Law pertaining to the manufacture of airguns question

The legal aspects of owning, shooting, importing arms/ ammo and other related legal aspects as well as any other legal queries. Please note: This INCLUDES all arms licensing issues/ queries!
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Re: Law pertaining to the manufacture of airguns question

Post by Sujay » Sun Apr 15, 2007 10:34 am

Art Collector,

It is not necessary that what I write is an absolute truth and I am myself ready to be corrected. You are always welcome to furnish alternate views / information.

Till the early 60's ( 1962 to be precise) Airguns were treated on par with Arms and Ammunition and the licencing procedure for both was similar. As per the latest Industrial Policy, only 6 specified cases require Industrial Licencing

The problem here is that Airgun is not specifically included in the list eligible for automatic FDI and it is classified under Chapter 93 ( Arms & Ammo) with sub classification 93040000. Consequently it is getting sweeped under Arms & Ammo. No dept has bothered to clarify the separate clause applicable to sub classification 93040000 :!:
Last edited by Sujay on Sun Apr 15, 2007 12:21 pm, edited 1 time in total.
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Re: Law pertaining to the manufacture of airguns question

Post by art_collector » Sun Apr 15, 2007 12:21 pm

Sujay.......thats ok we both learn from each others views and knowledge...thats the fun of being here ......on the forum....learning costs u nothing ..

AC

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Post by eljefe » Sun Apr 15, 2007 5:04 pm

All of us too, guys.Good info, keep on posting!
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Re: Law pertaining to the manufacture of airguns question

Post by penpusher » Sun Apr 15, 2007 5:38 pm

The joker in the pack is going to be the Minsitry of Home.I might also add that machinery to manufacture firearms requires to be licensed.The issuing authority again being the Ministry of Home.

penpusher

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Re: Law pertaining to the manufacture of airguns question

Post by Filarms » Wed Apr 25, 2007 12:05 am

mehulkamdar";p="16570 wrote:This is to revive a proposal that I had some time ago and discussed with some good friends on this forum though offline. I guess penpusher would be the best person to answer this series of questions though there may be others who may have some info as well...

1. What is the law pertaining to units manufacturing airguns in India? I am interested in knowing about licensing, tech transfer regulations and custom duty regulations for the import of capital equipment

2. Is technology transfer permitted in this field? Specifically if I have a EUropean manufacturer willing to offer technology for a royalty. Or, would it be permissible only if I also had a re-export provision for some of the production in payment for tech transfer?

3. What would be the rules pertaining to the import of some raw materials especially silicon steel springs, specialty washers etc? I am estimating that value would be to the tune of 70% over raw material costs though the addition may be even greater

4. As a Non Resident Indian (holder of an Indian passport living with a Green Card in the USA) can I run such a company with the association of partners based in India? My role would be to arrange financing and tech transfer from outside India. Also, would I be allowed to repatriate the loans/investment in the unit in India over time? To be honest, this is the part that frightens me the most

5. The technical tie up would be with one of the most reputable companies in the business and they have assured that they would help in every way as consultants to set the plant up and run it with quality control support in the future

If the possibilities are positive, then I just might hire some consultant to do a study on such a project in India though I am worried that they would not have the hard data on something like this as there is virtually no known collaboration of this kind. Only one Indian automobile manufacturer makes air rifles for a UK company on contract basis though they do not sell any in India. My proposal would have an Indian focus with the initial production targeted towards the 10 m match sports.

I would appreciate a response and suggestions on this. As this is likely to be a fairly big project in terms of investment and subsequent work and as I am not an airgunner - I don't even have an airgun - I would like to know what airgunning regulars think about this.

Cheers!
Greetings, I'm sorry to intrude on this discussion as I ran across the forum in my internet forays on airguns. I thought I might be able to give 2 cents worth of input because I am currently doing the same exact thing, albeit in the Philippines, where I believe we have similar (if not stricter) laws. I am based in the USA and 2 years ago undertook an airgun manufacturing business in the Philippines. I've learned a lot since then. I hope you can excuse a decently long entry as I try to share what we've learned in the hopes that you can glean some first hand information from those who've gone the route you are trying now.

First of all, I believe you may be blowing a lot of hard money on something that is completely unneccessary, and that is spending for european royalties. I do understand that there are great airguns to be found in europe (I own a few myself), but they are also made with incredibly expensive equipment (CNC machines, CNC Lathes, etc). To get designs from them would mean having to also invest a LOT in similar set ups and that is just not going to work out for an entry level airgun builder (unless you have cash to burn and time to wait for ROI). CNC machining is great for mass production but they are expensive to maintain and operate.

While my partners and I are avid airgunners with extensive backgrounds in hunting and competition (silhouette), and had a good knowledge of airgun construction, we also had no idea how to manufacture airguns, and believe me when I say the learning curve is pretty steep. We first tried to buy an existing airgun manufacturing outfit that was illegal (underground and unpermitted) in the hopes of getting it legitimized with the govt. When that didn't work out, we then decided to start from the ground up. That turned out to be a blessing, since we were able to acquire equiptment that was more in line with what we wanted to make. We then took it upon ourselves to design an airgun that was appealing to our local market (with enough similarities to what was currently offered) but infused with the technology that I was exposed to in the US. One of the most crucial things we had to do was design a simple, yet efficient airgun that was easy to make, operate, and fix. We were after all offering it to a third world country and most would not have access to high end repair facilities/parts. Also the fact that we were offering it for local consumption meant that we had to make it cheap and affordable. It took a lot of research and testing but our final product turned out to be something we are quite proud of. We actually have americans clamoring for them, and we're just waiting for our first shipment of export airguns to arrive in the USA.

After the right design, the next most important thing is manpower. Airguns, no matter how simple, are precision products. If you are happy with entry level c02 airguns, then you can afford some tolerance issues, but when delving into PCP (like we do), there are tolarances in its construction that cannot be compromised. Valves, ports, springs, and hammer weights are all very tolerance sensitive, with any slight deviation resulting in major accuracy and velocity changes. You must not skimp on the quality of your manpower, and only skilled machinists (milling machine and lathe operators) should tackle the precision internal work. Also, PCP pressures are no joke, with most PCP airguns operating at around 3200psi or 200 bar (co2 pressures are roughly around 800-1000psi, depending on the weather). Considering an automobile's tire is around 32 psi (and we've all seen an explosive tire blow out I'm sure, hehe), these pressures are nothing to joke about. Quality materials and careful construction is a must. We source all our aluminum/steel reservoir materials from the US. These are just things we cannot skimp on, as we risk lives and limbs in an accidental reservoir failure. Another issue we encountered was the availability of hardwood for our stocks. What I thought was not going to be a problem turned out to be quite a head ache as good quality wood is becoming scarce in our region. Barrels too are something to be considered, as good barrel making is becoming more and more a lost art form. The accuracy of your airgun is found mostly in its barrel (the other factor being its ability to deliver a consistent amount of air per shot), and without a good barrel, prepare to be happy with average to middling accuracy. We make our own brass barrels, since we dont have the machinery to work hard steel. We also import precision made steel barrels from manufacturers in the US and Germany.

With all that said, I do wish you well with the venture. There are different kinds of airguns for different kinds of cultures, esp in Asia. The koreans for example LOVE power, and it shows in their Shin Sung Careers and Sumatras. Us filipinos are more utility oriented, but we love to upgrade and "hop up". Before we came into the market with our precision PCP's, there were a lot of c02 airguns that were modified to produce higher velocities and better accuracy. Airgunners are a distinct breed, the kind that eschews the power of powderburners for the precision and accuracy of the tiny airgun pellet. I'd suggest you study the market well, and see what the average airgunner in India wants in an airgun. It would be good to move in the direction that best satisfies them, as they will be your end market. I believe that with a little ingenuity and research, you can come up with your own designs that are better suited for your market. If you need a little more help and advice, feel free to contact me. We always welcome new blood in the sport. You can see what we make over in our update site at http://filarms.blogspot.com , I believe they speak for themselves. Good luck!

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Post by mundaire » Wed Apr 25, 2007 12:40 am

Filarms,

An excellent first post indeed! Made very interesting reading :) Hope to see more like this from you...

Cheers!
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Post by Sakobav » Wed Apr 25, 2007 5:33 am

Filarms

Great post and lot of information. Looking forward to more posts from you

Cheers

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Re: Law pertaining to the manufacture of airguns question

Post by art_collector » Wed Apr 25, 2007 8:17 am

Great post, informative and should be helpful to many.

Many persons I know manufacture air guns in Kolkatta . Its a closed group who dosent share information , dosent welcome outsiders opinions (there might be exceptions which I wud exclude)

This post explained some of the most basic ground realities. It shud be extremely helpful to anyone who wants to manufacture / or is already manufacturing air guns.

AC

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Re: Law pertaining to the manufacture of airguns question

Post by The Doc » Wed Apr 25, 2007 9:03 am

Filarms,

Great post. I indeed took a look ( rather briefly) at your web site and boy I love the stuff you produce. Looks incredible. Now tell me do you make spring loaded air rifles too? Do you make air pistols? Whats the price ?

Thanks,

RP.

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Post by Filarms » Wed Apr 25, 2007 9:42 am

ORTHOPOD";p="18676 wrote: Filarms,

Great post. I indeed took a look ( rather briefly) at your web site and boy I love the stuff you produce. Looks incredible. Now tell me do you make spring loaded air rifles too? Do you make air pistols? Whats the price ?

Thanks,

RP.
RP,

We don't make spring guns. We are strictly PCP, since we started out in that direction, and we do think that it's the direction airguns are taking. It is equally self contained (with a pump) and easier to shoot accurately. We do make air pistols but they're the same price as our air rifles. They take the same effort to make. Our US price is $550. That reflects the shipping to the US tho. In the philippines, the price is roughly $400.

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Post by badshah0522 » Wed Apr 25, 2007 9:46 am

Welcome Filarms !!!!!!1

Good information dude.
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Re: Law pertaining to the manufacture of airguns question

Post by Sujay » Wed Apr 25, 2007 10:39 am

Thanks for the post Filarms.

Would you export to India ?
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Re: Law pertaining to the manufacture of airguns question

Post by mehulkamdar » Thu Apr 26, 2007 3:33 am

Filarms,

Thanks for the post and for your blog which I am going through as I type this. As the originator of this post, and the person who has a party willing to finance this, I appreciate your detailed response. If you think it is OK, I would like to call you sometime when you are free to discuss this. In the meantime, there are some uniquely Indian details which I shall post below. Please respond to them when you have time so that all our members may benefit from your response. I would also appreciate our members posting here with their views on this proposal:

1. India does not have a power limit described in terms of fps velocity or fpe energy but there is a penetration factor that ahs to be adhered to. Hence we shall not be able to produce high powered air rifles there

2. There are already several low priced spring piston air rifles being manufactured in India, and one brand, National, is fairly well regarded for it's price over there. I am looking at something of higher quality, for the booming target shooting market, especially 10 m match work. The financial proposal was an offer to tie up with a European manufacturer of match air rifles and pistols

3. There are several Automobile components manufacturers in South India who have advanced CNC equipment with spare capacities available for some work. That said, the project that I was referring to had a financial component for the equipment to be supplied from Europe

4. India is a very brand conscious market - I might be one of a tiny minority who would prefer to buy a custom made shirt instead of a branded one, but in a business venture, it would be impossible for me to sell something, good though it may be, without a brand to flaunt. Hence the European collaboration route. I would be happiest to be corrected on this specific point and be found wrong, but am not sure that that would happen

5. Specifically talking about barrels, I am a friend of Ernie Stalman of Badger Barrels in Wisconsin though, at the moment, all major US barrelmakers have their order books full with orders from the military. That said, the proposal offered was for the barrels to be made in house as well

6. With companies like Corus in the UK and Inland Steels in the US owned by Indian businesses, I do think that we would have a source of quality steels, though, again, the proposal itself has room for sourcing these from Europe

I would appreciate any further advice that you could offer as well as any more feedback we could get from our members - theya re airgunners while I am only a powder burner.

Cheers!

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Re: Law pertaining to the manufacture of airguns question

Post by Filarms » Thu Apr 26, 2007 9:12 am

mehulkamdar";p="18769 wrote:Filarms,

Thanks for the post and for your blog which I am going through as I type this. As the originator of this post, and the person who has a party willing to finance this, I appreciate your detailed response. If you think it is OK, I would like to call you sometime when you are free to discuss this. In the meantime, there are some uniquely Indian details which I shall post below. Please respond to them when you have time so that all our members may benefit from your response. I would also appreciate our members posting here with their views on this proposal:

1. India does not have a power limit described in terms of fps velocity or fpe energy but there is a penetration factor that ahs to be adhered to. Hence we shall not be able to produce high powered air rifles there

2. There are already several low priced spring piston air rifles being manufactured in India, and one brand, National, is fairly well regarded for it's price over there. I am looking at something of higher quality, for the booming target shooting market, especially 10 m match work. The financial proposal was an offer to tie up with a European manufacturer of match air rifles and pistols

3. There are several Automobile components manufacturers in South India who have advanced CNC equipment with spare capacities available for some work. That said, the project that I was referring to had a financial component for the equipment to be supplied from Europe

4. India is a very brand conscious market - I might be one of a tiny minority who would prefer to buy a custom made shirt instead of a branded one, but in a business venture, it would be impossible for me to sell something, good though it may be, without a brand to flaunt. Hence the European collaboration route. I would be happiest to be corrected on this specific point and be found wrong, but am not sure that that would happen

5. Specifically talking about barrels, I am a friend of Ernie Stalman of Badger Barrels in Wisconsin though, at the moment, all major US barrelmakers have their order books full with orders from the military. That said, the proposal offered was for the barrels to be made in house as well

6. With companies like Corus in the UK and Inland Steels in the US owned by Indian businesses, I do think that we would have a source of quality steels, though, again, the proposal itself has room for sourcing these from Europe

I would appreciate any further advice that you could offer as well as any more **** we could get from our members - theya re airgunners while I am only a powder burner.

Cheers!
mehulkamdar,

You may call or email me, of course. Just give me a heads up and let me know when you're calling. Let me try and cover the questions you posed here to the best of my abilities. Here goes...

1. India does not have a power limit described in terms of fps velocity or fpe energy but there is a penetration factor that ahs to be adhered to. Hence we shall not be able to produce high powered air rifles there.


The Philippines has a penetration test as well. It is widely regarded as an extremely short sighted and badly thought out law. In short, ours states that an airgun that can penetrate a 1/4 inch sheet of plywood at 10 feet will be considered a firearm and be subject to firearm regulation. That law doesn't stipulate what kind of plywood, what kind of pellet, and what angle. no matter how you look at it, a penetration test will involve power (measured in foot lbs of energy - FPE, derived from an eqution involving the velocity and projectile weight). I'd like some input from others here on how powerful their air rifles are and how they are adhering to the limit/requirement. I've read of some who ordered their airguns from the UK and the US, and those are generally pretty powerful. In any case, power is something important that you will have to determine. 10M competition airguns ideally need at least about 550-650 fps. In hunting, weak air rifles will just cause undue suffering in animals that aren't effectively put down with the first shot. In the Philippines, almost ALL airguns being produced will fail this penetration test. It is commonly ignored and I have actually yet to hear about an airgun being subjected to it.

2. There are already several low priced spring piston air rifles being manufactured in India, and one brand, National, is fairly well regarded for it's price over there. I am looking at something of higher quality, for the booming target shooting market, especially 10 m match work. The financial proposal was an offer to tie up with a European manufacturer of match air rifles and pistols.

I would really do a bit of research on your target market. Their tastes and needs will define the direction you will want to go. Things to consider would be whether spring piston airguns is what will sell the best, or if you decide to go with PCP or C02, on whether there is adequate access to supplies of either power source. That brings me to another related point. Our entry into the PCP business brought about a secondary market for us, and that is for the accessories required to refill PCP airguns. We also make the pumps to fill them, but now import carbon fiber cylinders (which are quite expensive) because we saw the increased demand for them that nobody was filling. It became another source of income, not to mention it was a great way to support the PCP airgun shooters in general. Carbon fiber cylinders have to refilled by a special compressor, usually found in Scuba shops. They cost about $3500 - $4000 new, but scuba shops who have that compressor will fill a carbon fiber cylinder for about $5.

See, in our market, we already knew there was a big c02 airgun user base. There are also a couple of underground PCP manufacturers, one of which was quite popular. But we felt the market could support another PCP manufacturer who niched itself above the rest, and so went in that direction. We are now the best known airgun brand in the country, after our 1st year in business. That was after we had to sell the general public (most of whom only knew about c02) on the virtues of PCP airguns. We did that by delivering a quality, accurate airgun, at a good price.

What I'm saying is, if you REALLY want to make spring piston airguns, then you truly may need to tie up with a european manufacturer, they do make the best of those. If you're asking for my opinion tho, I feel that would be uneccessary, as we see airguns going in the direction of PCP. I would instead invest my money in developing a new product to offer your market, like a PCP that can compete with the best the euros have to offer. Make it, and support it. I would think airgunners in general would embrace it, since they probably read all about them. I would rather import spring piston guns from europe or china (who make excellent ones btw). If you have the capital to import them in bulk, they'd no doubt still be profitable. In our case, we concentrated on ONE thing, PCP. For c02 airguns, we decided to buy the rather excellent QB-78 from china and imported those instead. That allows us to focus our resources on delivering one very good product, instead of spreading ourselves thin trying to make everything.


3. There are several Automobile components manufacturers in South India who have advanced CNC equipment with spare capacities available for some work. That said, the project that I was referring to had a financial component for the equipment to be supplied from Europe.


CNC machining is very useful in airgun manufacturing. That's all I can say. Our shop is steadily going in that direction and we're investing in our CNC machines little by little. One Vertical Milling CNC machine can make in 2 days what usually takes us 30 days to build on non-cnc machines.

4. India is a very brand conscious market - I might be one of a tiny minority who would prefer to buy a custom made shirt instead of a branded one, but in a business venture, it would be impossible for me to sell something, good though it may be, without a brand to flaunt. Hence the European collaboration route. I would be happiest to be corrected on this specific point and be found wrong, but am not sure that that would happen .


Hehe, this one I can relate to. Filipinos are extremely brand conscious as well. The thing is, because of the scarcity of "branded" (euro/american imports) airguns in the Philippines, filipino airgunners have learned to see VALUE instead. A quality product will speak for itself. Of course, maybe for you the way to that quality product is to have a joint venture with a euro manufacturer. I cannot predict your future line of airguns, and I am completely ignorant about your airgun market in India, so I don't know what to tell you. All I can say is, if the koreans can do it, the chinese can do it, and the filipinos can do it, I don't see why you can't make a quality airgun that can compete. While it may have been nice for us to be able to say that our airguns were jointly designed by Theoben or Weihrauch, there was no way we can afford the royalties. We had to do it on our own and with a lot of hard work and testing came up with a PCP airgun that can equal the euros in accuracy and performance. I also think I've mentioned that what might work for european tastes might not exactly be good for your market. Their airguns are huge complicated machines, with complex trigger assemblies that were partially designed by litigation lawyers hehe. Us asians don't really benefit from that, as a simpler made but just as good (performance wise) airgun might be better, for practical and economical reasons.

5. Specifically talking about barrels, I am a friend of Ernie Stalman of Badger Barrels in Wisconsin though, at the moment, all major US barrelmakers have their order books full with orders from the military. That said, the proposal offered was for the barrels to be made in house as well.

You will want to look into Lothar Walther barrels. That's where we source our premium barrels. Their USA branch is based in georgia. They make airgun specialized barrels and will make it to spec for you. As far as I know, they are not overbooked. Airguns barrels have different groove/land dimensions as well as different actual caliber dimensions from similar caliber powderburners. Some airgun barrels are also "choked" near the muzzle. Lothar Walther supplies barrels to most major airgun manufacturers, from FX to Logun, and I believe Theoben as well. I can give you their contact details if you need it.

I hope I've covered that well enough for you. I don't know what the euro proposal entails, but I do believe that no matter what it is, it can only be good for indian airgunners, so I will not lead you away from that. Offering a better airgun for a good price is ALWAYS a good thing, as it brings the sport forward as a whole.

I can only offer advice gained from experience from someone who's done almost exactly what you are planning. Please do your homework and due diligence, as that will help you avoid costly misteps. You are after all going into this to make a profit. Perhaps a trip to India and spending some time with airgunner associations and the like.

You may email me at [email protected] and let me know when you're calling.

Good luck!

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Re: Law pertaining to the manufacture of airguns question

Post by Filarms » Thu Apr 26, 2007 9:13 am

Sujay";p="18688 wrote:Thanks for the post Filarms.

Would you export to India ?
Sujay, I really don't know, we haven't looked into it. We have had a couple of queries who people in india who were interested, but they didn't end up ordering.

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