What is considered "Gunsmithing"

[DEPUTYBILL]

For FFL dealers, what would be considered as modifications to a gun you sold that would require you to be a "gunsmith"?
Example:
You sell a Sig 226 to a customer.
Are any of these modifications requiring a license from CA. DOJ/ ATF

Putting on a different set of grips
Putting on a set of night sights
Changing calibers (say a 40 to 357 Sig) just a barrel swap.
Changing the trigger
Putting a SRT kit into the gun
replacing worn springs, or parts

I guess my question is when does a FFL gun seller, became a gunsmith?

[DEPUTYBILL]

So anything you do "while he waits" is OK?

[Tyke8319]

Q: Is a license needed to engage in the business of engraving, customizing, refinishing or repairing firearms?

Yes. A person conducting such activities as a business is considered to be a gunsmith within the definition of a dealer.

[27 CFR 478.11]

27 CFR 478.11 - Meaning of terms.
(d) Gunsmith. A person who devotes time, attention, and labor to engaging in such activity as a regular course of trade or business with the principal objective of livelihood and profit, but such a term shall not include a person who makes occasional repairs of firearms or who occasionally fits special barrels, stocks, or trigger mechanisms to firearms;

However, I know o no manufactured, parts dealer, supplier, etc., that does not require an FFL in order to sell you parts (some are restricted to FFL's) unless you want to pay retail for the parts. supplies, etc.

[Tyke8319]

Here is a web site that may help further:

http://www.atf.gov/files/regulations-rulings/rulings/atf-rulings/atf-ruling-73-13.pdf

[Tallship]

I think you're asking the wrong question. As an 01 FFL holder, you are allowed to do gunsmithing. What you can't do is "manufacture", which is making changes to the gun before it's sold. So in your original question, you can do any of those things for the customer as long as you have delivered the gun to him and he has taken it out of your shop.