Make a Comment on New Firearm Export Regulations of the U.S. Commerce Department!

Deadline for submitting comments is Monday, July 1 at midnight Eastern

How to make a comment

  1. From your digital device copy the model comment below the following Background information.
  2. Go to the Public Comment page on:
  3. Paste the model comment below. Add your own comments if you want.
  4. Fill out the other information in the comment form, including your email address, whether you are commenting as an individual, organization, or anonymously, and click the button agreeing that the comment can be posted on the web, then click the Submit Comment button.


On April 26, the U.S. Commerce Department published an “Interim Final Rule” on gun exports under its jurisdiction, and invited members of the public to submit comments until July 1st. While the new rule makes several positive changes, it doesn’t curb some of the worst parts of U.S. gun exports, including exports to human rights violators – from Mexico to Israel -, the export of destructive weapons such as assault rifles, nor does it put an upper limit on the number of weapons exported to any one country. 

Yet the gun industry and its allies in Congress are already attacking the rule for the selective limits it places on weapons exports. Your comment is critical to ensuring that policy-makers hear from people who want to prevent gun violence both within and beyond U.S. borders.

The United States exports more guns to more countries in the world than any other, and the flow of weapons is growing. Since Donald Trump moved oversight of gun exports from the State Department to the Commerce Department in 2020, the volume of pistol exports to Latin America has grown by 81%, while violence and the press of people seeking asylum has grown. 

The export rule lists non-binding criteria for all U.S. gun export licenses, but focuses primarily on weapons exports to non-governmental end users. The State and Commerce Departments analyzed the risk of theft and diversion of exported guns, but did not focus on risks of human rights abuses, which led them to address mostly exports to nongovernmental end users.

Model Comment – please adapt this comment, with your own name, city, and any additional comments you wish to make. 

To whom it concerns:

I am writing in response to the Interim Final Rule on firearm exports published by the Department of Commerce on April 26. I support provisions of the rule, but strongly urge the Department to strengthen it in several ways to prevent U.S. weapons from being used to further violence and human rights violations.

I support the following provisions of the Interim Final Rule:

  • Reduction of firearm export licenses from four years to one year. Longer licenses risk putting weapons exports on automatic pilot, with less attention to changing circumstances or the consequences of prior exports. 
  • A “presumption of denial” of licenses for export to non-governmental end users to certain countries. This will have positive effects in countries like Guatemala (where the United States has exported an alarming increase of weapons in recent years) and other Central American countries.
  • Subjecting all firearms exports to the Commerce Department’s procedures for crime control items, which will provide needed additional scrutiny in the license review process when the importing country has a record of human rights abuses or civil disorder.
  • Creating new export classifications to differentiate between semi-automatic and non-semi-automatic weapons to better enable the Department of Commerce to track exports and evaluate the risk of diversion of specific weapons.

However, the rule does not address a number of ways that U.S. weapons exports are contributing to violence around the world. I am especially concerned that the State Department’s guidance, which shapes the rule, analyzed the risk of theft and diversion of exported guns, but did not focus on risks of human rights abuses, which led the rule to address mostly exports to nongovernmental end users. I strongly urge you to strengthen the rule in the following ways:

  • The Commerce Department should adopt policy that draws clear and binding red lines against exporting weapons to military and police end users implicated in human rights abuses, collusion with criminal groups or other violence. This should include using criteria for firearms exports that are at least as restrictive as those for U.S. assistance to military and police forces, known as the Leahy Law. 
  • The “presumption of denial” of exports to non-governmental end users should be extended to countries where U.S. companies have exported enormous quantities of firearms used in devastating violence, including Israel, Thailand, the Philippines, and Mexico. 
  • The rule should specify consequences, including denying a license, when firearms export license applications and purchase orders for firearms do not specify the identity of the weapons’ end users. 
  • The rule should cap the volume of weapons to civilian buyers, to prevent these lethal exports with a long shelf life from increasing violence during years to come.
  • The rule should specify a presumption of denial of export licenses for especially dangerous weapons to non-governmental users, such as assault weapons and .50 caliber rifles. The President has rightfully called for prohibiting the sale of these weapons of war and mass shootings within the United States; our country should not be exporting them to other countries. 
  • The rule should explicitly commit the Commerce Department to annually publishing firearms export data, including the number of licenses and firearms, dollar value and license duration for each country, whether the end users are government forces, private companies or individuals, and for each export category of weapon.

These measures are important for ensuring the Rule meets the goals of reducing the use of U.S. exported weapons in violence and human rights violations around the world.