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Joint Committee on Statutory Instruments Third Report


Memorandum by the Home Office


1. This memorandum is submitted in response to the following request from the Joint Committee on Statutory Instruments dated 14 December 2000:

    "Explain the reason for the increase from £50 to £150 in the fee for a new certificate of registration as a firearms dealer under section 35(3) of the Firearms Act 1968"

Full Cost Recovery

2. In setting fees for firearms licensing, successive Governments have sought to operate on a basis of 'full cost recovery' for the services concerned.

Variations in costs of inspections

3. The police are responsible for the inspection of the premises and paperwork of businesses applying for registration as registered firearms dealers. While the 'ordinary' dealer is often a small high street gunshop, the size and value of the businesses seeking registration can vary dramatically. Registered dealers may range from part-time dealers in specialist or vintage firearms to large defence manufacturers and substantial factories and warehouses. Accordingly the duration and cost of inspections of such businesses show correspondingly wide variations. All dealers are obliged to keep records of their transactions for inspection purposes. Inspection of large-scale operators with a considerable volume of trade can accordingly be very time-consuming.

The average costs of inspection

4. The fees charged for registration and renewal of registered firearms dealers are based on the average cost applicable to an ordinary shopkeeper. As with any average figure, it is accepted that the fee may not reflect the true costs to the police of dealing with very large or very small dealerships, but it does represent a logical and rational basis for the figure of £150.


5. The previous fee levels for registration and renewals were set on the assumption that it would be the initial registration of a dealer that would consume the largest part of police time. At this stage it would be necessary to inspect the security measures which would operate at the premises and to check the background and character of the applicant. In contrast the processing of a renewal application would require less police time, justifying a considerably lower fee. An inspection of the premises would usually take place, but providing that the dealer had not come to the adverse attention of the police over three years, the police investigation of his business and records would be limited.

6. Following the tragic events at Dunblane, the police have sought to review their procedures for firearms licensing. A registered firearms dealer is not obliged to obtain police permission to buy and sell each firearm or batch of ammunition, so the scope for a dishonest dealer to obtain considerable quantities of arms and divert them to the criminal market is considerable. The police have therefore sought to take a more rigorous approach to the renewal inspections of firearms dealers and their records of transactions. In certain cases the burden on the police has in fact increased from initial registration to subsequent renewals since the records of transactions and the resultant scope for malpractice becomes more substantial as the volume of trade increases. In those cases where a decision on renewal can be made without extensive re-inspection there will have been regular contact with the dealers over the three-year life of the certificate. The police time consumed by this process has also been taken into account in attempting to reach the average cost figure by which the appropriate fee level is determined.

Correlation with fees charged for individual firearms certificates

7. The average cost of inspecting and processing an application from a firearms dealer is significantly higher than the cost incurred in dealing with applications for individual firearms certificates. It may take a day or more of a police officer's time to inspect the premises, stock and records of a high street gunshop, while the relevant process relating to an individual may take only a couple of hours. The disparity between the fees for individual and dealer renewals reflects this greater workload and the additional administrative burdens incurred in inspecting dealers.


8. In setting this fee the Department has consulted parties within the trade who will be affected by the increase, including the Gun Trade Association. The Department is satisfied following these consultations that the proposed fee is not unrealistic for the work done and that it does not place an unreasonable burden on the businesses concerned.

19 December 2000

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