy or operation of the firearm beyond its original capabilities” . . . can you say catch 22 , why did you install these new sights . . “i shoot better with them” . . .put your hands behind your back 🙂

  • Pontificant

    Yeah, not playing any more. It’s like listening to some drunk guy babbling on about being king of the world. Their selective enforcement of this stuff is no different than being mugged by some arbitrary punk on the street. Unless people start implementing solutions that provide actual respect for those of us who exercise our rights, the control-mongering imbeciles will continue to keep coming at us.

    They lack respect, because they lack a healthy fear for the consequences of their actions. Like a child around a hot stove, they are going to learn an irreversible lesson that will pain them until the day they die. This has gotten too stupid to participate in or even pay attention to, F@ck ’em!

  • spencer60

    Wow… reloading! That’s new to me.

  • jay

    It sounds like this is all part of the u.n. firearms treaty BS. It would affect our sovereignty, as well as our ability to do business outside and inside the US. It is like the ammo registration in kalifornia. It’s all a back door to registration, and eventually confiscation. They are attacking us from so many directions it will be very hard to fight. I’m sure some politician will try to calm us down and tell us not to worry. It will never happen hear. When it does happen hear, I’m afraid we will all need to wear our hearing protection. Keep you powder dry. And remember, blue helmets make easily visible targets.