UPDATE August 2018: As we prepare for the long-awaited shift of commercial firearm-related items from the ITAR (Department of State) to the EAR (Department of Commerce) (see our post on that here), we’re preparing for an exciting new ‘Small Parts Exemption Service’. A few of the likely changes: increase in the dollar amount to $500 for all legal countries, and more items allowed (i.e. barrels, some ammo or components, more shotgun parts, etc.). Stay tuned for more info, which we’ll post as soon as it’s available!
IMPORTANT UPDATE: As of July 2013, just a few months after we published this post, DDTC raised the limit for qualifying small parts exports to Canada to $500, as anticipated.
In conversation with contacts at the U.S. Department of State, Directorate of Defense Trade Controls (“DDTC”), we’ve recently heard an interesting rumor that is worthy of hope, but as with all such things– don’t get too excited until it’s official.
This morning we received the following in part of an email from a contact at DDTC, after we raised the issue that their newly-revised “Firearms Guidelines” referenced a “$500 small parts exemption for Canada”:
My understanding is that a decision was recently made to revise 123.17(a) to raise the exemption to $500 in the case of Canada. But that has not yet been published in the Federal Register, because OMB has not approved it yet. So you cannot use the $500 exemption for Canada yet. We have brought this to the attention of the people who edit the Firearms Guidance.
So– we’ll certainly keep our eyes on this and post any updates if and when they become official.
The current exemption allows for exports of small firearms parts valued up to $100 wholesale, without an export license, when a Registered exporter such as ourselves files an “AES filing” claiming use of the exemption and giving the pertinent details.
Of course, if the limit does officially raise to $500, we’ll of course continue to offer this exporter AES filing service, which will become much more useful!
[Note: several years ago the exemption at 123.17(a) did include a $500 provision specifically for Canada, so whether this is a mistaken re-publishing of an old policy, or a real change in the works is yet to be seen.]