On January 2nd, ATF issued its first firearms ruling of 2015. The purpose was to clarify a few points that were made in ATF Ruling 2010-10. While both rulings are centered on manufacturing operations; 2015-1 focuses on “who” is performing the operation, “what” specific operations are being conducted, and “whose” manufacturing machines are being utilized. In summary, here are a few things to note:
This ruling differs from ATF Ruling 2010-10 in that it is focused more on firearm castings that are machined to become regulated frames/receivers versus 2010-10 which pertained to firearm frames/ receivers that were already regulated but were receiving additional processes (coatings, refurbishing, etc).
A person or business that is engaged in the business of “machining, molding, casting, forging, printing, or other manufacturing process to create a firearm frame or receiver” must be licensed as a manufacturer under the GCA.This is based on two main concepts: (1) The business controls the access and use of the tools and machines involved. (2) When the frame/receiver, or completed firearm is finished and returned to the customer, it is “distributed”
A person or business cannot avoid getting a manufacturers FFL, the marking requirements, or completing the record keeping requirements by allowing “persons to perform manufacturing processes on blanks or incomplete firearms (including frames or receivers) using machinery, tools, or equipment under its dominion and control where that business controls access to, and use of, such machinery, tools, or equipment.”
This ruling is specific to firearms covered under the Gun Control Act of 1968 and does not include firearms covered under the National Firearm Act of 1934.
Click Here for the full ATF Ruling 2015-1.