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07 FFL Contract with Machinists

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  • modls7
    Member
    • Feb 2009
    • 414

    07 FFL Contract with Machinists

    I was just wondering, does an 07 FFL that manufactures frames have to complete the manufacturing themselves? Can they contract with a shop? What would be the procedure to contract manufacturing out, if any?
  • #2
    CSACANNONEER
    CGN/CGSSA Contributor - Lifetime
    CGN Contributor - Lifetime
    • Dec 2006
    • 44093

    The one DOING the work needs an FFL.
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    • #3
      ke6guj
      Moderator
      CGN Contributor - Lifetime
      • Nov 2003
      • 23725

      an 07 FFL can use an unlicensed shop to do machine work on behalf of the 07, but the 07 needs to be onsite at all times while the work is being done, and not leave any product at the shop when he isn't there. That way, the 07's FFL covers the work being done. but, if the 07 wants to sub-contract out the work and pick it up when done, then the shop needs to be an 07 and would normally mark it with their licensee info (unless the contracting 07 got a marking variance for the work).

      this is stuff that you need to work out with your ATF auditors to make sure that you are staying on the good side of the line.
      Jack



      Do you want an AOW or C&R SBS/SBR in CA?

      No posts of mine are to be construed as legal advice, which can only be given by a lawyer.

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      • #4
        BigMac
        Senior Member
        • Oct 2005
        • 1117

        As a manufacturer you can have another manufacturer make your receivers.
        You have to arrange with the ATF in advance or the other 07 wont even entertain the idea.

        It done with a variance.
        gunnutsnospam@sbcglobal.net

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        • #5
          efillc
          Member
          • Feb 2009
          • 150

          Originally posted by feederic
          I was just wondering, does an 07 FFL that manufactures frames have to complete the manufacturing themselves? Can they contract with a shop? What would be the procedure to contract manufacturing out, if any?
          Most non-FFL machine shops don't want anything to do with making firearms or even parts because of fear of violating a federal gun law.
          EFI, LLC - 07/C2 in Inwood, WV

          Tank Vest - Molle Vest for Your Dual-Sport Gas Tank

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          • #6
            GetBulletsandBrass
            Member
            • Jul 2009
            • 376

            If the other shop is making receivers they will need an 07 and if they are doing them for your business, you need to get a variance filed with the ATF prior to having any done. Everything else is just accessories and parts.
            Adam

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