Would this constitute manufacturing?

[CifaldiPrecision]

Can an FFL01 gunsmith/retailer purchase a firearm for their inventory then do upgrades to that gun weather cosmetic or functional and then sell it that way or would that be considered manufacturing?

For example Glock 19, at apex trigger and do some slight work with the mill and then sell it.


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[Tyke8319]

It's no longer an approved handgun because it's been altered prior to sale.
Sell it then do the alterations.

[RickD427]

In addition to the roster issue correctly identified by Tyke8319, you should also be aware that the Fourth Circuit considered essentially the same issue in Broughman v Carver and held that the activity was "Manufacturing" such that an FFL07 was required.

[CifaldiPrecision]

Would this constitute manufacturing?

In addition to the roster issue correctly identified by Tyke8319, you should also be aware that the Fourth Circuit considered essentially the same issue in Broughman v Carver and held that the activity was "Manufacturing" such that an FFL07 was required.

This is the kind of info I needed. Thank you.

I assumed it would be but thought may as well ask.


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[taperxz]

In addition to the roster issue correctly identified by Tyke8319, you should also be aware that the Fourth Circuit considered essentially the same issue in Broughman v Carver and held that the activity was "Manufacturing" such that an FFL07 was required.

That's not entirely accurate, FFL 01s are given more latitude than that from ATF.

The real problem right now is the fee imposed by the state dept to do some of this work. (ITAR CRAP)

[CifaldiPrecision]

That's not entirely accurate, FFL 01s are given more latitude than that from ATF.



The real problem right now is the fee imposed by the state dept to do some of this work. (ITAR CRAP)

Well that's imposed on gunsmiths no matter.


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[taperxz]

Well that's imposed on gunsmiths no matter.


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No its not. Its only if you thread or do machine work that changes the characteristics of the firearm.

[CifaldiPrecision]

No its not. Its only if you thread or do machine work that changes the characteristics of the firearm.

So with the work I do yes it's imposed.


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[RickD427]

That's not entirely accurate, FFL 01s are given more latitude than that from ATF.

The real problem right now is the fee imposed by the state dept to do some of this work. (ITAR CRAP)

No its not. Its only if you thread or do machine work that changes the characteristics of the firearm.

taperxz,

Can you provide a citation?

The ATF cannot override a Circuit Court decision.

[CifaldiPrecision]

For example.

http://www.calguns.net/calgunforum/showthread.php?t=1318141

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[taperxz]

taperxz,

Can you provide a citation?

The ATF cannot override a Circuit Court decision.

We were sent a letter from the ATF outlining what constitutes manufacturing and requiring the State Department fee to do machining.

In Broughman v Carver the owner admitted to custom building rifles. The court ruled he needed to be an 07. Doing trigger work i don't believe would fall under an 07 only type work. Which is what the OP is about. Post purchase of course to avoid roster problems.

[CifaldiPrecision]

Yes the ITAR thing on gunsmiths is a legitimate thing that we got a letter from and it's not imposed by the ATF if that's what you're asking about. You are only allowed to swap equal parts for equal parts however doing any kind of machining such as threading a barrel etc. then requires ITAR payment supposedly


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[taperxz]

Yes the ITAR thing on gunsmiths is a legitimate thing that we got a letter from and it's not imposed by the ATF if that's what you're asking about. You are only allowed to swap equal parts for equal parts however doing any kind of machining such as threading a barrel etc. then requires ITAR payment supposedly


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Not asking, just saying. Additionally ATF doesn't have enforcement of that executive order by Obama, State dept does.

Under Trump, there probably is no enforcement of it. That's not me denying the rule does not exist or one should not adhere to the order at this time.

We are pretty particular how we move forward with a customers firearm but we do our gunsmithing as needed as an 01.

[CifaldiPrecision]

Would this constitute manufacturing?

Not asking, just saying. Additionally ATF doesn't have enforcement of that executive order by Obama, State dept does.



Under Trump, there probably is no enforcement of it. That's not me denying the rule does not exist or one should not adhere to the order at this time.



We are pretty particular how we move forward with a customers firearm but we do our gunsmithing as needed as an 01.

It was not an executive order.

2250 a year sucks.

The penalty if out of compliance sucks more. Lol


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[taperxz]

It was not an executive order.

2250 a year sucks.

The penalty if out of compliance sucks more. Lol


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I believe it was Obama agreeing to United Nations treaty via executive order since congress did not vote on or approve of the deal. Which means a Trump can rescind it. Aka executive order.