Taking bullets (not ammunition) to Professional Hunter

[Green Chile]

Any issues with taking bullets (not loaded ammo) to the PH in Africa? I would have them in factory boxes in a separate checked bag from the rifles of course. They would be in the bag along with my locked hard case of ammo. Not all of the bullets will match up with my rifles so is this a potential problem?

 

[Hunter-Habib]

I wouldn’t. Which part of Africa are we talking about ? It used to be legal in Namibia, when I last hunted there (Just Bullets).

 

[Green Chile]

South Africa on this trip. No transit through other African countries. In and out through JNB.

 

[Green Chile]

If not advisable, what about shipping from USA to SA...from me directly to the PH?

 

[mdwest]

If you are just talking about bullets/projectiles.. there is no problem taking them out of the US or shipping them directly to SA from the US side of the house (they are not regulated by either DDTC/ITAR or BIS/EAR/DEAR)..

There MAY be issue on the South Africa side (I am not an expert on SA law).. but as I understand it from several South Africans, SA also does not regulate bullets.. there are no import restrictions.. Although if they know you are bringing something into the country with the intent of giving it to someone else, they may want to try to tax that "import" (risk probably worth taking I would guess)...

 

[JMM]

I took 200 bullets for my guide thru Doha and Windhoek. Packed them in my checked luggage and there were no issues.

 

[Ontario Hunter]

Don't worry about it. Last August I flew to Joberg and on to Port Elizabeth with a box of new 458 Lott brass for my PH. No problem and the only gun I was bringing was 30-06. You will need a separate locking ammo case at Joberg. Put the bullets in the case and think about declaring them as gift for your PH so no duty (you will be leaving the bullets there so technically may need to declare them). Can't remember if I declared the brass. Probably not. Probably should have. Wait ... when I arrived at Joberg this last time, I didn't even go through customs. No one was home! But the police station was operational and guns must go through there. They didn't even open the ammo case.

 

[mcd]

If you are just talking about bullets/projectiles.. there is no problem taking them out of the US or shipping them directly to SA from the US side of the house (they are not regulated by either DDTC/ITAR or BIS/EAR/DEAR)..

There MAY be issue on the South Africa side (I am not an expert on SA law).. but as I understand it from several South Africans, SA also does not regulate bullets.. there are no import restrictions.. Although if they know you are bringing something into the country with the intent of giving it to someone else, they may want to try to tax that "import" (risk probably worth taking I would guess)...

Are you sure on the US regulations? I'm pretty sure they fall under the EAR as control items 0A505.x. If I'm wrong, I'd definitely like to understand the regulation better. It's not like US regs are clear, or that they don't conflict and backwards twist on themselves all the time, lol.

 

[MerKuryM8]

If you are just talking about bullets/projectiles.. there is no problem taking them out of the US or shipping them directly to SA from the US side of the house (they are not regulated by either DDTC/ITAR or BIS/EAR/DEAR)..

There MAY be issue on the South Africa side (I am not an expert on SA law).. but as I understand it from several South Africans, SA also does not regulate bullets.. there are no import restrictions.. Although if they know you are bringing something into the country with the intent of giving it to someone else, they may want to try to tax that "import" (risk probably worth taking I would guess)...

I'm not 100% sure on laws, but I wanted to order bullets from Rhino Bullets in SA to Namibia. The Owner suggested sending them via Courier and it seemed like there wouldn't be any extra paperwork or anything (same when I ordered a Silencer from SA)

 

[mdwest]

I think you might be looking at an old copy of the commerce document.. the most current (Feb 2023) is located here:

https://www.bis.doc.gov/index.php/d...ties-equipment-and-miscellaneous-items-1/file

you also have to read pretty much for a page or so in advance and after the mention of whatever it is you are looking for to make sure you have the full context of what they are saying... the commerce document in particular is horrible about stating things like "exceptions are"... a full page prior.. or saying "this was regulated by ITAR previously" completely out of context for what they are saying now...

what you are seeing in the version you are looking at are components to what commerce calls "inherently military munitions".. which are defense articles controlled under ITAR (uranium depleted shells, howitzer rounds, etc..etc..).. so they are saying if youre dealing with a part or component of an ITAR controlled item.. the component if not itself ITAR is controlled by EAR..

They make this slightly more clear in the newest version.. you'll find a similar "note" in the new version.. its Note 1 to 0A505.x in the new version.. where they make the same statement (primers, metallic cartridge cases, etc..).. but 0A505.X clearly states in the new version that what they are talking about is parts or components specifically designed for a commodity that is controlled by ITAR (military munitions)..

Hunting, range plinking, etc type ammo isnt ITAR.. therefore the components are neither ITAR or EAR..

To your point.. the US Regs are inherently difficult to navigate.. they are poorly written.. often contradict.. different agencies are in conflict.. etc..

To make it worse.. we have been going through export reform at the federal level for more than a decade at this point.. every year they make fairly large/sweeping changes.. its become something like trying to keep up with US federal tax code.. what was legal last year is now illegal.. and what was illegal last year is now legal.. what was regulated by ITAR last year is now regulated by Commerce.. what was regulated by Commerce last year is no longer regulated.. and what was not regulated by anyone last year, everyone now wants to regulate..

Even though they just updated the commerce regs less than 60 days ago.. I feel pretty certain they will update them again at least once more before the year is out lol..

 

[mcd]

Thanks for the update! I will definitely dive into that in further detail. I have an extremely vested interest as to why this would be important to me.

 

[Green Chile]

I used to be the importer for GSC bullets in the US but mailing bullets (not ammo) out of the country is new to me. Hopefully I can take them with me in checked luggage but I want to figure it out as A-frames and TSX are not something I want to have confiscated at the port of entry. I see all of these great responses but it doesn't sound definitive to me yet?

 

[Kevin Peacocke]

You can buy just about any brass or bullets in SA, admittedly it comes and goes out of stock so not immediate. Regulations are one tbing, but what happens on tbe ground is another. So is it worth taking the chance when you can just give him the money to buy it himself.

 

[mcd]

Well, it looked promising at first, comparatively speaking to my older document. However, it appears it still wraps this up, if I'm interpreting it correctly, unfortunately.

Here's the first part that encompasses pretty much any firearm, and the above ropes all ammunition components as a part of that it appears.

 

[Berettaco]

I took some 444 brass and some bullets through Joberg - no issues or questions asked. This last trip the airlines made sure my rifles didn’t make my flight so I was stuck using my PHs rifle for a couple days. We stopped at a local gunshop and I bought 4 boxes of 375 ammo as I didn’t want to shoot up all his ammo. While I was there I stumbled across a couple boxes of swift A frame bullets I couldn’t find in the US. I bought those and brought them back to the US with me. Again, no questions or issues. I didn’t look up the regulations tho…

 

[mdwest]

Its very possible they have made a change in the Feb 2023 document that puts bullets/projectiles on the regulated list...

Give me a bit to dig in a little bit.. and if necessary Ive got an attorney that specializes in export controls that I can call (this sort of thing is something Id like to know about for other than just personal reasons).. I'll see if I can get a definitive answer..

 

[Ontario Hunter]

Thanks for posting these regs. I knew that recent US expory regulations had become quite complicated. Turns out that is an understatement. Looks like you would need an export license to take those bullets out of the country. That may not be difficult. I was able to obtain Canadian export licenses for my guns and ammo fairly easily ... even two guns that I PERMANENTLY exported to South Africa when I went hunting. There is a limit on how much loaded ammo a hunter can bring into South Africa but as far as I could determine last year no restriction on components (just declare them and pay duty as applicable like everything else.) It looks like the problem now is getting stuff out of the US just got a lot more complicated. Anyone know how hard is it to get a US export permit/license?

What was interesting to me is that the regs state that exports of gun parts, barrels, bullets, etc. to Canada are exempt from licensing requirements if under $500. Apparently Brownells and others haven't caught onto it yet. They still won't sell anything to anyone with a Canadian credit card.

 

[Ontario Hunter]

Its very possible they have made a change in the Feb 2023 document that puts bullets/projectiles on the regulated list...

Give me a bit to dig in a little bit.. and if necessary Ive got an attorney that specializes in export controls that I can call (this sort of thing is something Id like to know about for other than just personal reasons).. I'll see if I can get a definitive answer..

Thanks for looking into this. I'd be glad to help pay his bill. This Bud's on me. That should cover it, right?

 

[mdwest]

Here's where the rub is going to be...

Whats the intended purpose of the export?

Effective Nov 2022.. Customs says a US Citizen can take up to 1000 rounds of ammo out of the country for personal use (temp export) without a license (clearly the airlines arent going to go for 1000 rounds due to weight, nor is South Africa.. but strictly from a licensing perspective the "export" is allowed without one..

Where the license is coming into play is if you are looking at a permanent export (shipping over with the intent to sell them, gift them, or whatever...)... If thats the case, the US govt wants its piece of the action (there is no export tax.. but they do want their license fee, etc)...

So.. as I am understanding things the way the regulation is written now... if you want to take a couple of boxes of projectiles out of the country (even 10 boxes).. its a non issue.. as long as they are FOR YOU...

If you are taking them out of the country knowing you have no intention of using them or bringing them back.. then you need a license...

Now.. is anyone ever going to ask you "what happened to those 200 projectiles you took out of the country?"... very likely not...

But are you technically violating the law and exposing yourself to the possibility that someone might ask.. it appears to be so...

Its after hours in DC... Ive got to call our law office tomorrow for other matters anyway... I'll try to ask when Im talking to them about this and see if they agree/disagree and what else they have to say about it..

 

[Green Chile]

Thanks for all of the checking on this. I'm also checking with Henry at Rifle Permits.com to see if he has thoughts on bringing some bullets in with checked baggage.