There have been a lot of numbers thrown around with regards to the Russian ammo ban. Many of them are unsourced or unattributed, and as near as I can tell, wrong. So what are the actual numbers? What is the actual impact of this ban going to be?
How Do Ammo Imports Work?
First things first, we have to establish how importers actually get imports. The ATF has of course, not made this easy. Fortunately, I was able to talk briefly with a pair of experts and get the layman’s version. I would like to thank David of Discreet Ballistics, and Christopher Thomas of Mark Barnes & Associates for answering my questions. David is a Type 08 FFL holder. Type 08 FFLs are those that actually permit you to go about importing firearms and ammunition from abroad. Christopher Thomas is an attorney who specializes in the import of firearms and ammunition.
For a Type 08 FFL, the process is fairly straightforward. Once you have your FFL, you register as an importer with the ATF and Department of State. Then the FFL sources whatever it is they would like to import and fills out an ATF Form 6. A Form 6 is good for two years but is limited to the types and quantities of whatever is on the form. For example, let’s say Generic Ammo Importer fills out a Form 6 to import a bunch of ammo from Russia. They would write on the form they are importing 20 million rounds of 7.62×39 FMJ Tulammo, or whatever else they are importing. They may also import some sporting shotguns, some 9mm, or what have you. The point is that it all goes on a Form 6.
Now comes the actual importation process. Twenty million rounds of ammo is a lot. So Generic Ammo Importer might bring it over in 10 shipments of 2 million rounds. For each shipment, you have to file a Form 6A. This is different from a standard Form 6. While a Form 6 requires ATF approval, just like a Form 1 to build your own suppressor, a 6A does not. The importer files it with customs, but it does not require any sort of approval process.
Why Does a Form 6 vs a 6a Matter?
This is where the wording of the new ban comes into play. The exact text of the order reads:
New and pending permit applications for the permanent importation of firearms and ammunition manufactured or located in Russia will be subject to a policy of denial.
Since 6As theoretically do not require approval, anyone with an existing Form 6 should still be able to bring in whatever ammo they are already approved for. The number of still valid Form 6s is likely in the dozens, if not hundreds, so ammo will still trickle in over the next two years.
Russian Ammo iMPORT Numbers
One number I’ve seen thrown around quite a bit is that Russian ammo makes up 40% of all ammunition on the commercial market in the US. As near as I can tell, this number is incorrect. I had a brief email exchange with Dr. Jurgen Brauer, Ph.D., the Chief Economist for Small Arms Analytics & Forecasting (SAAF). According to him:
Russian imports were, as for 2020, about 20% of all firearms ammunition-related imports (measured under international trade conventions as shells or cartridges, empty or with projectile, or parts thereof) … our numbers suggest a quantity of ~11.8 bn in 2018, of which ~2.1 bn were imports (hence ~9.7 bn domestically [manufactured]). As for Russia, a “20/20” rule of thumb thus far this year is roughly right. ~20% of imports are Russian, imports are ~20% of all ammo on the market. Thus, the Russian component is ~4% on this rule of thumb. The actual number is somewhat higher but, we apologize, reserved for our clients.
In a fact sheet published by the SAAF, they estimate that 765,487,845 shells, cartridges, or parts thereof, came in from Russia in 2020. Going off their estimate of about 11.8 billion rounds manufactured or imported in 2018, Russian ammo accounts for between roughly 4.5% and 6.5% of all ammunition on the domestic market.
Not an insignificant percentage by any means, but certainly less than the 40% estimates I’ve seen floating around. The percentage that Russian ammo imports make up of certain calibers, such as 7.62×39, 5.45×39, 9×18, or 7.62×54R, is almost certainly much higher, and may very well be 40%.
Where WILL ammo come from now?
Russia is, or was, without question, the number one source of ammo imports for the United States. The hit to the market is going to be massive. The existing Form 6s will help cushion this impact, but with that said, prices are already up, and likely won’t come down for some time. Other countries will step up to fill the gap. After all, demand is still sky-high.
Countries like Mexico, Italy, and the Czech Republic are already huge exporters of ammo to the United States. It will take time, but companies such as Aguila, Fiocchi, and Sellier & Bellot (just to name a few) are likely already considering expanding production. The real trick will be matching cost per round. In pre-COVID times, you could get Russian 7.62×39 for 18 cents a round if you shopped around a bit. Part of this low cost was the already existing infrastructure. The collapse of the USSR left behind factories tooled up to supply the entire Red Army. So ammo manufacturers in the former USSR had much lower start-up costs.
I can’t predict where exactly steel case ammo will come from again, or if it even will. Polish companies might try to pick up the slack, or any of the other former Soviet states. It may be that this was the last time steel ammo would be cheap or plentiful, but I doubt it. The market will fill the void, it’s just a matter of timing. Will we ever see 18cpr bulk steel-cased 7.62×39 again? Probably not. Will the cost come down from the 45 cents (or higher) that it’s at now? Absolutely.