This may cloud the issue a bit, but I'll go ahead.... I asked the ATF if the shipping of an unattached but fully built upper and lower in the same box would cause any issues. The ATF concurred that "assembling" the upper and lower is no different than assembling an o/u shotgun. In addition, the act of assembling did not constitute "manufacturing" by the receiving dealer. I can't imagine a dealer receiving an o/u shotgun as "other" or "frame only," so why would an AR be different?
In California, there is no constructive possession element to the AWB. Consequently, it is not a felony for a full featured, NON-BB equipped, lower to be shipped with the upper unless or until the two pieces are attached. If I am shipping out of state, then the issue is moot.
In California, there is no constructive possession element to the AWB. Consequently, it is not a felony for a full featured, NON-BB equipped, lower to be shipped with the upper unless or until the two pieces are attached. If I am shipping out of state, then the issue is moot.

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