In a new open letter posted today (dated March 22, 2022), the ATF has determined some “forced reset triggers” (FRTs) are “firearms” and “machineguns” as defined in the NFA and GCA.

The ATF claims the subject FRTs do not require shooters to pull and subsequently release the trigger to fire a second shot, instead utilizing the firing cycle to eliminate the need for the shooter to release the trigger before a second shot is fired. Accordingly, the ATF’s position is that any FRT that allows a firearm to automatically expel more than one shot with a single, continuous pull of the trigger is a “machinegun.”

Both the NFA and GCA define “machinegun” as any weapon which shoots, is designed to shoot, or can be readily restored to shoot, automatically more than one shot, without manual reloading, by a single function of the trigger. The term also includes the combination of parts – including a drop-in trigger – designed and intended, for use in converting a weapon into a machinegun

Though no specific manufacturers are named in the letter, such triggers are notably sold by Rare Breed Triggers (RBT) and Wide Open Triggers – the former of which received a Cease and Desist letter from the ATF in 2021 to stop production. In return, RBT fired back with a federal lawsuit, Rare Breed Triggers, LLC v. Garland, that was dismissed shortly after.

Rare Breed Triggers Reaction
RBT President Lawrence DeMonico posted the message below on their social media following the publishing of the ATF open letter:

“The ATF alleged the FRT-15 to be a machine gun in July of 2021. We have disputed that claim in a very public manner and even sued the government over this misclassification. There is unrebutted testimony in federal court by expert witnesses supporting the fact that the FRT-15 is NOT a machine gun. We have been working very hard to prepare for and file suit again in the near future.

Our position has always been and continues to be that the FRT-15 is a perfectly legal semi-automatic trigger so of course, we do not agree with their allegation that the FRT-15 is a machine gun.”

The open letter goes on to state the ATF intends to take appropriate remedial action with respect to sellers and possessors of FRTs. Any person who violates or fails to comply with the provisions of the NFA may be fined up to $10,000 per violation and is subject to imprisonment for a term of up to 10 years, as well as any machinegun possessed or transferred in violation of the NFA is subject to seizure and forfeiture.

The ATF open letter can be read in its entirety here.

For how this letter may impact your FFL, contact Orchid’s in-house firearms law professionals for more information and to learn about our trusted legal and compliance services.