Suppressors Suppressors allowed for export

[LeftyJason]

Just saw this. Don't fully understand the implications but looks like good news.

TRUMP ADMINISTRATION LEGALIZES COMMERCIAL EXPORTATION OF SUPPRESSORS - American Suppressor Association

Trump Administration Legalizes Commercial Exportation of Suppressors WASHINGTON, D.C. – The American Suppressor Association (ASA) is thrilled to announce that the Trump Administration has officially legalized the commercial exportation of firearm suppressors, effective immediately. The State...

americansuppressorassociation.com

 

[Hobo Hilton]

Good news for who? Surely for manufacturers.... Not so good for the Americans waiting in line for months.

Hobo

 

[Blutroop]

Yup he shoulda signed off on the hearing protection act instead so we could have our constitutional rights without needing a tax stamp or ear plugs.

 

[required_user_name]

Good, but supply and demand. Limited capacity to produce suppressors with a much larger international demand. Seems like more out of stock for us.

 

[hlee]

On the flip side, international demand could spur the relatively boutique US suppressor industry to increase capacity to meet demand. And, suppressor costs in other countries are mere fractions of what they are here in the states. I’m not sure a $1000 can is going to compete with the prices they see in European countries where suppressors can be bought off the shelf in sporting goods stores...

 

[hlee]

Yup he shoulda signed off on the hearing protection act instead so we could have our constitutional rights without needing a tax stamp or ear plugs.

Never got the chance. HPA died in committee...

 

[Zak Smith]

Candid talk and IMHO -- the restrictions on the US silencer market created market forces that produce better-performing suppressors, esp. on the high end, than Europe. This is because they are considered a "lifetime" purchase and so people want to buy the best. There are segments of the European and world market that already buy U.S. silencers for various reasons, one of them being performance. Capacity is limited mostly by how much a company wants to outsource and/or go in debt for machines vs. the downsides for each of those choices, or, potentially, later on. Business/company-level drama is common for gun companies that have been "optimized by MBAs".

The new change still requires an end-user certificate and it's not clear, at least to me, how this will actually shake out.

 

[LeftyJason]

Any insights @THEIS?

 

[Hobo Hilton]

Silencers are being manufactured around the world in great quantities.....

The Feds made a bold move... They seized the website of one of the suppliers. Nothing in the article says they seized any silencers.... LOL

Hobo

Archived: ICE HSI seizes website illegally selling weapon components, silencers from China in US

HSI Detroit seized the internet domain “http://lafoauto.com/” pursuant to an international arms-trafficking investigation. HSI determined that more than 350 suppressors seized by law enforcement across the county were purchased from the website and smuggled into the United States from China as...

www.ice.gov

 

[Zak Smith]

I'll just also point out that silencers *could* be exported prior to this change, but generally only to the military or federal police of allied nations.

 

[Zak Smith]

Basically as I read it prior to this the companies that had existing military/government contracts to supply suppressors would be used

If "government contracts" in this sentence meant US government contracts, I am pretty sure that is not true.

 

[Zak Smith]

Here is the text from the DDTC web site

DDTC Web Notice Regarding an Update to its Suppressor Policy - - DDTC Public Announcements

Effective immediately, the Department of State has rescinded its April 18, 2002, firearms sound suppressor policy. This policy provided for enhanced guidelines for the approval and issuance of export licenses for sound suppressors and restricted their export to only official end users such as government or military entities. Henceforth, DDTC will handle suppressor exports in a manner consistent with other USML-controlled technologies. This requires that applicants must identify a specific end user. Applications for the permanent export of hardware must include purchase documentation, a DSP-83 non-transfer and end use certificate (as suppressors are considered Significant Military Equipment under the USML), an end-user statement, and an import permit (if required by the destination country). Consistent with current licensing practices, all licenses will be reviewed and adjudicated on a case-by-case basis, and any pre-license checks or post shipment verifications will be conducted as deemed necessary and appropriate based on the totality of the circumstances of the transaction. Standard staffing protocols within the Department and interagency will be applied as required.

Event: DTAG Meetings
07/07/20
Plenary - May 14, 2020 - - DDTC Public Announcements

 

[HansohnBrothers]

Another question; which of the countries we can ship USML category 1 items to allow commercial importation of silencers? Let’s not forget import duties/taxes/tariffs, plus importer and broker fees. On the US side, we have to deal with Dept of State which presents its own challenges.

 

[THEIS]

Any insights @THEIS?

Hi,

Well, lol...lots actually but I learned not to attempt ITAR, DDTC, etc talk on forums because of all the "professionals" that want to attempt to argue, lolol.

Here is the short and sweet for clarity:

1. Suppressors have ALWAYS been allowed to be exported by USA based companies (Not USA Gov itself). They just had to be exported to .gov entities following same process as below and NOT to civilian end users.

2. The new policy is putting suppressors into the same export category and process that firearms used to be in. The exporter (Not the USA Gov itself) must get an import permit, EUC, signed DSP83, signed PO, etc from the buyer then complete the DSP5 (Permanent Exportation of unclassified items) and submit everything to the DDTC. DDTC will review each case just as they use to do with firearms and still do with everything else on Sec 121 of USML. Then DDTC will either approve or deny. The exporter then lodges the approved DSP5 and all other documents into the AES and delivers the package to the freight forwarder listed on the DSP5.

3. To any suppressor mfg here reading this, lol....Be sure to put a designator in your serial number scheme to differentiate between USA and International suppressors. It will help make it easier to calculate your FET.

Sincerely,
Theis

 

[HansohnBrothers]

Hi,

Well, lol...lots actually but I learned not to attempt ITAR, DDTC, etc talk on forums because of all the "professionals" that want to attempt to argue, lolol.

Here is the short and sweet for clarity:

1. Suppressors have ALWAYS been allowed to be exported by USA based companies (Not USA Gov itself). They just had to be exported to .gov entities following same process as below and NOT to civilian end users.

2. The new policy is putting suppressors into the same export category and process that firearms used to be in. The exporter (Not the USA Gov itself) must get an import permit, EUC, signed DSP83, signed PO, etc from the buyer then complete the DSP5 (Permanent Exportation of unclassified items) and submit everything to the DDTC. DDTC will review each case just as they use to do with firearms and still do with everything else on Sec 121 of USML. Then DDTC will either approve or deny. The exporter then lodges the approved DSP5 and all other documents into the AES and delivers the package to the freight forwarder listed on the DSP5.

3. To any suppressor mfg here reading this, lol....Be sure to put a designator in your serial number scheme to differentiate between USA and International suppressors. It will help make it easier to calculate your FET.

Sincerely,
Theis

Excellent synopsis. Unlike title 1 firearms, there is no FET due on title 2 firearms.

 

[THEIS]

Hi,

Another point of reference for the manufacturers.

Getting business relationship established with a regional importer/distributor in abc country is an easy way to make your products more viable in that country for several reasons but the main 1 is that instead of the $250 cost of the DSP5 for 1 suppressor to an individual; you can do the same $250 cost of the DSP5 for the importer with hundreds of every product model you make.

The US Department of Commerce has a specialized business cooperation department that can investigate and recommend potential International partners for you if you do not have a starting point or contact me; I do this stuff in my sleep, lol.

Sincerely,
Theis

 

[LeftyJason]

Hi,


I do this stuff in my sleep, lol.

Sincerely,
Theis

The whole reason why I tagged you into this thread.