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Which licenses need to manufacture a silencer design for research only ?

Posted: Mon Jan 16, 2017 12:29 pm
by ptcraft1234
Hi thanks to everyone for the great information here.

I'm excited about trying out a new silencer design for research only but wanted to make sure I file the proper paperwork.
If I am making two distinct designs, then I would file two Form 1s for personal use (one for each design) and thats it ?
I would not need a Form 7 to register as a general manufacturer if I am only making these two designs for research or personal use correct ?


Thanks for any guidance on this matter.

Re: Which licenses need to manufacture a silencer design for research only ?

Posted: Mon Jan 16, 2017 12:45 pm
by ptcraft1234
As a follow up, the reason why I was thinking a Form 7 would be needed is because it would be difficult to change baffle designs while doing research on the design. I guess it would be safer if I filed a Form 7 (although much more expensive), but would allow me to fine tune the design without violating ATF laws on baffles or other structural designs.

If anyone has a good license path to do a silencer research and design without violating any laws, please let me know. Thanks

Re: Which licenses need to manufacture a silencer design for research only ?

Posted: Mon Jan 16, 2017 1:20 pm
by doubloon

Re: Which licenses need to manufacture a silencer design for research only ?

Posted: Tue Jan 17, 2017 4:02 am
by bakerjw
ITAR is the kicker. That is what stopped me.

Re: Which licenses need to manufacture a silencer design for research only ?

Posted: Tue Jan 17, 2017 7:59 am
by T-Rex
bakerjw wrote:ITAR is the kicker. That is what stopped me.
I'm not sure if this is where he's getting the "for R&D only" part.
ITAR does have exemptions and this is one of them.
I've done a bit of reading and it seems you can get an 07/02 and not pay ITAR, with this being the rationale.
I haven't come across anyone needing to represent themselves, but I know this doesn't mean no one has, potentially, gotten slapped for it.

It looks like there is a process to which paperwork can be filed on a firearm by firearm basis. I'm not sure if the ATF has to approve each case.
Some have hinted that they go, solely, by the wording in the ITAR exemption list and forego the paperwork process.

Just what I've read, on this topic.

Also, don't you need to establish and verify a business, to get an 07?

Re: Which licenses need to manufacture a silencer design for research only ?

Posted: Tue Jan 17, 2017 10:12 am
by fastfire
bakerjw wrote:ITAR is the kicker. That is what stopped me.
Maybe the Trumpster will take care up the ITAR bs.

Re: Which licenses need to manufacture a silencer design for research only ?

Posted: Tue Jan 17, 2017 8:57 pm
by doubloon
T-Rex wrote:
bakerjw wrote:...
Also, don't you need to establish and verify a business, to get an 07?
Even if it's not necessary it would be wise to assign your 07 to a LLC.

Re: Which licenses need to manufacture a silencer design for research only ?

Posted: Wed Jan 25, 2017 2:52 pm
by diesel_fireman2001
You don't have to register with the DDTC and pay the ITAR tax until you start selling them. I emailed them a similar question awhile back and that is the response I got from them.