I thought I was prepared to submit my FFL application for an 01/07, but have waded into murky waters.

I have an outdoor store that sells bows, hunting supplies, and has an indoor bow range. We plan to add the guns in short order.  My plan was to get the 01/07 so we can sell guns that we have in stock and the 07 would be for assembling stripped lowers that we have purchased.  (I will NOT be making or forging our own branded lowers)

With that said, am I correct in getting the 01/07?  I have now talked to a couple FFL's and I am getting mixed feedback.  One says just get the 07 because that will allow me to manufacture AR rifles and sell in stock items..."You don't need the '01,' buddy!"   Another says that I do not need an 07 because I am not engraving or branding any of the lowers as my own. Which is it?

I have not submitted my application so I do not yet have an IOI interview.  I imagine this question will be answered then, but wanted to have my application and check correct.

Thanks in advance

If YOU are supplying the receiver, building and selling you are manufacturing. You also have to collect and pay the 10% FET per gun built every quarter to the BATFE. If you are building receivers that OTHERS are supplying you are NOT manufacturing. Just like in the custom 1911 business. Same thing.

If you Manufacture (build AR from parts the ATF says) you need a 07 and you need to mark the lowers even if someone else already marked them as you are now the manufacture in the ATFs eyes.  It is stupid!  There are ways to get marking variances but they are not setup for assemblers.

We really should push to get a lot of stuff the ATF calls manufacturing defined as not manufacturing.



To make this more clear if a customer brings in a lower and has you assemble it even with parts you source that is fine as a 01 as gunsmithing.  But if you build up lowers for sell it is manufacturing.

obigatory "don't forget the $2500 ITAR annual registration for 07 manufacturers"

FIFY

You don't need a 01 FFL as a 07 FFL covers a 01 and 06.

You need a 07 FFL if you will be assembling AR15s. For example you buy a lower and upper, and put them together. That is considered manufacturing and requires a 07 FFL. It's only considered gunsmithing if a customer asks you to do it on his lower.

ITAR registration fee of $2,250 once you start "manufacturing". Though if you already have a shop $2,250 is a non-issue. Usually homebased FFLs cry over the ITAR fees

So basically if you have an 01 you CANNOT but stripped lowers and parts kits and make and then sell complete rifles then correct? Is that what I'm understanding