The recent changes to US export regulations by the Bureau of Industry and Security (BIS) have introduced new complexities for UK dealers importing long-barrelled shotguns and optics from the U.S.
From 30 May 2024 all such exports to the UK (and Australia) now require a BIS license due to the adjustments under the AUKUS Trilateral Security Partnership. This regulatory shift has rescinded the previous “No License Required” status that facilitated easier trade between these nations.
The implications of this regulatory update could be considerable for the UK trade. First, the requirement for export licenses introduces additional administrative burdens and potential delays in the supply chain. The licensing process can be time-consuming and may involve detailed documentation and compliance checks, which could lead to longer lead times and increased costs for dealers.
Under the new rules, the export of these firearms and optics will require a license to all countries, driven by a Crime Control (CC) reason for control. This expansion signifies a global tightening of US export controls for firearms-related items, not just those directed at the UK and Australia.
For UK dealers, this means navigating a more stringent regulatory landscape that could potentially limit the variety and availability of U.S.-sourced firearms products. The additional hurdles might make it less economically viable to stock US products, possibly leading to a decreased range of offerings for UK consumers. Although, after speaking to key players around the issue, Gun Trade Insider believes UK importers and their US partners to be robust enough to handle the negative impact of this ruling.
The National Shooting Sports Foundation (NSSF), the US industry trade association, is actively reviewing these changes and is in the process of preparing a significant commentary to BIS, expressing the industry’s concerns and the economic impact of
these regulations.
Gun Trade Insider spoke exclusively to Mark Oliva, managing director, public affairs, NSSF, he commented: “NSSF is cautiously optimistic that the new Interim Final Rule published by the Commerce Department’s Bureau of Industry and Security (BIS) should have little visible impact to firearms and ammunition being exported from US manufacturers to businesses in the UK.
“NSSF is, however, continuing to monitor the implementation of the new Interim Final Rule closely, as the “90-day pause” of firearm exports lasted well beyond 180 days and caused considerable disruptions to US firearm and ammunition manufacturers and those businesses importing US products in overseas markets. The new Interim Final Rule, however, will have considerable logistics and administrative burdens on US exporters, as export licenses that were previously valid for several years must be renewed annually.”
Mark advised that the UK trade pay close attention to the below section of the legal documentation:
BIS creating four new Export Control Classification Number (ECCN) codes: 1) semi-automatic rifles; 2) semi-automatic pistols; 3) semi-automatic shotguns; and 4) certain “parts,” “components,” devices, “accessories,” and “attachments” for items controlled under ECCNs 0A506, 0A507, and 0A508. “Legacy” ECCNs to cover non-semi-automatic rifles and shotguns.
Rule adds Crime Control (CC) as a reason for control to all 500 series ECCNs, and revises the Country Chart column CC2 to require a license for ALL countries except Canada. This means long barreled shotguns and optics which currently do not require a license to some countries (A1, NATO, etc.) will now need a license. Further, the rule ends the “presumption of approval”, moving to case-by-case basis determination for all countries except the 36 listed in the Dept. of State Firearm Guidance Document, and listed in Part 742 Supplement 3, which have a “presumption of denial” policy. Extending denial policy to all countries with arms embargoes under International Traffic in Arms Control
Regulations (ITAR).
UK distributor, Viking Arms, imports a multitude of products from the US and will be affected by the
rule changes.
Andy Norris, Sporting division manager at Viking Arms told Gun Trade Insider:
“Viking are aware, as are its manufacturers and procedures are being put in place on both sides of the pond to meet any change in legislation. This is just another inconvenience to add to the Brexit issues, resulting in extra delays and costs to all involved.”
