Transfer of parted Single Shot AR

[ugimports]

Below is the quote from my customer. This initially sounds ok, except when am I required to log in the shipment to my bound book? Am I obligated to do it right after I open the box? Or can I let the customer touch it, fully assemble it on their own, and then log it in as a Single Shot Pistol? I know if I log it in before hand as a receiver then it would get DROSd as a long gun which we do not want. Am I ok having the customer fully assemble the firearm at my location after I receive the firearm, but before I log it in? Or is this a no-no? I've already sent a message back to my customer asking if they could just ship their upper to the sender so it comes to me fully assembled, but I haven't heard back yet.

I read about your fairly new FFL service in the Fremont area. Welcome! It's always good to have new options. I am working on jumping through the necessary hoops to get an AR pistol. My question is this, I plan to purchase a completely assembled AR pistol lower receiver from an out of state vendor (assembled meaning receiver, LPK, bullet button, pistol grip, buffer assembly, and fixed bobsled 0 round mag). Can I have this shipped to you, then I show up with a completely assembled pistol upper assembly, put the two halves together, insert two pins, and there we have a complete single shot AR pistol. Then we complete the DROS and I leave to wait my 10 days.

[freakshow10mm]

Act of manufacturing whether he does it or you do it. If it's done before 4473, it's manufacturing. An 07 FFL will have to do this for it to be legal.

Your options are have an out of state 07 FFL build it or you build it as you are an 07 FFL (which will also trigger ITAR).

Don't play with fire.

[aplinker]

Act of manufacturing whether he does it or you do it. If it's done before 4473, it's manufacturing. An 07 FFL will have to do this for it to be legal.

Your options are have an out of state 07 FFL build it or you build it as you are an 07 FFL (which will also trigger ITAR).

Don't play with fire.

Follow the above advice.

This has caused problems for other CA FFLs.

[ugimports]

Thanks, I've let the customer know that it needs to be fully assembled prior to shipment to me.

[tenpercentfirearms]

Thanks, I've let the customer know that it needs to be fully assembled prior to shipment to me.

That is the only way I would do it. Just the idea of letting a customer mess with the firearm before I log it in sounds wrong. If it doesn't come ready to go, then it shouldn't come at all.

[lorax3]

Act of manufacturing whether he does it or you do it. If it's done before 4473, it's manufacturing. An 07 FFL will have to do this for it to be legal.

Your options are have an out of state 07 FFL build it or you build it as you are an 07 FFL (which will also trigger ITAR).

Don't play with fire.

What constitues manufacturing according to the ATF?

Changing of weapon types? i.e other to pistol?

1. A rifle that comes in with a 20" barrel and the customer brings in a 16" they want to buy it with instead. The shop agrees to swap the barrels and sell the 20" as a part to someone else. Comes in as a rifle, leaves as a rifle. Manufacturing?

2. A complete AR comes in, one of the shop employee's wants the upper. The shop decides to sell the upper to the employee and offer the complete lower to the masses. Comes in as a rifle, leaves as a rifle, or maybe an other.

[djbooya]

What constitues manufacturing according to the ATF?

Changing of weapon types? i.e other to pistol?

1. A rifle that comes in with a 20" barrel and the customer brings in a 16" they want to buy it with instead. The shop agrees to swap the barrels and sell the 16" as a part to someone else. Comes in as a rifle, leaves as a rifle. Manufacturing?

2. A complete AR comes in, one of the shop employee's wants the upper. The shop decides to sell the upper to the employee and offer the complete lower to the masses. Comes in as a rifle, leaves as a rifle, or maybe an other.

Here's my understanding from what I've learned so far:

1. Barrels are drop in parts, not manufacturing. It gets logged in as a rifle and out as a rifle. As an aside, I would think it just as easy for the the customer to buy it with the 20" and swap the barrel out after DROS. That would avoid any ambiguity in my opinion.

2. Not sure, since if the rifle is disassembled then it is more of de-manufacturing so I'm not quite sure what happens when it gets logged out of the bound book since it isn't necessarily leaving as a full rifle if just the lower is sold later. However, I would assume putting on a different upper would then be manufacturing.. eh, I'm confusing myself with this scenario.

We'll see what others come back with...

[Quiet]

AFAIK...

Rifle gets logged in as a rifle (20" barrel) and logged out as a rifle (16" barrel). No manufacturing because it's still a rifle.

Reciever gets logged in as a reciever and logged out as a single-shot pistol.
Manufacturing because it gets logged in as one thing and out as another.

[lorax3]

Here is something interesting I found here.

U.S. Department of Justice
Bureau of Alcohol, Tobacco,
Firearms and Explosives
Firearms Technology Branch
August 15, 2008
Martinsburg, West Virginia 25405

https://www.atf.gov

[USMG]

It does get logged in as one and out another. He needs an out of state class 7 to do the work, it gets filed as a pistol, then shipped to you or the FFL in Ca to handle the transfer. We can do it, if you need it. Contact me to get all the specifics and costs.

[ugimports]

It does get logged in as one and out another. He needs an out of state class 7 to do the work, it gets filed as a pistol, then shipped to you or the FFL in Ca to handle the transfer. We can do it, if you need it. Contact me to get all the specifics and costs.

He is shipping his upper to the guy that build up the lower. He was just trying to save some time by not having to ship the upper out. Not sure who he used, but we're all set now, thanks all.

[freakshow10mm]

1. A rifle that comes in with a 20" barrel and the customer brings in a 16" they want to buy it with instead. The shop agrees to swap the barrels and sell the 20" as a part to someone else. Comes in as a rifle, leaves as a rifle. Manufacturing?

No.

2. A complete AR comes in, one of the shop employee's wants the upper. The shop decides to sell the upper to the employee and offer the complete lower to the masses. Comes in as a rifle, leaves as a rifle, or maybe an other.

In as rifle, out as rifle. In that situation as shop owner, I wouldn't split the weapon.