Parts kit / Registered receiver

[Clickjack]

[BONECUTTER]

Did you already DROS the receiver?

If yes, who shipped the firearm to the builder?

If you, why is the builder not shipping back to you?

If you had a firearm and sent to a FFL/builder, they should be sending back to you.
If you shipped them and they are sending to a dealer yes, the dealer needs to DROS the firearm.

[Clickjack]

Did you already DROS the receiver?

If yes, who shipped the firearm to the builder?

If you, why is the builder not shipping back to you?

If you had a firearm and sent to a FFL/builder, they should be sending back to you.
If you shipped them and they are sending to a dealer yes, the dealer needs to DROS the firearm.

I dros’d the receiver
I shipped the receiver and the parts kit to the builder.

Builder says it has to go to an ffl so there is record of it being a completed rifle now and not just a receiver but made it sound like I didn’t have to dros it again. Man I don’t want to dros it again and wait 30 days. California is a bummer

[BONECUTTER]

Builder in incorrect and can mail directly back to you. If they are forcing you to go though a dealer I would ask they cover your transfer fees/DROS/ect.

There is no law that requires it to go to a dealer or a record that it is now a rifle. If they say there is ask them to cite the Penal Code.

[CM Arms]

Wouldn't the builder have to be an 07 and roll mark and serial number the receiver post build? It's not like an AR-15 where they are just assembly parts.

If it has a new manufacturer and serial, I can see if having to go through an FFL to be re-DROS'd.

[BONECUTTER]

Wouldn't the builder have to be an 07 and roll mark and serial number the receiver post build? It's not like an AR-15 where they are just assembly parts.

If it has a new manufacturer and serial, I can see if having to go through an FFL to be re-DROS'd.

No, it is like an AR15. The lower was already transferred and serialized. Putting the parts together is not manufacturing.

If the dealer bout lowers and then build to sell as rifles they would be manufacturing.

[SkyHawk]

It is a gray area and some FFLs may error on the side of caution and function as an 07 FFL. Especially if they do this type of work frequently.

This gives a little insight:

https://www.atf.gov/regulations-rulings/rulings/atf-rulings/atf-ruling-2010-10.htm

Without knowing more about this specific FFLs license type, or if they have re-marked this gun - hard to say much more.

But in the end, this is how they chose to do it - and you have to roll with it now...

ATF’s long-standing position is that any activities that result in the making of firearms for sale or distribution, to include installing parts in or on firearm frames and receivers, and processes that primarily enhance a firearm’s durability, constitute firearms manufacturing that may require a manufacturer’s license. In contrast, some activities are not firearms manufacturing processes, and do not require a manufacturer’s license. For example, ATF Ruling 2009-1 (approved January 12, 2009) explained that performing a cosmetic process or activity, such as camouflaging or engraving, that primarily adds to or changes the appearance or decoration of a firearm is not manufacturing. Likewise, ATF Ruling 2009-2 (approved January 12, 2009) stated that installing “drop-in” replacement parts in or on existing, fully assembled firearms does not result in any alteration to the original firearms. Persons engaged in the business of these activities that do not constitute firearms manufacturing need only obtain a dealer’s license.


Although installing parts in or on firearms, and applying special coatings and treatments to firearms are manufacturing activities, the definition of “manufacturer” in 18 U.S.C. 921(a)(10) and 27 CFR 478.11 also requires that a person be “engaged in the business” before the manufacturer’s license requirement of section 923(a) applies. Thus, a person who manufactures a firearm will require a manufacturer’s license if he/she devotes time, attention, and labor to such manufacture as a regular course of trade or business with the principal objective of livelihood and profit