Regulation Interpretation

P

parshal

Member
I went down a rabbit hole by accident today and came across this page outlining the ATF's proposed rule 2021R-05. The thing that caught my eye was the second paragraph under Licensing of Dealer/Gunsmiths. How do you folks interpret this?

Dealer/gunsmiths are not authorized to perform repair, modify, embellish, refurbish, or install parts in or on firearms (frames, receivers, or otherwise) for or on behalf of a licensed importer or licensed manufacturer because those firearms are for sale or distribution. A license as a Type 07 manufacturer would be required.
 
I read that to mean you couldn't, for instance, install a muzzle brake without a manufacturer's license.
 
Read the " for or on behalf of Manufacturer" in other words you can not do work for a manufacturer of firearms before it is sold to public

Jim
 
The way my ATF Agent described it to me is thus;

As an 01FFL I can install a brake on another man's gun when he brings it in.
As an 01FFL I can install a barrel on another man's gun when he brings it in.
As an 01FFL I can stock and sell guns.
As an 01FFL I can stock and sell actions.

But if I want to buy actions and put barrels on and sell them as completed guns I need an 07FFL

I've worked with the ATF as ATF......and as BATF........and as BATFE......and now as ATF again.

They tried 3 times to sting the shop where I worked as a gunsmith in the 80's and I swore I'd never do them the dignity of retaining a license ever again. I told my ATF Agent this when I decided to consider re-upping as an FFL. We had a nice talk and he assured me they're trying to change their cowboy image. He even knew who Lon Horiuchi is. (DON'T BUY STUFF FROM HS PRECISION!!)....... please!

I still don't know if he was correct but because he treated me like a fellow human being I went with his recommendation and got an 07FFL

I buy some Kelbly actions and build rifles..... I don't know if this constitutes "doing work for Kelbly's" but this is what my agent told me I needed an 07 for
 
Al
It would only be for the mfg if you returned it to them after the work was completed and then was distributed under the mfg's umbrella. I do work for a major company, actually several. Stuff comes in, it goes back out to the mfg. I have never been questioned by them about having an 07 license. I'm sure it will happen at some point. It won't be a problem as I have an 07
 
01 07 007 wtf

This is classic federal ATF burocracy. Why have multiple designations when one would cover it all. I am going to get a 00LH license. I can barrel an AR but only a left handed one.
 
beaurocracy is beaurocracy is beaurocracy...... for the most part they don't know no better

At least the ATF IMO is actually trying to clean up their act and are LESS anti-gun than they were in the 80's-90's

The FBI on the other hand is striving concertedly for new heights of dysfunction

And are openly anti-gun
 
did you pay your federal export lic fee ???? you know even tho you never ship or sell outside the usa ??
 
I've had an FFL since the early 80's. I always had a good relationship with the ATF. I think starting with a good attitude when they stop by goes a long way. They are in the compliance business. Hell if it's permissible to run a business out of your house you can still get an FFL.
 
I have a printout of the ATF interpretation of manufacturing furnished by the ATF if anyone wants a copy let me know your email.

Jim
 
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