The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) announced last week a ruling that will affect any person licensed as a dealer-gunsmith performing certain processing or finishing on firearms owned and marked by a federally licensed firearms manufacturer.
The ruling will also affect licensed manufacturers and licensed importers who have contracts with specialized gunsmiths to perform a variety of processes involved in producing firearms.
The ruling holds that licensed firearms dealer-gunsmiths are not engaged in a manufacturing business, and are not required to hold a manufacturers license, under certain specified conditions.
The ruling was issued to address modern firearms manufacturing processes, which often involve a number of contractors other than the manufacturer whose name is marked on the firearm.
The ruling was issued to address modern firearms manufacturing processes, which often involve a number of contractors
Under the ruling, licensed dealers may perform manufacturing services if (1) the firearms are not owned by the licensed dealer-gunsmith; (2) the licensed dealer-gunsmith returns the firearms to the licensed manufacturer or licensed importer upon completion of the manufacturing process and does not sell or distribute the firearms to any other person; and (3) the firearms were properly identified and marked by the importer or manufacturer in accordance with the law and regulations.
ATF Ruling 2010-10 clarifies concerns and addresses questions about activities such as bluing, anodizing, powder-coating, plating, polishing, heat and chemical treating that have caused confusion over activities requiring a federal firearms manufacturers license, firearms marking requirements, and firearms record keeping requirements.