Clarification to Previous Machinegun Law Letter Alert

F.A.I.R. Trade Group
F.A.I.R. Trade Group
FireArms Import/Export Roundtable Trade Group
FireArms Import/Export Roundtable Trade Group

USA – -(Ammoland.com)-In an Alert issued on August 8, 2016, F.A.I.R. Trade Group notified members of an apparent change in ATF policy on the term of validity of the law enforcement demonstration letters required to be submitted with Form 6 import applications and National Firearms Act (NFA) transfer applications.

The Alert advised that at the recent Import/Export conference held in Washington, DC, ATF officials advised industry members that the law letter required to import and transfer machineguns as dealer sales samples is valid only for a period of six months. The Alert stated that ATF will not approve a Form 6 import application or a NFA transfer application if the law letter is more than six months old.

On August 11, 2016, ATF officials advised F.A.I.R. that the 6-month period of validity is limited to law letters submitted with Form 6 import applications. ATF officials advise that the 6-month term of validity is a long-standing policy and was consistent with the term of validity for the International Import Certificate (IIC).

ATF officials further advise that the agency applies a one-year period of validity to law letters submitted with NFA transfer applications on Forms 3, 4, and 5. Thus, a law letter that is 7 months old would not be accepted by ATF with a Form 6 import application, but it would be accepted with a Form 3 transfer application or other domestic transfers.

The F.A.I.R. Trade Group notes that ATF’s limiting the law letter validity period for imports to the 6 months synonymous with the IIC is overly burdensome, especially because F.A.I.R. has been working since 2009 with the Department of Commerce to get the term of the IIC extended to one year. Importers are well aware that the 6-month term of validity of the IIC often causes delays in obtaining export authorizations from countries abroad, and a second, newly issued IIC is often necessary before the transaction is complete. The same considerations should dictate a one-year term of validity for law letters submitted in support of Form 6 import applications.

The F.A.I.R. Trade Group will be submitting a petition to ATF requesting the agency to consider changing its internal policy to accept law letters for a one-year period for purposes of import. This change will ensure consistency in the term of validity and avoid requesting police departments to sign fresh letters for NFA imports.

F.A.I.R. apologizes for any confusion our Alert of August 8, 2016, may have caused.

The F.A.I.R. Trade Group is a 501(c) (6) organization dedicated since 1994 to protecting the interests of the firearms and ammunition import and export community. F.A.I.R. operates entirely on the funds derived from our dues-paying membership. If you are interested in becoming a member or contributing to the organization, please visit our website at: www.fairtradegroup.org.

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