Mr. Lomas
I agree about the sporting shotguns with barrels greater than 18 inches. but rifles are a different story:
Category I - Firearms, Close Assault Weapons and Combat Shotguns
* (a) Nonautomatic and semi-automatic firearms to caliber .50 inclusive (12.7 mm).
Note:
This coverage by the U.S. Munitions List in paragraphs (a) through (i) of this category excludes any non-combat shotgun with a barrel length of 18 inches or longer, BB, pellet, and muzzle loading (black powder) firearms.
Are bolt action rifles non automatic? What about single shot rifles, or pump and lever action rifles?
What you forgot to include is that the " * " before that means any of those guns that are considered "Significant Military Equipment".
There in lies the key point to all this. !!!
With all respect I think you're reading this wrong. The definition of significant military equipment is outlined in Sect. 120.7. After reading the regs, I can find no exception for sporting arms other than shotguns with bbl longer than 18", bb guns and pellet guns and muzzle loading guns..
§ 120.7 Significant military equipment.
(a) Significant military equipment means articles for which special export controls are warranted because of their capacity for substantial military utility or capability.
(b) Significant military equipment includes:
(1) Items in § 121.1 of this subchapter which are preceded by an asterisk; and
(2) All classified articles enumerated in § 121.1 of this subchapter.
[58 FR 39283, July 22, 1993, as amended at 62 FR 67275, Dec. 24, 1997]
Dept of Commerce Firearms Export FAQ includes the following:
What types of firearms does the Department of Commerce have jurisdiction over?
The Department of Commerce's Bureau of Industry and Security (BIS) has jurisdiction over shotguns with a barrel length of 18 inches or more and related components. BIS also has jurisdiction over muzzle loading rifles and handguns, air guns, replica firearms, shotgun shells and components, and most optical sighting devices for firearms.
What types of firearms does the Department of State have jurisdiction over?
Department of State’s Directorate of Defense Trade Controls (DDTC) has jurisdiction over defense articles and services.
This includes rifles and handguns and certain optical sighting devices. DDTC also has jurisdiction over shotguns under 18 inches in barrel length.They go on to say that rifle stocks are under the jurisdiction of the Dept. of State (DDTC), which administers ITAR.
There is a provision to request a commodity jurisdiction(CJ) to determine if your goods or service falls under ITAR regulation. Apparently this cannot be filed for a class of items but must be filed for each item.
