Quoted:


I don't see why it wouldn't be ok.

U.S. Department of Justice


Bureau of Alcohol, Tobacco,


Firearms and Explosives


Firearms Technology Branch


August 15, 2008


Martinsburg, West Virginia 25405


www.atf.gov





Manufacturing of Firearms





Below are examples of operations performed on firearms and guidance as to


whether or not such operations would be considered manufacturing under the


Gun Control Act (GCA). These examples do not address the question of whether


the operations are considered manufacturing for purposes of determining


excise tax. Any questions concerning the payment of excise tax should be


directed to the Alcohol and Tobacco Tax and Trade Bureau, U.S. Department of


the Treasury.





Generally, a person should obtain a license as a manufacturer of firearms if


the person:





1) is performing operations that create firearms or alter firearms (in the


case of alterations, the work is not being performed at the request of


customers, rather the person who is altering the firearms is purchasing them


making the changes, and then reselling them);


2) is performing the operations as a regular course of business or trade;


and


3) is performing the operations for the purpose of sale or distribution of


the firearms.





1. A company produces a quantity of firearm frames or receivers for sale


to customers who will assemble firearms. The company is engaged in the


business of manufacturing firearms and should be licensed as a manufacturer


of firearms.





2. A company produces frames or receivers for another company that


assembles and sells the firearms. Both companies are engaged in the


business of manufacturing firearms,


and each should be licensed as a manufacturer of firearms.





3. A company provides frames to a subcontractor company that performs


machining operations on the frames and returns the frames to the original


company that assembles and sells the completed firearms. Both companies are


engaged in the business of manufacturing firearms and should be licensed as


manufacturers of firearms.





4. A company produces barrels for firearms and sells the barrels to


another company that assembles and sells complete firearms. Because barrels


are not firearms, the company that manufactures the barrels is not a


manufacturer of firearms. The company that assembles and sells the firearms


should be licensed as a manufacturer of firearms.





5. A company receives firearm frames from individual customers, attaches


stocks and barrels, and returns the firearms to the customers for the


customers’ personal use. The operations performed on the firearms were not


for the purpose of sale or distribution. The company should be licensed as a


dealer or gunsmith, not as a manufacturer of firearms.





6. A company acquires one receiver, assembles one firearm, and sells the


firearm. The company is not manufacturing firearms as a regular course of


trade or business and is not engaged in the business of manufacturing


firearms. This company does not need to be licensed as a manufacturer.





7. An individual acquires frames or receivers and assembles firearms for


his or her personal use, not for sale or distribution. The individual is


not manufacturing firearms for sale or distribution and is not required to


be a licensed manufacturer.





8. A gunsmith regularly buys military-type firearms, Mausers, etc., and


sporterizes” them for resale. The gunsmith is in the business of


manufacturing firearms and should be licensed as a manufacturer.





9. A gunsmith buys semiautomatic pistols and modifies the slides to


accept a new style of sights. The sights are not usually sold with these


firearms and do not attach to the existing mounting openings. The gunsmith


offers these firearms for sale. This would be considered the manufacturing


of firearms, and the gunsmith should be licensed as a manufacturer.





10. A gunsmith buys government model pistols and installs "drop-in”


precision trigger parts or other "drop-in parts” for the purpose of resale.


This would be considered the manufacturing of firearms, as the gunsmith is


purchasing the firearms, modifying the firearms, and selling them. The


gunsmith should be licensed as a manufacturer.





11. A gunsmith buys surplus military rifles, bends the bolts to accept a


scope, and then drills the receivers for a scope base. The gunsmith offers


these firearms for sale. This would be considered the manufacturing of


firearms, and the gunsmith should be licensed as a manufacturer.





12. A gunsmith buys surplus military rifles or pistols and removes the


stocks, adds new stocks or pistol grips, cleans the firearms, then sends the


firearms to a separate contractor for bluing. These firearms are then sold


to the public. This would be considered manufacturing of firearms, and the


gunsmith should be licensed as a manufacturer.





13. A company purchases surplus firearms, cleans the firearms, then


offers them for sale to the public. The company does not need to be


licensed as a manufacturer.





14. A company produces firearms or firearm receivers and sends the
firearm/receivers out for colorizing (bluing, camouflaging, phosphating,
or plating) and/or heat treating. Do the companies performing the
colorization and/or heat treating need to be licensed as manufacturers,
and are the companies required to place their markings on the firearm?
ATF has determined that both colorization and heat treating of firearms
are manufacturing processes. The companies performing the processes are
required to be licensed as manufacturers. If the companies providing
colorization and/or heat treating have not received variances to adopt
the original manufacturer’s markings, they would be required to place
their own markings on any firearm on which they perform the
manufacturing process of colorization and/or heat treating.

Quoted:


Absolutely legal if the lower is already theirs.