DIAS Question

[opsoff1]

For the experts: Can a current Class 2 Dealer / Manufacturer make a DIAS? Assuming if it is allowed, it would fall into a Post May 86 Dealer Sample? and hence only available to other Class 2 or Class 3 guys & LEO's?
Please school me on this.

This generated from a discussion I heard at the range the other day.

TIA

[rjacobs]

yes. An 07/02 can basically manufacture anything. Those things which are considered post samples would be available for other 02/07's, 01/03's with a love letter or to LEO or MIL or GOV types.

[opsoff1]

Thank you for the reply. A few more questions if I may..
Does the holder of the 02/07 need to manufacture in house or can he sub out the various parts to different machine shops?
Is a subcontracted machine shop required to be an 02/07 holder as well?
Obviously since he can manufacture a DIAS, then it must go through the registration process, SN'd, Dated etc. and would only be available to the Gov/Mil/LEO. Additionally, he couldn't manufacture until he had a legit request from one of those agencies? Correct?

TIA

ETA - I had opined at the range, that due to all of the heartburn with DIAS's back in the early 80's, that he couldn't make new ones - looks like I was mistaken.

[rjacobs]

Thank you for the reply. A few more questions if I may..
Does the holder of the 02/07 need to manufacture in house or can he sub out the various parts to different machine shops?
Is a subcontracted machine shop required to be an 02/07 holder as well?
Obviously since he can manufacture a DIAS, then it must go through the registration process, SN'd, Dated etc. and would only be available to the Gov/Mil/LEO. Additionally, he couldn't manufacture until he had a legit request from one of those agencies? Correct?

TIA

I do not have an 07/02 so really am not an expert on the minutia. I think the answer is NO to the first that you cant sub something out to a non licensed shop, but maybe you can with a variance. I dont know. I do believe an 07/02 could buy a DIAS from another 07/02 or have another 07/02 manufacturer for them, under a variance. Just as an example quite a few shops sell lowers with their name on them. They generally do 0% of the work. However they are still required to be an 07/02(and pay all the fun ITAR fee's) and have the lowers manufactured for them under a variance. I would GUESS the same goes for stuff like DIAS or other products that require an 07/02.

To the second, an 07/02 can manufacture what they want, when they want, thats what they pay to do. They dont have to wait for anybody to request something. How else would an 07/02 build prototypes of a new weapon that they would then take around and demo? An 01/03 would have to wait to get something like a DIAS until an agency requested a demo of it and gave them a love letter.

[opsoff1]

Appreciate the insight. Thank you.
A lot of this generated from the discussion about new DIAS (useless IMHO) and who can make them. I didn't think they could be made any longer.
Confusing - glad I am not in that business.

[rjacobs]

Im sure somebody with an 07/02 can chime in on this eventually and speak to the minutia if it.

[Gunfixr]

An 07 with sot can make them, and yes they are post samples. You just send in your f2 and tell them.
It can only be transferred to gov, le agencies, other 07s or 01/02s with sots and an le demo letter.

Because of all the 80% receiver hype, and people getting local shops to finish them, and businesses selling them and letting the customer finish it on their machine, "manufacturing" has been really, fully defined as of early this year.
Pretty much making anything that will get a number must now be done by an 07, but it was always this way for nfa.

Sent from my SGP612 using Tapatalk

[opsoff1]

An 07 with sot can make them, and yes they are post samples. You just send in your f2 and tell them.
It can only be transferred to gov, le agencies, other 07s or 01/02s with sots and an le demo letter.

Because of all the 80% receiver hype, and people getting local shops to finish them, and businesses selling them and letting the customer finish it on their machine, "manufacturing" has been really, fully defined as of early this year.
Pretty much making anything that will get a number must now be done by an 07, but it was always this way for nfa.

Sent from my SGP612 using Tapatalk

Can an 07/02 sub out the parts to a local machine shop? If so - who would have the responsibility to SN / Date them?

[Gunfixr]

Only parts that are not "firearms". If it has to have a serial number, an 07 has to make it.
It would have to be numbered as soon as it meets the qualifications.
A completed and usable dias must have a number, so as soon as it is usable, it qualifies.
Usable is defined by atf, not we the people. You can guess, but should err on the side of caution. Otherwise, you have to send a sample, which for one-offs, is not practical.
For the AR dias, the housing should be able to be subbed out to a non 07 if the sear hole isn't drilled, and the sear if it's pivot hole isn't drilled. Then, the 07 drills the holes, and assembles it, and engraves it. Should, this is my guess, based on my reading much of the nfa handbook and talking with senior atf investigators and an atf attorney about manufacturing.

Also, there are exceptions. Since all suppressor parts are regulated, even though only the tube is numbered, an 07 is required to make any suppressor parts. But again, if they are not complete, meaning usable, it's not a part yet. But I have not discussed whether dias parts fall under this or not. There just isnt a market for such things, since they aren't transferable.

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