Category Archives: Manufacturing

May a gunsmith or manufacturer ship a firearm they have repaired directly to the owner?

A client recently asked this question.  He specifically wanted to know if the rules differ when the customer is in a different state than the manufacturer or gunsmith. Given the myriad laws and regulations which govern both the transfer and shipment … Continue reading

Posted in ATF, BATFE, Federal Law, FFL Issues, Gunsmithing, Interstate Firearm Transfers, Manufacturing, Shipping Firearms | Comments Off on May a gunsmith or manufacturer ship a firearm they have repaired directly to the owner?

May a machine shop allow customers to use their machinery to finish 80% lowers?

I was recently contacted by a firearms enthusiast who is also the owner of a machine shop.  He wanted to know if he could host an event where he opened his shop to a group of fellow shooters so that … Continue reading

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Why do some approved Form 1’s say “FORM 1 REGISTRATION” in box 4a?

I recently received a call from a client who had received his approved Form 1 for a self-manufactured suppressor.  The Form 1 application had been submitted pre-41F via eForms. In reviewing the approved form in preparation for having his tube … Continue reading

Posted in 41F, 80% Lower, Administrative Law, ATF, BATFE, eForms, Engraving, Federal Law, Form 1, Manufacturing, SBR, Suppressors | Leave a comment

Do you have to register for ITAR if you are only manufacturing AR-15 uppers?

In my last post I answered the question of whether or not an FFL is required if one is only manufacturing and selling AR-15 uppers. Almost immediately I was asked a follow-up question about whether or not a person who … Continue reading

Posted in AR-15, ATF, BATFE, Federal Law, ITAR, Manufacturing, Uppers | Comments Off on Do you have to register for ITAR if you are only manufacturing AR-15 uppers?

Do you need an FFL to manufacture and sell AR-15 uppers?

I was recently asked whether an FFL is required to manufacture and sell AR-15 uppers. The answer is ‘no‘ but I want to caution readers that this would not necessarily be the case if the upper in question was for a … Continue reading

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What are the requirements for engraving an item you are building on a Form 1?

This is one of those questions that gets asked over and over again and I should have written about it long before now. But today I correct that omission. Let’s walk through this in 10 easy steps. 1)  When you build an … Continue reading

Posted in 80% Lower, ATF, BATFE, Engraving, Form 1, Manufacturing, NFA Trusts, SBR, Short Barreled Rifles, Short Barreled Shotguns | Comments Off on What are the requirements for engraving an item you are building on a Form 1?

Does 922(r) apply when building an SBR from an imported pistol?

I received a call last week from a client who was planning to SBR a swiss pistol and wanted to know whether the US-made parts requirement of 922(r) would apply. His concern is understandable since this is yet another area where … Continue reading

Posted in 922(r), AR Pistols, ATF, ATF Guidance Letters, BATFE, Federal Law, Firearms Technology Branch, Form 1, Imports, Manufacturing, SBR, Short Barreled Rifles, Short Barreled Shotguns | Comments Off on Does 922(r) apply when building an SBR from an imported pistol?

Has the ATF changed their mind about the Sig brace?

UPDATE: The ATF has released a letter clarifying their position on this issue.  For the latest information, read my article discussing their open letter. … Over the last week I have had a flood of emails from clients wanting to … Continue reading

Posted in AOW, AR Pistols, ATF, ATF Guidance Letters, BATFE, Firearms Technology Branch, Form 1, Manufacturing, SBR, Short Barreled Rifles, Short Barreled Shotguns | Comments Off on Has the ATF changed their mind about the Sig brace?

Want to get your manufacturers FFL? Don’t forget ITAR!

Last week I received a call from an FFL client who was concerned about a conversation he had with an ATF agent during a routine audit. My client holds a manufacturing FFL but has never actually engaged in manufacturing since … Continue reading

Posted in AECA, ATF, BATFE, Federal Law, FFL Issues, ITAR, Manufacturing, USMIL, USML | Comments Off on Want to get your manufacturers FFL? Don’t forget ITAR!

Form 1 is available on eForms once again!

Probably the single question that I am asked more than any other is “When will eForms be back?”  And while I cannot answer for Form 4 applications I can tell you this … Form 1 is back as of today! … Continue reading

Posted in ATF, BATFE, eForms, Form 1, Manufacturing, NFA Trusts, Processing Times | Comments Off on Form 1 is available on eForms once again!