When do I become an ammo "manufacturer"?

[gnbrotz]

As I've made it known that I've recently been preparing to reload, I've had some inquires from others about selling them ammo and/or reloading their brass.

I DO recognize the serious potential for liability were I to do so. I've asked other reloading friends the same thing in the past, and none were willing to do so (understandably). Most offered to let me use their equipment if I wished.

My question is, (hypothetically) assuming I'm willing to accept the risk and/or would obtain a large liability policy, at what point does the government consider me a "manufacturer" and thus subject to their regulation, licensing, etc.?

[PaBimmerGuy]

if you start manufacturing ammo for others.

[gnbrotz]

if you start manufacturing ammo for others.

Can you be more specific and/or provide a citation? What if I simply give the ammo to someone, or let them shoot a few rounds of my own load while at the range together?

[P89]

http://www.atf.gov/firearms/faq/manu...ammo-reloading

Q: Is a person who reloads ammunition required to be licensed as a manufacturer?
Yes, if the person engages in the business of selling or distributing reloads for the purpose of livelihood and profit. No, if the person reloads only for personal use.

[18 U.S.C. 922(a) (i) and 923(a), 27 CFR 478.41]

[WVBob]

Not for Profit is the issue. If you load for friends and only ask, (ask is the big word), them to pay you for your cost or supply you with components, you can do it on a small scale. But, if any thing goes wrong, anything, somehow it will be your fault. If they miss a deer at 100 yards, it's your fault. If a case splits and gets jammed, it's you fault.

I reload for ME ONLY.

[Xringshooter]

Greg, as shown above you are ok. You can even reload and give them to friends to shoot. It is the intent to sell your reloads and make a profit or to sell them in any business you own that requires you to get the manufacturers license. I reload for my Dad, not very often but I do it. It's probably the liability that I would worry about the most. If you reload for a friend and something goes wrong, your "friend" might just be asking (through a lawyer) for a lot of your money and or possessions.

When someone asks me if I can reload for them and they will pay me, I tell them I don't do that (because of liability) but they are more than welcome to come over with all the components and use my equipment. They are then reloading their rounds themselves and if something goes wrong, they bought the bullets, primers, powder, etc., and they did the act of assembling the reloaded rounds. I suppose that if something went wrong a shyster lawyer could try to pin the blame on you and your equipment, even though you din't actually do the reloading.

[shortthrow50]

Plenty of people reload friends for a small donation. You would seriously have to be pumping out alot of rounds to be in the sights of the authorities.

[*Klutch*]

I reload for me, my brother and my close friend who is a LEO, all 40S&W and a few others for me. I don't make any money on it but we split the cost of everything and it works out nice. My LEO friend uses them for practice before he has to qualify and my brother and I just shoot more when we go to the range.
I think all in all for the ATF to view you as a manufacturer you would have to be making quite a bit of ammo, but by law I guess it's as soon as you turn a profit.

[knight0334]

If you're gonna "manufacture" for a profit, the FFL Type 6 is only $30 per three years.

People who cast their own bullets for sale need that license. So long as you aren't doing it as a business you should be okay. You can load for friends, family, and acquaintances - but if you start charging, then you're in business. They can supply all the materials, but you'd have to supply the labor for free.

[gnbrotz]

Plenty of people reload friends for a small donation. You would seriously have to be pumping out alot of rounds to be in the sights of the authorities.

I'm not interested in whether or not I'm "in the sights of the authorities." I'm worried about whether or not I'm in compliance with federal law.