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View Full Version : Chain of custody, 07 Compliance questions


Boogaloo
01-07-2012, 2:30 PM
(AR15 lower receiver manufacturing)

Wondering if any of you had any specific information on chain of custody and license requirements with regards to building lowers from raw forgings.

I Did as much searching as I could prior to posting this, if it has been addressed and my search skills failed me, please forgive the inconvenience.

My intentions are to do 100% of the machining myself from raw forgings.
Ultimately, I will need to have the Type III anodizing done elsewhere.
Furthermore, I intend to finish these lowers in my own work space located at my house.

Assume for the sake of this conversation that my 07 lists my home address as my place of business exclusively. I have a shop located in another city, and it is NOT listed on my FFL nor is it licensed separately.

At what point am I required to license (or only do business with licensees) the additional facilities that I use for ANY process during the fabrication of said lowers?

As an example:

(1) I receive the raw forgings (from a vendor) at my home office (my workspace).
(2) I transport the raw forgings to my shop which is not listed on my FFL (nor licensed separately)
(3) I (personally) machine the forgings into "80%" lowers at the shop
(4) I then return back to my home work space to finalize the remaining 20% (sans the anodizing), thereby manufacturing a 100% lower.

Substitute (1) for billet. In other words, I may elect at some point to produce 80% lowers from billet @ the shop. That will come later.

Am I in compliance as long as I do not manufacture a fully functioning lower at the shop ?

I ran this by my IOI, but he directed me to email the firearms technology branch, and indicated that they can take a couple of weeks to reply since they are a bit understaffed. That is why I am reaching out to you folks.

Just figured I would see if any of you have addressed this issue before.

Thanks in advance.

EBR Works
01-08-2012, 6:52 AM
IMO your process appears correct since the lowers are "born" at your licensed location. Be aware that the anodizing facility will need to have an FFL unless you physically remain with the lowers during the process. Where is the engraving being done?

Boogaloo
01-08-2012, 9:16 AM
IMO your process appears correct since the lowers are "born" at your licensed location. Be aware that the anodizing facility will need to have an FFL unless you physically remain with the lowers during the process. Where is the engraving being done?


Hi EBR,
Thank you for the reply.

The "engraving" will be done on our CNC's.

Your reply begs a question however.

Can I have ANY process performed on these lowers at any phase in the operation or at any location/facility I choose, so long as I (the FFL holder) remain with them throughout the process?

EBR Works
01-08-2012, 11:28 AM
That is my understanding. Someone please correct me if I am wrong.

You may also want to join and post this question here since it is a FFL only forum:

http://www.fflonly.com/intro.php

They have a manufacturing specific sub-forum to post this.

efillc
01-09-2012, 6:02 AM
Can I have ANY process performed on these lowers at any phase in the operation or at any location/facility I choose, so long as I (the FFL holder) remain with them throughout the process?
Once the lower is a firearm (more than 80% complete) the business performing the work would need a Type 07 even if you're present when the work is done.
See example #3: http://www.atf.gov/firearms/faq/manufacturers.html#dealer-gunsmithing

ETA: We've found that even if the lowers haven't reached the 80% threshhold yet, most non-FFL machine shops still won't touch them out of fear of violating federal laws.

ke6guj
01-09-2012, 6:39 AM
Once the lower is a firearm (more than 80% complete) the business performing the work would need a Type 07 even if you're present when the work is done.
See example #3: http://www.atf.gov/firearms/faq/manufacturers.html#dealer-gunsmithing


that is more a generic FAQ than actual legal answer.

IIRC, I've seen letters that said that it was ok for an non-FFL shop to do the work as long as the FFL was physically present.