LEGAL
Prohibited Items Policy
This documents outlines the items that can be manufactured and the items that fall under dual-use or restricted categories.
Last updated: 2025-Nov-14

1. Definitions

1.1 Platform

"Platform" means the make.direct manufacturing platform, including all related websites, interfaces, communication systems and ordering processes through which Clients may submit manufacturing requests.

1.2 Platform Operator

"Platform Operator" means SIA Strix Studios, a limited liability company registered in the Republic of Latvia, European Union, acting as the owner and operator of the Platform.

1.3 Client

"Client" means any natural or legal person submitting, initiating or attempting to submit a manufacturing order through the Platform.

1.4 Weapons and Weapon Parts

"Weapons and Weapon Parts" means any item, object, component, or assembly that is classified as a weapon or an essential weapon component under the laws of the European Union, Latvia, or any other jurisdiction relevant to the order. This includes, without limitation: firearm parts or subassemblies; receivers, slides, triggers, barrels, locking mechanisms; suppressor components; ammunition components; explosive or pyrotechnic components; parts of rockets or missiles; weapon accessories; and any item designed, adapted or reasonably capable of functioning as a weapon or substantially contributing to a weapon's operation, concealment, modification or lethality.

1.5 Dual-Use Items

"Dual-Use Items" means goods, components, software, technical drawings or files that may reasonably have both civilian and military applications, or that may contribute to the development, production, operation or enhancement of weapons, surveillance systems, encryption systems or military technologies. This includes all items listed in Annex I of Regulation (EU) 2021/821 (Dual-Use Regulation) and any additional items that, in the judgement of the Platform Operator, present a material security, military or misuse risk.

1.6 Applicable Regulations

"Regulations" include, without limitation:

  • Regulation (EU) 2021/821 (Dual-Use Regulation);
  • Regulation (EU) 2025/41 concerning the import, export and transit of firearms;
  • Directive (EU) 2021/555 on the acquisition and possession of firearms;
  • Council Common Position 2008/944/CFSP on the control of military exports;
  • EU sanctions legislation, including restrictive measures applicable to Russia, Belarus, Iran and other jurisdictions;
  • United Nations sanctions;
  • Comparable foreign regulations such as the United States ITAR, EAR, and the Undetectable Firearms Act;
  • Any other law that may become applicable due to the nature of the item, the Client's location, the intended end-user, or the detected risk profile.

The Platform Operator may apply or rely on any such laws, even if they originate outside the Client's jurisdiction, where necessary for compliance or risk mitigation.

1.7 Sanctioned and Politically Affected Persons

"Sanctioned and Politically Affected Persons" means any natural or legal person subject to sanctions or restrictive measures under EU law, Latvian national law, UN Security Council resolutions, OFAC sanctions, or comparable foreign sanctions regimes. This includes entities or individuals associated with military, paramilitary, insurgent, extremist or destabilising activities, as well as persons acting on their behalf, including proxies, intermediaries or shell entities.

2. General Conditions

2.1 Prohibited Orders

The Platform Operator will not manufacture, process or otherwise handle any order involving Weapons, Weapon Parts, Dual-Use Items, prohibited military components, items destined for sanctioned jurisdictions, or items that raise reasonable suspicion of unlawful, harmful, military or destabilising intent.

2.2 Discretion of the Platform Operator

The Platform Operator reserves the unilateral, exclusive and final right to determine whether any submitted model, file, communication or order constitutes a prohibited item or unacceptable risk. This determination may be based on the file's design, context, intended use, external information, pattern analysis, or any risk indicators deemed relevant.

2.3 Client Obligations

Upon request, the Client must provide complete, accurate and verifiable information regarding:

  • the nature and purpose of the requested design;
  • its origin and authorship;
  • the intended use of the manufactured item;
  • the identity and jurisdiction of the final recipient and end-user.

Failure to comply, or provision of ambiguous, incomplete or misleading information, permits immediate cancellation.

2.4 Military or Law-Enforcement Orders

The Platform Operator may, at its sole discretion, consider manufacturing components for officially authorised armed forces or governmental agencies of recognised states. Such orders require prior written approval and verifiable official documentation. Standard Platform workflows may not be used.

2.5 Client Agreement to Terms

By placing an order, creating an account, uploading a file or otherwise using the Platform, the Client confirms acceptance of this Prohibited Items Policy and all related rules, terms and conditions. This acceptance is a condition for access to the Platform and for the initiation of any order.

3. Liability and Enforcement

3.1 Order Refusal and Cancellation

Any order that the Platform Operator determines to involve prohibited items or associated risk may be unilaterally rejected or cancelled at any time. Such cancellation may occur without refund, regardless of order status, material costs or manufacturing progress.

3.2 Reporting to Authorities

The Platform Operator may report any suspicious, unlawful or potentially harmful order or activity, including associated models, personal information and communication logs, to competent authorities in Latvia, the European Union or other relevant jurisdictions. This includes law enforcement, licensing authorities, financial-intelligence units, customs authorities or export-control regulators.

3.3 Cooperation With Investigations

The Platform Operator will cooperate fully with any lawful investigation. This may include disclosure of order details, uploaded models, payment information, logs, communications and technical data, subject to applicable data-protection laws.

3.4 Responsibility for Final Use

The Platform Operator is not responsible for the final use, misuse, modification or deployment of any manufactured item. If a produced item is later used to harm any person, cause damage, commit a crime or violate any law, the Client bears full legal responsibility. The Client agrees to indemnify the Platform Operator against any damages, claims, liabilities, prosecutions or losses arising from the Client's actions or the downstream use of the manufactured item.

3.5 Finality of Operator Decisions

All determinations made by the Platform Operator under this Policy are final, binding and not subject to challenge or appeal.

4. Latvia-Specific Compliance

The Platform Operator is subject to the laws of the Republic of Latvia, including:

  • the Law on the Circulation of Weapons (Likums "Ieroču aprites likums"), which strictly regulates weapon components, subassemblies and items that may be adapted for use as weapons;
  • the Law on Export, Import and Transit of Strategic Goods (Likums "Stratēģiskas nozīmes preču aprites likums");
  • Cabinet Regulations governing licensing, export control and classification of strategic goods;
  • Latvia's implementation of Regulation (EU) 2021/821 and related EU export-control frameworks;
  • Latvia's implementation of EU sanctions and its national sanctions list.

Important specifics for Clients:

  1. Latvia classifies a broad range of mechanical parts as "weapon components" if they can reasonably be adapted into a weapon or used for its functioning.
  2. Manufacturing or providing such components without proper authorisation constitutes an offence, even if the item is unfinished or non-functional.
  3. Latvia strictly enforces EU sanctions and requires reporting of suspicious activities under both export-control and anti-money-laundering regimes.
  4. Untraceable, modular or home-manufactured firearm parts fall under the strictest interpretation of "prohibited weapon components" under Latvian law.
  5. The Platform Operator is legally required to refuse manufacture and report any suspected unauthorised weapon-related activity.