Need an 07 FFL to build ARs?

[Table Rock Arms]

So based on that, a customer can buy a stripped lower and every other part and the 01 FFL can assemble it without needing a manufacturer's license. However, the 01 FFL cannot take a stripped lower, build it into whatever configuration they want and then attempt to sell it.

I haven't looked into it too deep as I am an 07 FFL so I could do it anyway, but I believe you can do it if the customer brings the gun to you, and it is not something you do all the time. But if you sell the lower and then build it up and make a habit of those kind of transactions, that won't fly. I could be wrong.

[jtmkinsd]

So based on that, a customer can buy a stripped lower and every other part and the 01 FFL can assemble it without needing a manufacturer's license. However, the 01 FFL cannot take a stripped lower, build it into whatever configuration they want and then attempt to sell it.

Correct...the whole restriction comes into play when you manufacture for sale. But if you build one or two a year ATF isn't going to come down on you IMHO.

[franklinarmory]

rbetts... great post.


How about if the FFL in question buys frames, then sells "Kits" that are comprised of all the component parts off a functional AR-platform rifle?

As in, serialized frame. Upper, stock etc.... Without actually selling it as a complete firearm?

In this scenario you only need an 01 as you are selling the frames and are not MFGing a firarm correct?

Because you are selling a complete firearm (even though it is not built out,) the TTB will still want their excise tax of 11% if you sell enough of them. So be sure to factor that into your cost.

[Table Rock Arms]

Because you are selling a complete firearm (even though it is not built out,) the TTB will still want their excise tax of 11% if you sell enough of them. So be sure to factor that into your cost.

This is a fact. I was on the phone with TTB 10 minutes ago and the guy told me this even though I never asked about it.

Ryan

[Purple K]

What about minor things like installing scopes, bullet buttons, etc?

[GoingQuiet]

What about minor things like installing scopes, bullet buttons, etc?

Installation of parts on customer request = gunsmithing. That is an allowable practice as an 01.

Installation of parts on your behest with intent to improve for resale = Manufacturing.

If a customer comes in and wants you to bolt a scope on, no problem.

When you start thinking hey, I can add this and this and this and sell it as a package, you owe Uncle Sam FET.

[Munk]

This is a fact. I was on the phone with TTB 10 minutes ago and the guy told me this even though I never asked about it.

Ryan

Perhaps if it's a receiver on one transaction, and a "build kit" as the next transaction? Note: The build kit would be a distinct item that may be used with any lower, not just the one that was purchased minutes before.

(this is mostly theoretical jackassery on my part, If i do get into the business I fully intend to get MFG status so I can do proper builds for people.)

[GoingQuiet]

*snip*

[GoingQuiet]

This is correct. If you make any modification with intent to resell it is manufacturing. And according to the TTB website, anything you modify with intent to resell makes you liable for excise tax. I am trying to qualify that but TTB is not real good about getting back to me.

What I am trying to figure out, is at what point do you have to mark the gun or barrel with your company info. Obviously if you repair a broken stock on a Remington 700 you wouldn't have to. But if you are changing the gun from semi auto to single shot would you have to then? I was under the impression that if you are part of the manufacturing process of the final product you either have to have a variance or your info must go on the gun, but there are some people saying otherwise. Do you have any idea on this?

Don't know if this helps but.....

http://www.goingquiet.com/GunbrokerPhotos/ATF%20Markings.jpg

[Table Rock Arms]

Don't know if this helps but.....

http://www.goingquiet.com/GunbrokerP...20Markings.jpg

Good info. The reason I am trying to contact them is in regards to converting a semi auto pistol to single shot and dropping in a longer barrel to meet regulations in order to ship the gun into California. According to all the info that I have read from ATF, I can't imagine that I wouldn't have to engrave it with my info, but there have been a couple people who told me it is considered gunsmithing and you don't have to. I am basically 100% sure that if I am buying the gun then modifying it for the purpose of reselling it then I have to log it into my manufacturing bound book, engrave my info in it, and pay excise tax if I do over 50 of them. Which is exactly what I am doing until I hear otherwise. However it would make things cheaper and easier if I didn't have to so I am looking into it.

Ryan