Here's  the question, I am a 01-03sot am interested in Gemtech intergrally suppressed barrels for the 10-22.  Just started as a 03 been a regular ffl with a storefront for 19 years. How can I market the Gemtech barrel ? If I put it on a gun would  I would need to be a 07 manufacture ? If I put it on a customers gun do I have to be a 07manufacture. Do my customers have to do a form 1 since they are changing the barrel? NEED SOME INSIGHT?????

If you're buying the integral barrels, installing them to guns in your inventory, and selling the result, that requires a manufacturing license.

If you're selling the integral barrels to customers, and/or installing them to the customer's already-owned 10/22s, then that's just a bit of gunsmithing done under your 01 FFL.

Installing an integrally suppressed barrel to a 10/22 does nothing to the gun's status as a regular title 1 firearm, unless the integral barrel winds up taking the barrel length under 16", at which point it's making an SBR in addition to installing a suppressor.  In that case, you would once again have to have a manufacturing license - unless the customers all Form 1 their SBRs in addition to buying a Form 4 integral suppressed barrel from you, and have you install the suppressed short barrel to their already-owned and stamped Form 1 SBR 10/22s when both stamps have come back.

The Gemtech MIST-22 is 16+ inches.

You do not need a 07 to put it on your gun for demos, nor do you need one to put it on customer guns. No form 1 needed as it is 16+ inches.

That's my thoughts do my own as a display "not for sale" and offer the barrels-suppressor's for sale but my concerns are removing the stock barrels off customers guns or ones I have already done 4473 forms on and replacing them with the gemtech  barrels am I still good as a gunsmith ? not as a manufacturer?

If the customer owns all of the parts first you are good to go.  So don't do any work until the 4473 is done on the Title I gun and the Form 4 approved + 4473 done on the suppressor.

Quite honestly, if your customer can't change the barrel on a 10/22, themselves, I'd be worried about them. It's not like it's rocket surgery.

"Its not like its rocket surgery" nearly knocked me off my chair.

Install it on your own 10/22 and tag it "NOT FOR SALE"?
 
I dunno.



I used to work for a big sporting goods chain.


We would have a couple ARs with aftermarket rail systems, bipods, attachments and optics for the display case. We had pricing of the rifle, and then pricing for the rifle + accessories added. We were just an 01 FFL. Not sure if it was "legal". Don't think the manager didn't care all that much.