SMALL PARTS EXEMPTION ($500/$100) SERVICE DETAILS
Note: in July 2013, for Canada only the previous “$100 limit” was raised to $500 USD.
Details about the exemption found in 22 CFR 123.17(A).
United States law (specifically the “ITAR” – International Traffic in Arms Regulations”) allows for the export without an export license of certain firearm-related parts and components. This guide provides some details about the so-called “small parts exemption.” Here are the basics:
- Does not apply to any parts/components related to Shotguns (these are regulated by the U.S. Department of Commerce rather than the U.S. Department of State, and there is not equivalent exemption for shotgun parts in the Export Administration Regulations).
- Does not apply to ammunition-related parts and components. These are classified as “Category III on the U.S. Munitions List, while the exemption only refers to “Category I(a) firearms.”
- Does not apply to “Significant Military Equipment,” which includes any firearm itself.
- Does not apply to any parts at all related to fully automatic firearms, even if you’re planning to use the part on a semi-auto variant.
- Does not apply to any parts made in embargoed countries such as China, Iraq, some Russian companies, etc. (See list at this link).
- Does not apply to Scopes, which are regulated for export separately by the U.S. Department of Commerce, and there is no equivalent exemption.
- Also does not apply to barrels, cylinders, frames (receivers), or complete breach mechanisms.
- Exemption can only be used and claimed by a DDTC Registered Exporter (not just any business, nor a foreign individual traveling in the US).
- As the Registered Exporter, we must still file documentation online (using the Automated Export System, or AES) to notify the government that we’re using this exemption, including the item description, tariff code, value, weight, date of export and Port of Exit.
- By law, orders cannot be broken up into smaller shipments to meet the $100/500 threshold.
- It is defined in the law as $100 ($500 for Canada) “wholesale” value, so in limited cases we may export something that retails for slightly more than $100/$500 USD if our wholesale cost is less than the applicable amount.
OUR FEES FOR PROCESSING A LOW-VALUE EXEMPTION
Australia / New Zealand
All Other Countries
Exemption Filing Fee for single (or first) line item:
Exemption Filing Fee for each additional line item:
+ 5% of the total value
Prices do not include shipping, nor any taxes or duties charged by the importing government.
FREQUENTLY ASKED QUESTIONS
about the “small parts exemption”
1. Why do we charge an exemption filing fee if there’s no export license required?
Even though there is no full export license required, U.S. law requires that any business that uses this exemption be a ‘Registered Exporter’ which is very costly. Further, exports made under this exemption are required to be filed using a system called ‘AES’, and in so doing we are certifying compliance to the regulations, which means inspecting contents of the package and doing our due diligence, which takes time and resources.
2. What about the other exemptions? Like for guns made before 1899?
We have more information available about other services, including the “pre-1899 exemption” on our website at www.borderview.com/services/for-individuals/.
3. Isn’t the exemption for $100 value, not $500?
For several years until July 2013, the exemption limit was at $100 USD value for all countries. On February 22nd, 2013 we posted on our blog (link here) that we heard from inside sources of a possible forthcoming increase to $500 value for Canada only. Then, on July 5th 2013 we were the first company to publicly post about the official announcement of the change, over on the forums at CanadianGunNutz (link here).
4. How do I get started?
5. Does the product have to be shipped to you first or can the seller send it straight to me?
Yes, the product must be shipped to us first, because we must verify that the item actually being exported is exactly as we described it on the export declarations. Therefore we must have the items in our possession, and initiate export from here.
6. Where should I have the box sent? How should it be marked?
After you’ve completed the “Small Parts Exemption Request” form and we’ve given you approval to proceed, we will send you shipping instructions.
7. Will my package be opened?
Yes, we have to make sure we’re exporting what we say we’re exporting. Any apparent damage or deficiencies will be reported to you right away.
8. How long does the process take?
We will typically process an Exemption Filing within 1 week of receiving your package. Issues such as slow payment or complex shipping can extend the timeline.
9. How much will shipping be to me, from Borderview International?
Whenever possible we use the United States Postal Service (USPS) to ship parts/components under the small parts exemption. To determine postage costs from us to you, visit http://ircalc.usps.gov/, select your Destination Country, Package Type and estimated weight. We ship either by Priority Mail International or Express Mail International – your choice. (Some countries don’t allow any firearm-related items to be imported by mail. To check regulations for your country, visit the USPS’ International Mail Manual Individual Country Listings here).
10. If I’m going to be in the Lynden area, can I pick up the merchandise at your office?
Unfortunately, due to the complexities around the actual cross-border portion of the process, we must ship the items to you. However, postage is usually quite reasonable and saves you the time and fuel of making a trip.
Finally, the Fine Print: Borderview International reserves the right to refuse any shipment whether it meets the qualifications herein or not. This guide is meant for informational purposes only, and is not intended to be understood as complete or a full interpretation of the law. Consult a lawyer licensed in your jurisdiction for qualified legal advice. The importer is fully and completely responsible for complying with all import regulations within their country. Rejection of a shipment by Customs or otherwise is not grounds for any sort of refund, for fees or shipping. Borderview LLC is not responsible for any damage that occurs during shipment, whether shipment from the seller to our facility, or from our facility to the foreign end user. And if you’re still reading, thank you for your attention to detail, it goes a long way in this industry.
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This information is provided as general information only and in no way is intended as legal advice. Before making any decisions based on this information you should confirm the facts yourself and contact a licensed attorney for legal advice as needed. The application and impact of laws can vary widely based on the specific facts involved. Given the changing nature of laws, rules and regulations, and the inherent hazards of electronic communication, there may be delays, omissions or inaccuracies in information contained herein. Accordingly, the information on this site is provided with the understanding that the authors and publishers are not herein engaged in rendering legal or other professional advice. As such, it should not be used as a substitute for consultation with professional legal advisers. Before making any decision or taking any action, you should consult a qualified and duly licensed legal professional.