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12/6/2019 7:27:02 PM
Posted: 12/11/2013 1:09:20 PM EST
Hi everybody,

I'm in the process of getting my FFL. Mostly to do transfers. But I did have a few questions.

I understand with ATF that taking a receiver and building a fully function rifles constitutes an 07 license. What about half a job?

So someone who is a 01 FFL, can they build and sell AR uppers? are they manufacturing?

What about someone who takes a stripped lower and builds a completed lower. Is that manufacturing?

Can you point to the rules for either one? The FAQ talks about completed firearms.

Also, where would you recommend I look for distributors for parts, receivers, powder, ammunition, Etc.

I'm in the DFW area if it makes any difference.

Thanks in advance.
Link Posted: 12/11/2013 1:31:06 PM EST
No FFL needed for uppers.

MFG is generally adding value before a sale.
Link Posted: 12/11/2013 3:43:30 PM EST
Taking an item and doing work on it then reselling it is a manufacturing activity. If the thing you are selling is a firearm, you need a manufacturer FFL.

Building up and selling AR uppers is a manufacturing activity, but AR uppers are not firearms so no problem there.

Building up and selling lowers does involve the firearm receiver though, so would require the mfg FFL even if you don't make complete functioning rifles.
Link Posted: 12/11/2013 5:08:18 PM EST
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By RenegadeX:
No FFL needed for uppers.

MFG is generally adding value before a sale.
View Quote

Would building AR uppers be considered manufacturing under ITAR? (and requiring registration with the State Department)
Link Posted: 12/11/2013 5:24:15 PM EST
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By DogtownTom:

Would building AR uppers be considered manufacturing under ITAR? (and requiring registration with the State Department)
View Quote View All Quotes
View All Quotes
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By DogtownTom:
Originally Posted By RenegadeX:
No FFL needed for uppers.

MFG is generally adding value before a sale.

Would building AR uppers be considered manufacturing under ITAR? (and requiring registration with the State Department)

Very good question. I'm not sure, but I would imagine yes.
Link Posted: 12/11/2013 5:25:29 PM EST
[Last Edit: 12/11/2013 5:26:31 PM EST by TnMike]
Double post. Damn smart phone
Link Posted: 12/11/2013 5:32:34 PM EST
[Last Edit: 12/11/2013 5:36:24 PM EST by RenegadeX]
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By DogtownTom:

Would building AR uppers be considered manufacturing under ITAR? (and requiring registration with the State Department)
View Quote View All Quotes
View All Quotes
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By DogtownTom:
Originally Posted By RenegadeX:
No FFL needed for uppers.

MFG is generally adding value before a sale.

Would building AR uppers be considered manufacturing under ITAR? (and requiring registration with the State Department)



Yes.

CATEGORY I—FIREARMS, CLOSE ASSAULT WEAPONS AND COMBAT SHOTGUNS

(a) Nonautomatic and semi-automatic firearms to caliber .50 inclusive (12.7 mm).

...

(g) Barrels, cylinders, receivers (frames) or complete breech mechanisms for the articles in paragraphs (a) through (d) of this category.

(h) Components, parts, accessories and attachmentsfor the articles in paragraphs (a) through (g) of this category
Link Posted: 12/11/2013 6:27:24 PM EST
[Last Edit: 12/11/2013 6:28:57 PM EST by teeli]
but as long as you transfer/sell the stripped lower, you can build it after as a gunsmith service without an 07.
edit for clarity:
as long as the lower is sold, they can have you assemble the parts in it for them for a fee, as you aren't manufacturing a firearm, you are working on one that you recently sold.
however assembling a lower "other" then selling it after would be construed as manufacture.
Link Posted: 12/12/2013 7:00:52 AM EST
So as an 01 FFL you can only be in business to sell "accessories" or transfer firearms or "gunsmithing"

Which brings me the the second part of my barrage of questions.

Originally Posted By ggenovez:
Also, where would you recommend I look for distributors for parts, receivers, powder, ammunition, Etc.

I'm in the DFW area if it makes any difference.

Thanks in advance.
View Quote

Link Posted: 12/12/2013 7:33:31 AM EST
Discussion ForumsJump to Quoted PostQuote History
Originally Posted By ggenovez:
So as an 01 FFL you can only be in business to sell "accessories" or transfer firearms or "gunsmithing"

Which brings me the the second part of my barrage of questions.


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Discussion ForumsJump to Quoted PostQuote History
Originally Posted By ggenovez:
So as an 01 FFL you can only be in business to sell "accessories" or transfer firearms or "gunsmithing"

Which brings me the the second part of my barrage of questions.

Originally Posted By ggenovez:
Also, where would you recommend I look for distributors for parts, receivers, powder, ammunition, Etc.

I'm in the DFW area if it makes any difference.

Thanks in advance.



Whoever makes those items will provide you with a list of distributors.
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