Manufacturer's License
There are a bunch of posts on the Gen. Discussion forum from and about Joe's Custom Guns and his 10/22 conversions. That got me to thinking that I believe I read somewhere that if I start with a bunch of parts and put them together to sell, I need a federal manufacturer's license. IIRC, it didn't take much--just changing a barrel and stock on a 98 Mauser to sell would do it. Anyone know the rules on that?
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Not a lawyer... and waiting for Mark to chime in ... BUT ...
You need a manufactures license to actually make the receivers. If you are doing custom work (like Joe) on existing receivers, you just need the FFL to be engaged in the business of selling guns and such. If you had a local shop, and I could bring in a bare receiver, wait a few hours while you slap some parts on it, and go home, you don't even need the FFL since the owner is there. But like gunsmithing, if you take the receiver into possession for more than a few hours, you need the FFL and to enter the item into your bound books.0 -
I believe that Joe assembles SBRs, so he needs a manufacturers license to do that. That would also permit him to assemble AOWs.
Neal0 -
"they must also have a fed ammo mfg license of some type.'.........yes that is so, if you sell 'reloads' you need an ammo mgf. license.
also if you do a lot of rebuilding/ finishing you need a mgf. license (think powder coating 100's of ar lowers). My atf contact told me anything over 100/year (fwiw)
"Think about it. If a gunsmith worked on 101 guns in a year your example would say he needs to be a manufacturer."............no, that isn't what I said. If you build (for sale) or do commercial finishing (above noted ar's) of over 100 firearms per year they want you to have a 07 ffl (and pay the excise tax). I the mid 1990's Kimber bought 1000's of m-96 swedish rifles, restocked and rebarreled them. they needed a mgf. license to do that.0 -
Mike is correct. An old neighbor used to load for all the local sheriff's and city police, he had a reloading license
I am a Washington state Hunters Safety instructor, the only way we can let our students shoot reloads is if they come from a licensed reloader.
W.D.0 -
A fairly concise rundown on FFLS is HERE: http://en.wikipedia.org/wiki/Federal_Firearms_License
It is not all inclusive, but does hit the high points fairly well.
If you are making ordinary firearms to SELL- you need an 07 FFL. You will also have to register with the State Dept- and last time I looked, the ATF wants an excise tax on each gun made under the license. I think failure to pay that tax is what put Ithaca out of business.
If you are making ammo, OR components for ammo, to SELL- you need a 10 FFL- and register with State Dept.0 -
quote:Originally posted by MIKE WISKEY
also if you do a lot of rebuilding/ finishing you need a mgf. license (think powder coating 100's of ar lowers). My atf contact told me anything over 100/year (fwiw)
Never believe anything an agent tells you. Remember it is Alcohol Tobacco then Firearms. Most, ok a lot, of atf agents never even do any gun work. They are too busy dealing with winery's and distilleries to even think about gun laws.
Think about it. If a gunsmith worked on 101 guns in a year your example would say he needs to be a manufacturer.
Well I am sure Mike is an expert. Things have also changed from the time I had my license. Back then you could refinish as many guns as people would pay for and never need anything more then an FFL. you could even rebarrel and restock as many old guns as you could get paid for. No one ever said you needed a manufactures license to do that then. I guess now they need the $ to pay for for votes from the 47%.
Also if you look at the faq page from the feds http://www.atf.gov/firearms/faq/manufacturers.html#dealer-gunsmithing , you will see some people do need a manufacturers license to upgrade guns they own and intend to sell. It all depends on who you are doing the work for, and if you are manufacturing a frame. No real firm reason why you would or would not need a manufacturing license any more. Oh for the good ol' days.0 -
quote:Originally posted by goodgunparts
Remember it is Alcohol Tobacco then Firearms. Most, ok a lot, of atf agents never even do any gun work. They are too busy dealing with winery's and distilleries to even think about gun laws.Not to hijack the thread, but...
Their name was changed to Bureau of Alcohol, Tobacco, Firearms and Explosives (BATFE) 10 years or so ago when they were moved over to the Dept. of Justice.
Firearms and explosives became their primary focus, with their alcohol and tobacco duties now limited to illegal production/smuggling investigations instead of industry regulation.
At the same time the Alcohol and Tobacco Tax and Trade Bureau (TTB) was created under the Dept. of Treasury. This is the agency that deals with the wineries and distilleries.0 -
I know this is a few year old thread but thought it would help me if I replied to it and asked for clarification on rules for FFL 07 Manufacturers. The ATF seems to be asking questions about DOJ ITAR Registration which is annual and cost $2,250 per year.
If you have an 07 and are just assembling parts the ATF considers that manufacturing!
Does anyone have a handle on this? What if a FFL 01 was customizing a gun frame up for a customer then he would be a Manufacturer also (or not)?
How many parts can you add or replace before you move across from gunsmith to manufacturer?!?!!??[?]0 -
Plow through these and you'll have a better understanding of the terms and the regulations. NOTHING is black and white, so don't expect to find definitive answers without submitting specific questions to the BATF and receiving their reply in writing...and those replies don't always hold up in court!
https://www.atf.gov/file/82791/download
https://www.atf.gov/file/11711/download
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