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Brasilia, December 14, 2022.

RELINT 035/2022.

to the most excellent Lord

JOSÉ MÚCIO MONTEIRO FILHO
Future Minister of Defense

Ref.: Information and regulations - firearms and ammunition.

The National Association of the Arms and Ammunition Industry - ANIAM, in greeting you cordially, through
its President, Salesio Nuhs, comes before Your Excellency to expose and request, as follows.

ANIAM is a non-profit civil entity, founded in 1969, composed of representatives of the national arms and
ammunition industry, with the aim of promoting the development of the defense sector in the country.

Composed of 6 national industries, the sector employs more than 70,000 people, registers annual
revenues of around R$ 13 billion and collects approximately R$ 2.8 billion in taxes per year.

In addition to domestic industries and their suppliers, the weapons and ammunition segment comprises
approximately 3,500 stores, brokers, instructors, psychologists, clubs, technical assistance, authorized
carriers and other service providers.

90% of the Brazilian market is served by national industries.

Its associates, Companhia Brasileira de Cartuchos – CBC and Taurus Armas S/A – Taurus make up the
Defense Industrial Base – BID and are accredited by the Ministry of Defense as Strategic Defense
Companies – EED, in view of the essentiality of these companies to the promotion of Brazilian scientific
and technological development, fundamental for the preservation of security and national defense.

IDB is the set of state or private companies that participate in one or more stages of research,
development, production, distribution and maintenance of strategic defense products - goods and services
that, due to their peculiarities, can contribute to the achievement of objectives related to the security or
defense of the country.

The role of the EED is to ensure the country the operational and technological autonomy necessary for
the competencies assigned to the Armed Forces in favor of national sovereignty, in addition to being an
important engine of economic growth and generator of employment and income, considering its
characteristics of highly qualified personnel, advanced technologies and high effect on other industrial sectors.

National Association of Arms and Ammunition Industry – ANIAM | CNPJ 62.642.046/0001-61

SHN Block 02 Block “E” Kubitschek Plaza Hotel Room 161 Brasília | DF -
CEP: 70322-902
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BID employs 2.9 million people, represents 4.46% of GDP directly and has approximately US$4.5 billion in
ongoing business.

The balance and strengthening of Brazilian defense material industries are conditioned to the existence of
alternative markets to the Armed Forces in order to ensure continuity, scale for competitiveness, and
technological capacity for continuous investments in research, development and innovation. The internal market
for military products, although strategically essential for the BID, with rare exceptions, does not generate orders
capable of making it viable. It is necessary to seek alternatives, which in principle are found in dual investments
and exports, as prescribed by Decree No. 6703, of December 18, 2008, by which the then president-elect Luiz
Inácio Lula da Silva approved the National Defense - END, which is why the civil market is so important for
maintaining the BID.

Thus, in the fulfillment of its institutional mission and on behalf of the arms and ammunition segment, ANIAM,
aiming to clarify and contribute to the regulation of the sector in the country, after listening to industries,
commerce, confederations, institutions and consumers in general, makes the following considerations.

1. SCENARIO

Over the past 4 years, the current Government has issued several rules that have impacted the arms and
ammunition sector.

The main focus of these measures were the so-called CACs, an acronym that represents Collectors, Shooters
and Hunters, registered with the Brazilian Army.

Although important in the historical, sports and fauna control context, access to weapons for these categories
was carried out without due criteria, causing a distortion of purpose and harming the real CACs.

Tiro Esportivo was responsible for Brazil's first Olympic gold medal, won in 1920, in Antwerp, by the athlete
Guilherme Paraense. Until the present day, our country contemplates many athletes and many conquests in
this sport.

The management of invasive animals is also extremely important for the balance of the fauna, as well as
collecting for the maintenance of our history.

However, what we saw was a flood of ordinary citizens claiming CAC registration to gain access to weapons,
including those for restricted use, and be able to carry them under the argument of carrying transit for
displacements.

There was also a widespread release of imported weapons and ammunition, without due control and with tax
incentives. Ammunition is being imported without proper markings, and weapons and ammunition are imported
without being released through computerized control systems, such as SICOVEM and SICOFA.

National Association of Arms and Ammunition Industry – ANIAM | CNPJ 62.642.046/0001-61

SHN Block 02 Block “E” Kubitschek Plaza Hotel Room 161 Brasília | DF -
CEP: 70322-902
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2. NECESSARY MEASURES

2.1. Regulatory agency

Following the example of several countries in Europe and the United States, create a regulatory agency that
takes care of the control of firearms and ammunition. Currently, there is a lack of structure of Organs competent
bodies to manage, administer, control and supervise the segment.

Among the agency's attributions will be the stratification of the categories of gun purchasers, putting an end to
the trivialization carried out with the CAC category. It will also be responsible for establishing the quantities of
weapons and ammunition authorized for each category, creating computerized and online controls, carrying out
the integration between SIGMA and SINARM, establishing the means of inspection, penalties, defining the
procedure and the allocation of weapons seized or in non-compliance with the legislation, in addition to
establishing the deadlines for the entry into force of the new regulations.

The agency will have 6 months to structure itself, create the electronic means for controls and inspection, carry
out the amnesty of weapons in the appropriate categories and structure the collection of weapons that are not
legal.

The agency will be composed of a president appointed by the Presidency of the Republic, in addition to at least
one member of the Ministry of Defense, the Ministry of Justice, an entity representing Brazilian sport and fauna
management, and also the industry that integrates the national entity representing the arms and ammunition
industry – Aniam and the BID.

2.2. Classification of calibers

Maintain the current rule, contained in art. 3 of Decree 10.030/2019, with the wording included by Decree
10.627/2021, which is in line with the classification carried out worldwide. In most countries in the western world,
calibers .38, .357, .380 and 9mm are allowed for civilian use. In terms of projectile diameter, all of these represent
the same caliber, as per the attached document. The different nomenclatures essentially come from market
issues, or where the ammunition was developed. Some use the inch system (.38, .357, .380), others use the
metric system (9mm). Calibers intended for rifles and machine guns continued to be classified as restricted use.

2.3. Import

Return to the previous rule, importation only in exceptional cases and as long as there is no national similar.
Revocation of tax incentives. Ensuring equality between the national and imported product, which today enjoys
tax and regulatory benefits and facilities, to the detriment of the national industry, which, in addition to being
unconstitutional, violates the END, approved by the Government under President Lula.
Re-establish inspection of imported products, making marking mandatory on products and their packaging and
carrying out control through electronic systems (SICOVEM, SICOFA, SIREM, SIP...).

National Association of Arms and Ammunition Industry – ANIAM | CNPJ 62.642.046/0001-61

SHN Block 02 Block “E” Kubitschek Plaza Hotel Room 161 Brasília | DF -
CEP: 70322-902
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2.4. Amnesty

Carry out a new amnesty according to the new classification of acquirers, thus, expired registrations may be renewed,
provided they are in accordance with the new classification. In addition to regularizing the weapons brought to Brazil,
without proper control, so that they can be identified and inspected by the Government, following the example of the
amnesty and re-registration carried out until 2009.

2.5. Validity period of records

Return to the previous rule, for revocation every 5 years, as established in 2016. A shorter period encourages illegality
and overloads the competent bodies.

2.6. Control

Implement a single, online control of all the movement of firearms and ammunition in the country between manufacturers,
specialized stores, institutions, sports organizations and consumers.

Control considering both registrations of weapons in SINARM and SIGMA, according to the authorized quantities of
each category, according to legislation.

Inventory control of entities and commercial establishments and sales made with lashing through registration of the
weapon and CPF number, together.

System under the management of the regulatory agency, which may, at any time, carry out online inquiries of stock,
movement of weapons and ammunition purchased and sold by date, product, volume, etc., for all categories of
purchasers, in addition to the possibility of suspend and cancel CR, which will even allow requesting, in real time,
inspection units to take steps to residences or any other commercial or sports establishment to check stocks and prove
sales launched.

Integrated control of Integrated control of

all channels all channels
sales sales

Documentation verification -
System launch, with
Consumer Sale identification doc Available balance Billing automatic quantity
- CRAFT
check
- CR (if applicable) write-off

Distributor and/or Check product type System launch, with

documentation verification and available Billing automatic quantity
Store Sale
- CR balance write-off
Manufacturer

Sale Entity
Check product type System launch, with
documentation verification and available Billing automatic quantity
sporty
- CR balance write-off

Management of
Institutional Sales authorization Billing system launch distribution to
check
members of corporations

National Association of Arms and Ammunition Industry – ANIAM | CNPJ 62.642.046/0001-61

SHN Block 02 Block “E” Kubitschek Plaza Hotel Room 161 Brasília | DF -
CEP: 70322-902
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2.7. ammo supplies

The circulation of inputs and their stocks must be controlled via the same system as ammunition, with reduced
quantities and allowed only to sport shooters and subsistence and control hunters, according to the classification
suggested below.

2.8. Civil

Restore the previous procedure, excluding the presumption of effective necessity, which, again, now has to be
declared. Acquisition of weapons only for permitted use and with reduced quantity, going from 6 weapons to
up to 4, with the possibility of having only one weapon in each residence, up to a total limit of 4 weapons.
Possession of a weapon, one in each household, aims to prevent the transport and circulation of weapons in
national territory.

2.9. landowner

Establish gun ownership to the extent of your property/residence. Allow the acquisition of weapons in the same
quantity as civilians, in addition to two weapons for restricted use, due to the existing peculiarities required for
the rural area.

2.10. Members of professional categories (military, police, municipal guards, legislative police, Revenue
auditors, ABIN and GSI members, magistrates and prosecutors)

Reduce the current quantities, returning to the previous rule in which they could acquire weapons for permitted
use in the same quantity as civilians, plus two weapons for restricted use, according to the caliber used by the
member in the corporation.

2.11. Institutions

Return to the previous rule, in which, as well as for weapons and ammunition for restricted use, there is also a
need for authorization for the acquisition of weapons and ammunition for permitted use. Change record
competency to Army.

2.12. CAC

Stratify the CAC category according to need, as follows:

ÿ Beginner Sport Shooter (ADI): only permitted weapons.

ÿ Full sport shooter (ADP): for weapons for restricted use, proof is required that the weapon claimed is provided
for in the rules of practice, national or international, of the shooting modality practiced by the acquirer.

National Association of Arms and Ammunition Industry – ANIAM | CNPJ 62.642.046/0001-61

SHN Block 02 Block “E” Kubitschek Plaza Hotel Room 161 Brasília | DF -
CEP: 70322-902
Machine Translated by Google

ÿ High-performance sports shooter (ADA): equal to the advanced, with the amount of weapons and ammunition
adequate to the training needs.

ÿ Subsistence hunter (CS): maintain current rule that was established by the Government of the President
elected.

ÿ Hunter Control (CC): Restricted use weapons only if suitable for slaughtering animals
authorized and as long as it is registered with IBAMA.

ÿ Collector (CO): The circulation of arms and ammunition is prohibited, except for exhibition duly authorized
by the regulatory agency.

Revoke the transit permit and establish that the circulation of weapons in the collection must be carried out
without ammunition. The shooter and the hunter may apply for a transit permit for only one firearm to protect
the collection, provided that all requirements are met and previously authorized by the competent body.

Thus, these are the measures that we deem necessary for the real control of weapons and ammunition in our
country, as well as for the maintenance of the BID, responsible for the generation of jobs, taxes, foreign
exchange and for the Brazilian scientific and technological development, fundamental for the preservation of
national security and defense.

We therefore make ourselves available to provide any additional elements and clarifications on the subject
addressed in this correspondence.

Certain of Your Excellency's understanding, we take the opportunity to reiterate our wishes of esteem and
consideration.

Yours sincerely,

Salesio Nuhs
President

National Association of Arms and Ammunition Industry – ANIAM | CNPJ 62.642.046/0001-61

SHN Block 02 Block “E” Kubitschek Plaza Hotel Room 161 Brasília | DF -
CEP: 70322-902