Brent, you have a lot of experience but that was not my impression of ATF. Sometime around 2009 A general in Afghanistan without much to do ruled that all center-fire antique guns being sent to the USA via APO had to get pre ATF approval. This included Sniders and Martini-Henry. I found a very knowledgeable guy at ATF importation branch who explained all the rules to me. He forwarded the forms. I filled them out and got them back a month later. Mind, these were US import regulations. But if there are US laws pertaining to export as well, I would expect them to know. Gene
ATF has an import regulation branch but no export. I submitted an e-mail question to them on Jani's behalf:
to: imports@atf.gov
Exporting antique (pre 1898) hand gun collection to Europe:
Sirs: I am asking this question for a European friend. He has several pre 1898 antique pistols, mostly percussion, stored with an FFL gun dealer in the USA. He would like to export these to the European Union. He can handle the EU importation paperwork from that side of the Atlantic. However, are there any US laws that need to be addressed before export? Thanks
Maybe so, but your experience is an American (and American organization), sending a gun back to America. Sending a gun to a foreign land (and NOT an American military instillation), is nothing like sending a gun or part your English friend, Harry, which is what I was trying to do. THAT is State Department all the way. The rules as I recall, are that you can send parts under $100 value, but NOT barrels of any value, nor complete guns. And that's just from the American end of the transaction. What is required on the other end - is yet another thing, but I never got to that because USA law said I could not send a barrel, period. You might notice that many dealers will no longer sell barrels or liners to any out of country address any longer. That started maybe 5-10 yrs ago, due to these restrictions.
I imagine that generals can autocratically declare a lot of rules, and the military has to abide by them, but the OP did not invoke the military in his question. Also, this is outbound, not inbound.
Call a senator's office or peruse the State Department website and find the correct office. Once I did that, it was all crystal clear in just a minute or two.