Efficient/economical alternatives to Form 1?

[JC in SC]

Are there any reasonable alternatives to the Form 1 process for dabbling in suppressor design and construction each time you want to investigate a new baffle design or manufacturing process? Is it exceedingly difficult to become a Type 7 FFL with a Class 2 SOT in order to be able to experiment without paying $200 and waiting many months each time? A brief search turns up ffl123.com, which indicates this is a viable option; however, they're selling a how-to on the subject, so looking for some objectivity. Any help or direction would be greatly appreciated.

[doubloon]

Technically a Form 1 is not for dabbling or experimenting.

A Form 1 for executing a single design and living with the result. Then if you don't like it get another Form one to produce another device.

The only legal avenue for dabbling and experimenting with NFA devices is a manufacturing license.

All presupposing the question is specifically about dabbling and experimenting in the U.S.

[cdrissel]

If you want to play you have to pay - multiple form1s or get the SOT.

[quiettime]

Or you can always build your Form 1, then work with a 07/02 if it does not perform how you want. It will cost you but it may be better than having a couple (or more) F1 cans that both don't work as well as you'd hoped.

Of course the best plan is to study here as much as you can and also study successful commercial cans so you have a good understanding before you cut metal

[cdhknives]

Are you asking how many form 1's do you have to burn before you break even becoming a manufacturer?

[doubloon]

Are you asking how many form 1's do you have to burn before you break even becoming a manufacturer?

1 ... 2 ... 3 ...



But I believe that license has to be maintained to keep what you make so multiply that by the number of years you plan to keep'em.

And technically that's not a license to manufacture toys for your personal collection.

[propeine]

Are you asking how many form 1's do you have to burn before you break even becoming a manufacturer?

1 ... 2 ... 3 ...



But I believe that license has to be maintained to keep what you make so multiply that by the number of years you plan to keep'em.

And technically that's not a license to manufacture toys for your personal collection.

Sole proprietorship I thought you could transfer out for free any non posties if your FFL expired but I could be mistaken.

Also don't forget ITAR at 1500/year. So that makes somewhere north of 9 cans per year to break even with FFL and ITAR. I'm not gonna get in a pissing match about ITAR and "research"

[doubloon]

...
Sole proprietorship I thought you could transfer out for free any non posties if your FFL expired but I could be mistaken.

Also don't forget ITAR at 1500/year. So that makes somewhere north of 9 cans per year to break even with FFL and ITAR. I'm not gonna get in a pissing match about ITAR and "research"

Wasn't sure about how easy it is to get your personal collection out.

No clue on ITAR, that's a lot more owls.

[T-Rex]

Also don't forget ITAR at 1500/year.

I thought ITAR was over $2200/yr?
Plus the licensing fee, on top of that.

If you're trying to reinvent the wheel, or come out with "the next big thing" in suppressors, then do it, because you'll need the R&D.
If you want to make a really nice form 1 suppressor, spend some time reading the vast amount of info, here and on some other sites, and you shouldn't be disappointed.

[JC in SC]

Given the whole "make money without spending any of your own" vibe at the aforementioned website, I should have known that it was not as inexpensive or easy as it sounded. I had not even considered ITAR. I had, I guess erroneously, thought that if you were not planning to export, you would not have to worry about ITAR. I guess if the manufacture of weapons is involved, it might be required regardless.

I have done quite a bit of research here with respect to baffle design, etc. What is not completely clear to me is how much detail must go into the Form 1. It seems that I have seen some information that indicates caliber and maximum length are all that is required to submit the Form 1. Then I've seen other information implying that a full blown print package must be submitted. If you build based on a proposed design and it absolutely sucks, can you not modify it thereafter?

As an engineer, the theory and science behind the designs fascinate me. Building something otherwise available commercially might save money, but I do not find it as interesting as trying to improve upon the mousetrap. I doubt that I would come up with anything to revolutionize the industry, but it would be interesting to try new concepts.

[propeine]

Given the whole "make money without spending any of your own" vibe at the aforementioned website, I should have known that it was not as inexpensive or easy as it sounded. I had not even considered ITAR. I had, I guess erroneously, thought that if you were not planning to export, you would not have to worry about ITAR. I guess if the manufacture of weapons is involved, it might be required regardless.

I have done quite a bit of research here with respect to baffle design, etc. What is not completely clear to me is how much detail must go into the Form 1. It seems that I have seen some information that indicates caliber and maximum length are all that is required to submit the Form 1. Then I've seen other information implying that a full blown print package must be submitted. If you build based on a proposed design and it absolutely sucks, can you not modify it thereafter?

As an engineer, the theory and science behind the designs fascinate me. Building something otherwise available commercially might save money, but I do not find it as interesting as trying to improve upon the mousetrap. I doubt that I would come up with anything to revolutionize the industry, but it would be interesting to try new concepts.

If you are a manufacturer you are supposed to pay ITAR. There is a letter you can write which basically says "I'm researching not selling" and occasionally get variances but it is very rare. Some have tried to get away without paying it while researching and some probably get away with it but others have been charged with what would basically be considered back taxes for it.

This is all from me reading though I do not have direct experience.

You most definitely do not need to send prints to the ATF for the form 1. Length and caliber is plenty. No you cannot alter it (beyond removing additional material for say cone clips) after it is complete even if it sucks, nor may you repair it. Now when is it considered complete is the question? Some argue (whiterussian I believe) that its complete when you decide it is satisfactory. Many more argue that it is complete when you fire it the first time. Thought police BS in my opinion.

I build for pride mostly and as an engineer I enjoy tinkering too. I have no illusions of grandeur about building a better mouse trap.

[BinaryAndy]

Wasn't sure about how easy it is to get your personal collection out.

It's already "out". The form 4 process is a tax on transfers. If you make NFA items as an FFL, and then stop being an FFL, you already own the items so no transfer has occurred. You retain ownership, ATF does not pass go or collect $200. (This does not apply to post-ban machine guns, they must be transferred to someone who can have them.)

[doubloon]

... The form 4 process is a tax on transfers. ..

No s--t?!?!? Good to know.

I believe you're talking about how it works for a legitimate 07/0x business and not the guy who started this thread who just wants toys without paying the tax.

[JC in SC]

... The form 4 process is a tax on transfers. ..

No s--t?!?!? Good to know.

I believe you're talking about how it works for a legitimate 07/0x business and not the guy who started this thread who just wants toys without paying the tax.

My primary reason would be to avoid the wait for the approval followed by cost savings. I'm very intrigued by the design aspects, but am discouraged about the wait and a possible $200 boat anchor that suppresses poorly. I wouldn't be opposed to starting a small FFL business, even if it were only self sufficient. I don't mind paying for toys, have three in jail at the moment. I'll probably submit a form 1 for a suppressor in the coming weeks/months once I recover from recent expenditures:)

[T-Rex]

Personally, I think you're going a bit overboard.
Wait times are not terrible, about 100 days now, and are the perfect time to plan, research and design your build.
A $200 boat anchor? Not if you put in the time reading and asking questions.

Id rather produce a quality product, once every couple of months, than knock out so-so pieces on a daily basis, trying to get it right.

And to be honest, although I don't agree with it, a $200 tax is merely pittance when you weigh the advantages of a suppressor. My scope rings cost more than that!

Instead of worrying about an FFL, I'd sit down and make a list of my needs and goals. Then, focusing around those, spend the next couple of weeks researching. Plot a simple sketch and build process, and either post it up, for critique, or IM it to individuals of your choosing. By the time your stamp is approved, you'll have a final rev.

$.02

[BinaryAndy]

No s--t?!?!? Good to know.

I believe you're talking about how it works for a legitimate 07/0x business and not the guy who started this thread who just wants toys without paying the tax.

It would work that way for any FFL, but you have to at least intend to make a profit from your business in order to have an FFL. You're not allowed to get an FFL "only" to acquire personal firearms. The application asks a few yes/no questions about this.

You could in theory get an FFL, make some experimental designs, and attempt to sell said designs to manufacturers thus avoiding ITAR under the R&D exemption. Not that I think this is a good business plan, but it is a thought. Of course ITAR is so vaguely worded that it could probably be applied to half the population of the US. Heck, a lot of the posts on this forum definitely violate ITAR. The whole thing is blatantly unconstitutional and absurd.

I do tend to agree with T-Rex, FWIW.

[doubloon]

.... What is not completely clear to me is how much detail must go into the Form 1. It seems that I have seen some information that indicates caliber and maximum length are all that is required to submit the Form 1. ...

Maximum length and maximum caliber but putting down a length of 8" and ending up with a length of 6" or less might be an issue if you were extremely unlucky.

[mr fixit]

I looked into pretty much the same thing just because I wanted to know. I sent E-mails to the Department of State about the ITAR fees for R&D. This is the Email chain:

I sent:
To: DDTC Response Team
Subject: ITAR registration and fees question

I am looking into the possibility of obtaining a Manufacturer type 07
with SOT license, to be able to legally manufacture firearm
silencers/suppressors. This would not involve sales of any kind, and
would be only to allow legal research and development of suppressors and
suppressor components.

Since there would be no sales and no marketing, what would be the
requirements in regard to ITAR? And what, if any fees would be
required?

Thank you,

The reply:

All manufacturers, exporters, and brokers of defense articles, related
technical data and defense services as defined on the United States
Munitions List (Part 121 of the ITAR) are required to register with the
Directorate of Defense Trade Controls (DDTC). Registration is primarily
a means to provide the U.S. Government with necessary information on who
is involved in certain manufacturing, exporting and brokering
activities. Registration does not confer any export rights or
privileges, but is a precondition for the issuance of any license or
other approval for export.

There is an initial fee of $2250. Please click on the links below which
provide detailed information regarding the registration process.

Who Must Register - http://pmddtc.state.gov/registration/wmr.html
Registration Submission - http://pmddtc.state.gov/registration/crp.html
Electronic Payment of Fees -
http://pmddtc.state.gov/registration/epr.html


Thank you,

Adrienne R. McElhaney
DDTC Response Team

I responded to clarify:

To clarify, even though no products on the list would be sold or
otherwise available to transfer, and only doing research and
development of the technology would require the payment of the fees?


And the final response:

Companies that engage solely in research and development, with no sales or gifting involved, are specifically excluded from the registration requirement per ITAR Part 122.1(b)(4).
Kirk Bennett
DDTC Response Team

Which says to me that it is possible. I would think you could try many variables and parts layouts and keep rebuilding or start over until you found what worked then either offer to sell the design or even share it with your friends here. I would think you could also build a form 1 suppressor for yourself based on the extensive research you have done. I don't think you could build lots of 'prototypes' to test and keep them as your personal cans.

[mr fixit]

Just to add, you would still have to qualify and apply to become a 07 SOT FFL.

[PBinWA]

Move to Idaho?

[alordnapa]

1) Get a job with a licensed manufacturer, and never, ever, even think about bringing any solid work home
2) Move to a free country
3) Do all of your design work, flow analysis, etc, and pay a manufacturer to build and test your design(s)
4) Spend a zillion dollars to comply with all Federal SOT and State licensing, manufacturing, and storage requirements, and risk being financially ruined and/or killed for the slightest error or misstep.

Have you noticed that all these choices suck?