FFL Import & Export Regulations 3 — Questions and Answers
Question 1: A Type 08 FFL (importer of NFA firearms) wishes to import a foreign-made suppressor. Which additional approval is required beyond ATF Form 6?
- State Department DSP-61 license
- ATF Form 4 tax payment
- DEA import certificate
- No additional approval; Form 6 is sufficient for NFA importers (Correct answer)
Correct answer: No additional approval; Form 6 is sufficient for NFA importers
A licensed NFA importer (Type 08) with an approved ATF Form 6 import permit may bring in NFA items without a separate Form 4; the Form 4 governs civilian transfers.
Question 2: Under 27 CFR Part 478, how many days does an FFL have to report the importation of multiple handguns (two or more) to ATF?
- 24 hours
- 48 hours
- 5 business days (Correct answer)
- 30 days
Correct answer: 5 business days
FFL importers must file an ATF Form 3310.5 report within 5 business days when importing two or more pistols or revolvers at one time.
Question 3: Which US Munitions List (USML) category covers pistols, revolvers, rifles, and shotguns not classified as NFA items?
- USML Category I (Correct answer)
- USML Category IV
- USML Category XI
- USML Category XV
Correct answer: USML Category I
USML Category I covers non-automatic and semi-automatic firearms up to .50 caliber, including conventional handguns and rifles.
Question 4: An importer wants to bring in Chinese-made semi-automatic pistols. Federal law under 18 U.S.C. § 922(r) primarily restricts this by:
- Requiring a Type 11 FFL for all Chinese firearms
- Prohibiting import of semi-automatic pistols from China regardless of configuration (Correct answer)
- Mandating a minimum barrel length of 6 inches
- Limiting imports to 500 units per calendar year
Correct answer: Prohibiting import of semi-automatic pistols from China regardless of configuration
Presidential Proclamation 6391 (1994) banned the importation of Chinese-made semi-automatic pistols into the United States.
Question 5: The 'country of origin' marking required on imported firearms under 27 CFR § 478.92 must be:
- Printed on the box only
- Engraved or cast on the receiver to a minimum depth of .003 inch (Correct answer)
- Applied with a permanent adhesive label
- Listed only in import documentation, not on the firearm itself
Correct answer: Engraved or cast on the receiver to a minimum depth of .003 inch
Imported firearms must have the country of origin marked on the frame or receiver to a depth of at least .003 inch and in 1/16-inch letters.
Question 6: An end-user certificate (EUC) in the context of ITAR exports is primarily used to:
- Certify the firearm passed US proof testing
- Assure the US government the foreign buyer will not re-export without authorization (Correct answer)
- Establish the FFL's liability cap in case of misuse
- Replace the need for a State Department export license for NATO allies
Correct answer: Assure the US government the foreign buyer will not re-export without authorization
An EUC is a document from the foreign buyer certifying the final use of the exported defense article and commitment against unauthorized re-export.
Question 7: Which export license exception under the EAR allows US persons to temporarily export firearms for personal use while traveling abroad?
- License Exception TMP (Temporary)
- License Exception BAG (Baggage) (Correct answer)
- License Exception GOV (Government)
- No exception exists; a license is always required
Correct answer: License Exception BAG (Baggage)
License Exception BAG permits US persons to take personally owned firearms abroad as personal baggage without a formal export license, subject to quantity limits.
FFL Import & Export Regulations 3
A Type 08 FFL (importer of NFA firearms) wishes to import a foreign-made suppressor.
Which additional approval is required beyond ATF Form 6?