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9/2/2011 9:30:37 PM EDT
If i want to work on peoples uppers, like swapping hand guards and barrels, do i need any type of licence if i dont touch the lower?
What about pinning barrels? is that something that i need to worry about?
9/3/2011 6:03:57 AM EDT
[#1]
for friends or for hire. That is the question
9/3/2011 8:00:14 AM EDT
[#2]
for hire. and if i cant do any of it without an ffl for hire, can you do stuff for trade? or if you trade does that still make it business?
9/3/2011 8:53:14 PM EDT
[#3]
The lower receiver is the firearm.  You don't touch that/take them in without a FFL.

On uppers, they are not a firearm, and you do not need a FFL to work on them alone (why companies like Model 1 that sell built uppers and other parts that are not receivers do not need a FFL).

But on the same token, if you are going to work on upper for a businesses, you will need have a business licenses, including insurance (read someone has a problem with a barrel and you will be liable) and paying your quarterly taxes (read you start taking on upper work/advertising for such, the BATF is going to take a good look at you to make sure that you are legit, and not touching/taking in firearms with out a FFL).
9/10/2011 6:43:11 AM EDT
[#4]
I asked an ATF agent the same question... He summed it up like this. If you order an upper for a customer and sell it to him our right, then you don't need an FFL. If you order an upper and other parts to put on it (HGs, low pro gas block, etc) then you need a Gunsmith FFL, but you have to give the customer the parts, and they have to come back the next business day. If you add the parts that same day, you need a Manufacturers FFL because (per ATF) you altered and/or manufactured a new firearm. He suggested for me to go ahead and get the Manufacturer FFL, for peace of mind and ability to step up to actual firearms manufacturing later if I chose to. My situation may be different than yours, but I suggest contacting you regions ATF office and asking them. ATF has screwy laws, but if they tell you how to do it (get it in writing and signed) and its wrong, it's on them, not you. Good Luck!
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