Are you thinking about or already engaged in manufacturing NFA firearms?  If so, you’ll want to be sure that you keep by your side a copy of ATF publication 5320.8, Chapter 7.  This publication is the ATF “National Firearms Act Handbook” and Chapter 7 sets out 10-pages of requirements, including the federal departments and agencies responsible for licensing and oversight, as well as the forms required to undertake the process.  For your quick reference, we’ve uploaded it to the Orchid Advisors on-line research library. In this blog, we’ll highlight a few key points, including a couple that are not as obvious as one might expect. To get to the point of manufacture of National Firearms Act (“NFA”) firearms, you must first apply for and obtain your Gun Control Act (GCA) manufacturer’s license.  In other words, all manufacturers of all types of firearms must first have a GCA manufacturer’s license, which we might think of as a general or standard manufacturing license.  The NFA manufacturer’s license is then a second, specialty designation.  These licenses require payment of fees and have a limited duration (can be renewed).  Licensing is handled through the Bureau of Alcohol, Tobacco, Firearms, and Explosive Devices (“ATF”). If you’re not sure whether your firearm would classify as an NFA firearm, you can submit a request for classification in advance of manufacturing.  The request goes in to the ATF’s Firearms Technology Branch, and the response will be in the form of a letter ruling.  “Letter rulings” are available for a variety of topics and are written clarifications that facilitate business decisions with input from the ATF. Additional paperwork flows through the federal Department of State, pertaining to the Arms Export Control Act (AECA).  This is one of those non-intuitive provisions.  Whether or not you intend to or do export firearms or other defense articles itemized on the “US Munitions List,” all firearms manufacturers must register with the State Department’s Directorate of Defense Trade Controls. As with all manufacturers of firearms, there is a reporting requirement, specifically ATF Form 2.  This form includes data from date of manufacture to firearm type, model, barrel length, overall length, caliber, gauge/size, serial numbers and other identifying marks, and storage location.  Another detail to note is that the modification of an existing firearm into an NFA firearm requires reporting also of the original manufacturer or importer name and address.  Reactivation of an unserviceable NFA firearm is considered to be the manufacture of an NFA firearm.