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.

No FFL needed for uppers.

MFG is generally adding value before a sale.

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.

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.

Double post. Damn smart phone

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

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.

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.

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