The Ups and Downs of Federal Firearms Licensees (1975-2012)

Whether you are manufacturing, importing, exporting dealing, gunsmithing, or collecting firearms and ammunition, chances are that you are required to register with th eATF to become a “Federal Firearms Licensee” (FFL).  As of year-end 2012

[J1] , there were more than 130,000 FFLs. The current total as per the March 2014 release is 139,889.  FFLs are broken down into nine types and assigned numbers.  So, for example, an FFL-06 is a manufacturer of ammunition, while an FFL-07 is a manufacturer of firearms.  (Note that the numbers are 1-3 and 6-11; there are no “04” or “05” types.)

Here is a 2012 breakdown of FFLs by types and numbers currently issued:

FFL-01 Dealers and gunsmiths 50,848 FFL-02 Pawnbrokers 7,426 FFL-03  Collectors 61,885 FFL-06 Manufacturer of ammunition 2,044 FFL-07  Manufacturer of firearms 7,423 FFL-08  Importer 848 FFL-09  Destructive device – dealer 52 FFL-10  Destructive device – manufacturer 261 FFL-11  Destructive device – importer 169

Over the years since 1975, there have been some significant comparisons of highs and lows to the current FFLs of each type.  For example, back in 1992, there were 248,155[J1]  dealers and gunsmiths with FFL-01 licenses (See page 18 of the 2013 ATF Report).  By comparison, the number of manufacturers of firearms has steadily risen from 364 back in 1975 to its 2012 high of 7,423.

If you are an FFL, one resource available to you is the “FFL Newsletter” published by the ATF.  Here’s the ATF Newsletter index, dating back to 1979.  What’s helpful about the Newsletters is that the ATF covers both the legal updates and the practical updates. This is one of the few ways ATF communicates directly with the firearms industry.  They deem the topics enclosed in these newsletters important, and so should you! When it receives a sufficient number of questions, comments, or complaints, it includes commentary in the Newsletter.  In some instances, the ATF emphasizes that the article has the weight of an amendment to a prior ATF Ruling, regulation, or other governing provision.

Whether you are a new FFL or have been one for decades, it’s not a bad idea to become familiar with the ATF website, reports, and newsletters. Day-to-day operations may keep you busy, but consistent use of these materials will help you to be ready for your ATF audit – inevitability for all FFLs, regardless your type.

Orchid Advisors provides electronic newsletter (“Advisory and Alert”) and blogs for general informational purposes only. It should not be considered a formal or informal interpretation of law. It is not intended as professional counsel, should not be considered legal advice and should not be used as such.