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Posted: 1/20/2013 7:00:00 PM EDT
I am looking into possibly manufacturing 80% lowers, I have a shop and a cnc mill for automotive parts. Can 80% lowers be manufactured for resale without an FFL? I am still considering an 07/02 but I have more research into insurance and such before that will happen.
Link Posted: 1/20/2013 7:03:30 PM EDT
You need a letter from the ATF saying that the paperweight is not a gun. A sample of your product has to be mailed in to the ATF after six months to a year, they will respond with the answer. You will still need a FFL and 07.

Link Posted: 1/20/2013 7:30:39 PM EDT
I believe which 80% is done may be specified.

At one time the fire control group machining could be done without an holes for the pins, but now the FCG part of an 80% cannot be machined by the manufacturer.

Link Posted: 1/20/2013 7:48:39 PM EDT
No, you cannot manufacture 80% lowers and sell them without an FFL. There is no If, Ands or Buts about it. You can't even give them away, and even leaving them to my kids in my will is questionable. Think along the same lines as to why most guys justify having a trust for their Class III stuff. Check out CNC Guns for a lot more info. He has started selling some of his proprietary lowers (AR45) so if what you are interested in is selling because you have the ability to machine for yourself, then he has a great forum for those kinds of questions.
Link Posted: 1/20/2013 8:20:26 PM EDT

Originally Posted By jclaypool:
No, you cannot manufacture 80% lowers and sell them without an FFL. There is no If, Ands or Buts about it. You can't even give them away, and even leaving them to my kids in my will is questionable. Think along the same lines as to why most guys justify having a trust for their Class III stuff. Check out CNC Guns for a lot more info. He has started selling some of his proprietary lowers (AR45) so if what you are interested in is selling because you have the ability to machine for yourself, then he has a great forum for those kinds of questions.

Why not? If the ATF has documented that what you are selling is NOT/NOT a gun. Then why do you need a FFL?

-Jim
Link Posted: 1/20/2013 8:53:07 PM EDT
[Last Edit: 1/20/2013 9:00:37 PM EDT by DasRonin]
Are you speaking as a licensee or just "shooting from the hip" with your comments?

SO... WRONG!

I have bought 80% and 30% lowers and they are mailed right to my door!

If an ffl was required that could not happen!

From one of the 80% dealers:

"Our 80% lowers and rifle kits are not considered to be firearms by the ATF. As such, you do not need to purchase them through a firearms dealer. "

"We provide a "paper weight" forging that can be finished to build an AR15 (style) lower receiver. The machining is approximately 80% complete. "


You CANNOT complete an 80% lower and sell them. ATF also "recommends" if you complete an 80% lower you mark it uniquly so that if it is stolen it can be identified.

Originally Posted By jclaypool:
No, you cannot manufacture 80% lowers and sell them without an FFL. There is no If, Ands or Buts about it. You can't even give them away, and even leaving them to my kids in my will is questionable. Think along the same lines as to why most guys justify having a trust for their Class III stuff. Check out CNC Guns for a lot more info. He has started selling some of his proprietary lowers (AR45) so if what you are interested in is selling because you have the ability to machine for yourself, then he has a great forum for those kinds of questions.


Link Posted: 1/20/2013 8:57:26 PM EDT
Originally Posted By jclaypool:
No, you cannot manufacture 80% lowers and sell them without an FFL. There is no If, Ands or Buts about it. You can't even give them away, and even leaving them to my kids in my will is questionable. Think along the same lines as to why most guys justify having a trust for their Class III stuff. Check out CNC Guns for a lot more info. He has started selling some of his proprietary lowers (AR45) so if what you are interested in is selling because you have the ability to machine for yourself, then he has a great forum for those kinds of questions.


Oh, lord.
Link Posted: 1/20/2013 10:55:00 PM EDT
[Last Edit: 1/20/2013 10:56:20 PM EDT by jclaypool]
The OP was asking if he could manufacture them and sell them. I was assuming he meant milling AR 80%ers into fully stripped lowers. I said no.

Once again the fabulous personalities of ARFCOM raise their almighty doucherific heads.
Link Posted: 1/21/2013 2:30:35 AM EDT
If the OP wants to know if he can produce forgings that have 80% of the machining done, say go from 0% forging to 80% of the machining, then as long as those 80% forgings are endorsed by ATF as being paper weights and not firearms (it often depends on where that 80% machining has been done), then yes, you're not manufacturing anything that requires a manufacturer's FFL (and the SOT that goes with it).

If the OP's question is about doing something WITH an 80% forging that makes it more than 80% finished, that's another matter,
Link Posted: 1/21/2013 3:54:37 AM EDT
I think you would want to apply for a FFL . I could see the ATF being up your ass if you didn't . Though it's not considered a firearm there are some rules to making them.

I think you also need a letter from them stating your paperweight is not a firearm.
Link Posted: 1/21/2013 4:01:23 AM EDT
I also think that is more trouble then it is worth making 80% lowers. Unless you made 100% stripped lowers and had license to do so as well.
That 80 percent lower thing is a touchy subject.
Just my opinion .
Link Posted: 1/21/2013 4:23:34 AM EDT
Are they going to be from forgings or bar stock?
Link Posted: 1/21/2013 5:54:36 AM EDT
I am referring to going from a blank forging or a chunk of 7075 to what the aft considers 80%.
Link Posted: 1/21/2013 1:44:49 PM EDT
Originally Posted By Boosted3s:
I am referring to going from a blank forging or a chunk of 7075 to what the aft considers 80%.


First, research what ATF considers 80% of the machining process and then design your product. Then get a written opinion from ATF that your design meets their requirements for an 80% lower. With that, go for it.
Link Posted: 1/21/2013 11:40:07 PM EDT
One additional feature I would like to see completed on 80% lowers is the trigger slot milled out as a shallow pocket. Then all that would need to be finished is the FCG pocket and a few holes.

Link Posted: 1/22/2013 6:11:30 AM EDT
Originally Posted By shrikefan:
One additional feature I would like to see completed on 80% lowers is the trigger slot milled out as a shallow pocket. Then all that would need to be finished is the FCG pocket and a few holes.



Yes, I agree that this would be nice on a forging.
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