Category Archives: Manufacturing

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

Posted on February 5, 2017 by John Pierce

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?

Posted on January 25, 2015 by John Pierce

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?

Posted on January 7, 2015 by John Pierce

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?

Posted on December 28, 2014 by John Pierce

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?

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

Posted on October 5, 2014 by John Pierce

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!