Category Archives: Manufacturing

eForms is back for Form 1 Submissions

At the beginning of October, the ATF announced that Form 1’s are once again available for submission via eForms. Initial applicants have astonishingly reported approvals in as little as 15 days!  And while I suspect that number will increase with … Continue reading

Posted in 41F, 80% Lower, Administrative Law, AOW, AR Pistols, AR-15, ATF, BATFE, CLEO Notification, eForms, Form 1, Form 23, Manufacturing, NFA Trusts, Processing Times, SBR, SBS, Short Barreled Rifles, Short Barreled Shotguns | Comments Off on eForms is back for Form 1 Submissions

Do I need an FFL if all I am going to do is manufacture and sell cast bullets?

I received a call from a client last week asking this question. He wanted to start a business manufacturing cast bullets which he would then sell online and at flea markets. He was hoping that, because he was only dealing … Continue reading

Posted in Administrative Law, AECA, Ammunition, Ammunition Components, ATF, BATFE, Federal Law, FFL Issues, ITAR, Manufacturing, USML | Comments Off on Do I need an FFL if all I am going to do is manufacture and sell cast bullets?

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

Posted in 80% Lower, ATF, ATF Ruling, BATFE, Manufacturing, Regulatory Rulemaking | Comments Off on May a machine shop allow customers to use their machinery to finish 80% lowers?

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

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

Posted in AR-15, ATF, BATFE, Federal Law, FFL Issues, Manufacturing, Uppers | Comments Off on Do you need an FFL to manufacture and sell AR-15 uppers?

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:  For the latest news on the stabilizing brace issue, see my March 21, 2017 update. … Over the last week I have had a flood of emails from clients wanting to know what I think about the ATF’s seemingly ever-changing … 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?