Friday, August 29, 2008

Manufacturing definitions.

So, as some of you may recall, the ATF recently released a document clarifying what it thought constituted "manufacturing firearms".

Since this made it sound like your gunsmith needed a Type 07 and had to pay excise tax if he put new sights on your Glock or spray-painted your 870 green, this raised some questions. Sean Galt decided to write to the BATFE for clarification, and included an extensive list of cc recipients.


Regolith said...


Writing to the BATFU for clarification is about like playing Russian Roulette. There's no guarantee that the letter you get in return will reflect their actual policies, and a non-significant chance that they'd tell you you're in the clear, then arrest you or shut down your operations a few weeks later after they decided they didn't really mean what they said.

SpeakerTweaker said...

I'm really loving not only the cc recipients, but the order they're listed in.

This guy clanks when he walks.


B&N said...

Does this mean that the several cans of AlumahydeII that I have on my garage shelving qualifies me as being a manufacturer?

Somebody in legal should get in touch with Brownells about this.

Regolith said...


That should read "non-insignificant."

dneylon said...

Under their definitions I should probably be waiting for a BATFU raid due to the modifications I made to my 20 gauge.

trebor1415 said...

Did anyone else notice this only applies if the gunsmith did work to a gun that he then *sold* to a customer.

A gunsmith who does work on CUSTOMER SUPPLIED guns does NOT need a manufacturer's FFL as this rule does not apply.

I'm not defending this rule, but it's not the OMG NO MORE GUNSMITHING EVER! rule that people think.

Army of Dad said...

If that is true then the gunsmith woudl need to wait until a customer buys a gun to do a the work. When doing it before the cutomer buys might actually lead to a sale.

Oh wait, ATF and logic were never introduced.

Sean Galt said...

I'm not willing to chance a random interpretation by whomever the agent dejour may happen to be.
When the penaty for being noncompliant with ITAR is up to $1,000,000 and/or 10 years, I want a letter back and on file.
If I have to follow new rules, so be it. It would only broaden my horizons...for a price.
Yet I keep working- but only for LEOs, right now.

Tam said...


FWIW, what Trebor said is correct based on my calling around. Give Hamilton Bowen a ring, as he's been very active in getting this nailed down. Tell him that Tamara (the chick who brought the Webley auto for him to shoot last fall) suggested you call.

Basically, if you're an 01, you don't want to do any work on guns unless somebody's already paid for them, otherwise you are straying into 07 territory and (more importantly) owe excise tax on the difference in value you've added to the gun..