Federal firearms licensees must comply with a number of federal laws: the Gun Control Act (GCA), National Firearms Act (NFA) and Arms Export Control Act (AECA). They must also comply with ATF regulations found in Parts 447, 478 and 479 under Title 27 of the Code of Federal Regulations (CFR).
However, licensees can ask ATF for an alternate method or procedure (known as a variance request) to fulfill their regulatory obligations. This process is set forth in 27 CFR 478.22 and 27 CFR 479.26.
ATF can choose to approve a variance from regulatory requirements in Parts 447, 478 and 479, but cannot approve a variance from statutory requirements in the GCA, NFA and AECA.
Types of variances
Certain types of variance requests are so common that ATF has created special forms or guidance to make the process easier. If your request falls into one of these categories, be sure to follow the specific instructions for that type of request.
The most common variance request is to mark manufactured or imported firearms with alternative identifying information. ATF has created a special form to help licensees apply for marking variances that are reasonable and won’t hinder the effective administration of the law.
The Firearms and Ammunition Technology Division (FATD) is responsible for analyzing and responding to marking variance requests.
Digital storage of Form 4473
To store your completed Form 4473s electronically, you need to submit a variance request that addresses ATF’s minimum standards for digital storage systems.
All other variances
The Firearms Industry Programs Branch (FIPB) is responsible for analyzing and responding to all other variance requests for firearms. If you have any questions about this process, please contact FIPB by email at FIPB@atf.gov or by phone at (202) 648-7190.
Prepare your request
Your variance request should include:
- Your name
- Your company name (if any)
- Your full 15-digit federal firearm licensee (FFL) number
- Which regulation(s) you want to deviate from
- Your proposed alternate method or procedure
- Why you wish to deviate from the regulation(s)
Make sure your request is signed and dated by a responsible person listed on the license.
Submit your request
Send your request as a signed PDF attachment to FIPB by email at FIPB@atf.gov.
You may also submit your request in writing to:
Bureau of Alcohol, Tobacco, Firearms and Explosives
Firearms Industry Programs Branch
99 New York Avenue NE, Mail Stop 6.N-518
Washington, DC 20226
Check on the status of your request
Processing times can vary widely depending on the complexity of the request. You can email or call FIPB at (202) 648-7190 to check on the status of your request.