This is an area where speculation is dangerous. Primers may fall under the International Traffic In Arms regulations administered by the State Department or their regulation may have transferred to the Department of Commerce under the recent rule change. In either case, their commerce is regulated.
Exactly correct. ITAR is a bitch, but this should answer his questions. Also, primers are considered an explosive and that falls under ITAR.
WHAT ABOUT PARTS AND COMPONENTS?
Parts and components is a very important concept. In many cases if an item is on the Munitions List, parts and components that are specially designed for that item are also on the list and subject to ITAR. I’ll repeat that –
If an end item is on the Munitions List, in many cases parts and components that are specially designed for that item are also on the list and subject to ITAR. Also, in some cases if the end item is on the list, the parts and components may be listed on the Commerce Control List and regulated under the Export Administration Regulations instead.
Update
Primers would fall into either category 3 or category 5 of the munitions list.
Category I: Firearms, Close Assault Weapons and Combat Shotguns
Category II: Materials, Chemicals, Microorganisms, and Toxins
Category III: Ammunition/Ordnance
Category IV: Launch Vehicles, Guided Missiles, Ballistic Missiles, Rockets, Torpedoes, Bombs and Mines
Category V: Explosives and Energetic Materials, Propellants, Incendiary Agents and Their Constituents
Category VI: Vessels of War and Special Naval Equipment
Category VII: Tanks and Military Vehicles
Category VIII: Aircraft and Associated Equipment
Category IX: Military Training Equipment
Category X: Protective Personnel Equipment
Category XI: Military Electronics
Category XII: Fire Control, Range Finder, Optical and Guidance and Control Equipment
Category XIII: Auxiliary Military Equipment
Category XIV: Toxicological Agents, Including Chemical Agents, Biological Agents, and Associated Equipment
Category XV: Spacecraft Systems and Associated Equipment
Category XVI: Nuclear Weapons, Design and Testing Related Items
Category XVII: Classified Articles, Technical Data and Defense Services Not Otherwise Enumerated
Category XVIII: Directed Energy Weapons
Category XX: Submersible Vessels, Oceanographic and Associated Equipment