An FFL Question to gunsmiths

[mao0720]

To all of you 'smiths out there making custom bolt action rifles, do you have to have a type 7 FFL or just a standard FFL? Does barreling an action and bedding a stock to it constitute "manufacturing a firearm? The reason I ask is because my dad is looking into getting his ffl and wanted to assemble AR15s, but he found out to do that he needed a Type 7 FFL for manufacturing firearms. So, I am curious if the same rule applies to bolt action firearms or just to semi-autos.

 

[CatShooter]

To all of you 'smiths out there making custom bolt action rifles, do you have to have a type 7 FFL or just a standard FFL? Does barreling an action and bedding a stock to it constitute "manufacturing a firearm? The reason I ask is because my dad is looking into getting his ffl and wanted to assemble AR15s, but he found out to do that he needed a Type 7 FFL for manufacturing firearms. So, I am curious if the same rule applies to bolt action firearms or just to semi-autos.

Manufacturing a firearm is defined by the person or company that makes the part that has the serial number.

Usually, that is the receiver, but in some cases it can be just a plate of steel.

 

[shortgrass]

Short answer, and certainly NOT the complete answer. If the FFL owns the receiver/action and builds a rifle using it and offers it for sale, he needs a 07 license. Doesn't matter if the action/receiver is from a donor firearm or purchased new (like Stiller or a 700 from Brownells). If your customer supplies the receiver for the build, technically, the customer is the "manufacturer", and the FFL only needs to be licensed as a 01. ATFE would be the proper place to go for clarification as they're the 'enforcers' of the laws and regs, not an internet forum. There are lots of "ins and outs" to this question, and many times it's hard to pry the info out of them. They only answer what you ask and don't elaborate. So, you need to ask them alot of questions.

 

[CatShooter]

Short answer, and certainly NOT the complete answer. If the FFL owns the receiver/action and builds a rifle using it and offers it for sale, he needs a 07 license. Doesn't matter if the action/receiver is from a donor firearm or purchased new (like Stiller or a 700 from Brownells). If your customer supplies the receiver for the build, technically, the customer is the "manufacturer", and the FFL only needs to be licensed as a 01. ATFE would be the proper place to go for clarification as they're the 'enforcers' of the laws and regs, not an internet forum. There are lots of "ins and outs" to this question, and many times it's hard to pry the info out of them. They only answer what you ask and don't elaborate. So, you need to ask them alot of questions.

I am a licensed manufacturer, and the above is a total load of BS.

The manufacturer is the business or person that makes the serial numbered part (usually the receiver) OR the person that converts an existing firearm of one class to a different class.

If you buy or otherwise own a receiver and you put a barrel on it, you are NOT a manufacturer, and need no license, for example you convert a rifle to an SBR or a full auto - then you need a license (called a " Special Occupational Tax").

If what shortgrass said was true, most savage owners with a barrel nut wrench would be looking at big jail time.

 

[shortgrass]

Catshooter, did I say AN INDIVIDUAL couldn't do the work himself? I did not! The question is about "which FFL". I think you need to brush up on the rules/regulations or make a call to ATFE for clarification. By the way,,,, I'm a 07 FFL, myself. I was forced into becoming 07 from a 01(by ATFE) because I had built a couple rifles using receivers that my company owned. By the way catshooter,,,, you've got no cooth or tact and always seem to come off as a know-it-all! My best advise to the OP,,,,,,,, get your advise from ATFE,,,,,,,, NOT from catshooter or me!

 

[CatShooter]

Catshooter, did I say AN INDIVIDUAL couldn't do the work himself? I did not! The question is about "which FFL". I think you need to brush up on the rules/regulations or make a call to ATFE for clarification. By the way,,,, I'm a 07 FFL, myself. I was forced into becoming 07 from a 01(by ATFE) because I had built a couple rifles using receivers that my company owned. By the wat catshooter,,,, you've got no cooth or tact and always seem to come off as a know-it-all! My best advise to th OP,,,,,,,, get your advise from ATFE,,,,,,,, NOT from catshooter or me!

HA!!

 

[shortgrass]

www.atf.gov.Firearms/faq/manufactuers

 

[stacy]

I'M FFL HOLDER MY SELF AND I'M A GUNSMITH,I HAVE A SHOP,SO YOUR BEST BET IS TO CONTACT THE ATF W/YOUR QUESTIONS BECAUSES THEIR A LOT TO YOUR QUESTION.BECAUSE IT'S THERE CHOICE IS TO WHAT U DO AND WHERE U DO IT AT.

 

[mao0720]

So, then, Catshooter, is a bolt action receiver considered a "rifle" or an "other"? Because an AR receiver when purchases on its own is considered an other. So, when you buy a stripped receiver and build it into a rifle you have converted it to a different class.

 

[CatShooter]

So, then, CatShooter, is a bolt action receiver considered a "rifle" or an "other"? Because an AR receiver when purchases on its own is considered an other. So, when you buy a stripped receiver and build it into a rifle you have converted it to a different class.

What??

The federal definition of "Other" requires individual tax stamps.

http://www.atf.gov/firearms/guides/importation-verification/firearms-verification-nfa-aow.html

The 4473 form uses "other" to describe stripped actions and receivers - when you put a barrel or an upper on it, you are not converting it, and you are not manufacturing it.

It is semantics.

If what shortgrass said was true, then you would need a manufacturing license to change barrels on a Glock - and along with the class 7 license come the mandatory export licenses from the state department (even if you are not going to export)... very large green.

 

[mao0720]

[/quote]

What??

The federal definition of "Other" requires individual tax stamps.

http://www.atf.gov/firearms/guides/importation-verification/firearms-verification-nfa-aow.html

The 4473 form uses "other" to describe stripped actions and receivers - when you put a barrel or an upper on it, you are not converting it, and you are not manufacturing it.

It is semantics.

If what shortgrass said was true, then you would need a manufacturing license to change barrels on a Glock - and along with the class 7 license come the mandatory export licenses from the state department (even if you are not going to export)... very large green.
[/quote]

I meant "other" as in the term used on 4473s not "other" as in "Any other weapon". The law still states that if you as an FFL holder want to assemble ,from components, ARs you must have a type 7 FFL licence.

 

[shortgrass]

My 'link' didn't work,,,, try this; www.atf.gov 'click' on "Firearms" under "Firearms Industry" click on "frequently Asked Questions" now click on "manufactuers" (it's inside the heavily outlined box near the bottom)

 

[CatShooter]

My 'link' didn't work,,,, try this; www.atf.gov 'click' on "Firearms" under "Firearms Industry" click on "frequently Asked Questions" now click on "manufactuers" (it's inside the heavily outlined box near the bottom)

Your link/reference make my case - read it carefully!

 

[CatShooter]

I meant "other" as in the term used on 4473s not "other" as in "Any other weapon". The law still states that if you as an FFL holder want to assemble ,from components, ARs you must have a type 7 FFL licence.

Read this link carefully.

http://www.atf.gov/firearms/faq/manufacturers.html

If you do onesies and twosies - or a gunsmith puts one together for a customer as an order, they are not manufacturing them - if a gunsmith (or you) buys a bunch of lowers and a bunch of uppers, then it is considered manufacturing.

It is a matter of quantity and intent.

 

[stool]

ACTUALLY up to 49 per year WITHOUT the 07...........

if i read the fine print right and it has not changed.

this gets down to FET I BELIEVE.

you buy a reciever and sell it no 07.
buy a reciever and add value buy assembling into a rifle, you need an 07...if more than 49 per year...and you owe the FET on the new value.

 

[mao0720]

I read the ATF FAQ carefully, and there still seems to be some grey area. Essentially, it seems to me. If I have a customer say " I want this action, this barrel and this stock" and I acquire those parts from a distributer and assemble them, then I DO NOT need a type 7. But if I buy a receiver, barrel and stock. Assemble them and put them on my shelf for sale, then I DO need a type 7. Am I reading this correctly. It also seem that my above interpretation would apply to ARs as well?

 

[shortgrass]

I read the ATF FAQ carefully, and there still seems to be some grey area. Essentially, it seems to me. If I have a customer say " I want this action, this barrel and this stock" and I acquire those parts from a distributer and assemble them, then I DO NOT need a type 7. But if I buy a receiver, barrel and stock. Assemble them and put them on my shelf for sale, then I DO need a type 7. Am I reading this correctly. It also seem that my above interpretation would apply to ARs as well?

That's the way I read it, too! And that's the way ATFE explained it to me! Did you look at all the other so called "gunsmithing activities" that are considered 'manufacturing'?

 

[mao0720]

Guys it Christmas, let's keep the jibes and attitudes to a minimum. That is not directed to any specific person but to all members, and commenters, please.

 

[dickn52]

Ok, I am NOT an FFL holder. I do have a serial numbered Win 52 barreled receiver/action that I am about to build into a rifle. At the present time it is just a chunk of steel waiting a trigger, bolt, guard, stock and sights to become a .22 LR rifle. Can I do this legally? When I bought the action it went through an FFL transfer to me. (Actually I am fairly certain that I can find a gunsmith to assemble the parts into a working rifle).

 

[stool]

one it is not just a chunk of steel...it is a serialized rifle reciever......goood news you have already done the hard part.
in my opinion you or your gunsmith, without an 07, can complete your project....to become a 22 rf rifle.

Ok, I am NOT an FFL holder. I do have a serial numbered Win 52 barreled receiver/action that I am about to build into a rifle. At the present time it is just a chunk of steel waiting a trigger, bolt, guard, stock and sights to become a .22 LR rifle. Can I do this legally? When I bought the action it went through an FFL transfer to me. (Actually I am fairly certain that I can find a gunsmith to assemble the parts into a working rifle).