Is Adding a Stock "Manufacturing"

[eltee]

I have been an FFL 01 for many years. I JUST got my SOT 03 approved.

I want to put an HK factory stock on an HK SP5 pistol, making it an SBR which I am licensed to possess, sell, etc. I am just not sure if I need a "manufacturing" license to simply attach a factory stock.

Also, does anyone have an email or phone number to contact BATFE to ask this question? I recently relocated to Nevada (hence the SOT).

THANK YOU for any input.

For the record, Nevada and Clark County were extremely welcoming and helpful in transferring my FFL 01 from California to here, and the local BATF made acquiring my SOT 03 very easy.

[OCArmory]

Yes it is manufacturing. Just call the local field rep that did your initial interview. They are usually the most helpful. Since you are not a manufacturer with an SOT you will have to pay the $200 as it is outside the scope of your license. It will also need to be engraved. The only reason to go this route would to use the business name for engraving purposes.

[eltee]

Could I transfer it to a local 07 (manufacturer) licensee, have them attach the stock, then form 3 it back to my business?

[Tyke8319]

ATF definition of manufacturing:

https://www.atf.gov/file/82791/download

[audiophil2]

Manufacturing SBRs also requires ITAR registration and payment.

[OCArmory]

Yes you could just have a local 07 manufacture it and transfer it back on a form 3. That is what I would do.