Memorandum by the Home Office
FIREARMS (VARIATION OF FEES) ORDER 2000 (S.I. 2000/3148)
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
Correlation with fees charged for individual firearms
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
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