ATF Ruling 2009-2
Any person who installs “drop in” replacement parts in or on existing, fully
assembled firearms does not manufacture a firearm, and does not need to be licensed as a
manufacturer under the Gun Control Act. A “drop in” replacement part is one that can be
installed in or on an existing, fully assembled firearm without drilling, cutting, or
machining. A replacement part, whether factory original or otherwise, has the same
design, function, substantially the same dimensions, and does not otherwise affect the
manner in which the weapon expels a projectile by the action of an explosive. Any person
who is licensed as a dealer, which includes a gunsmith, and who installs “drop in”
replacement parts in or on existing, fully assembled firearms as described in this ruling
does not need to be licensed as a manufacturer under the Gun Control Act. Any person
who is engaged in the business of installing “drop in” replacement parts in or on existing,
fully assembled firearms as described in this ruling must be licensed as a dealer, which
includes a gunsmith, under the Gun Control Act.