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Clarify

Resolving regulatory ambiguity to provide licensees, applicants, and the public with clear, consistent, and actionable guidance.

Contents

 

06P: Firearm Activities in Foreign Trade Zones, Customs-Bonded Warehouses - NPRM

ATF is proposing to amend the definition of "importation" in its Gun Control Act (GCA) and National Firearms Act (NFA) regulations to create a parallel exclusion from import requirements for items brought into Customs Bonded Warehouses (CBWs), matching the exclusion that already exists for Foreign Trade Zones (FTZs). The proposal also removes a restriction that currently limits permissible Federal Firearms Licensees (FFL) activities in FTZs and CBWs to storage only, expanding the range of lawful activities FFLs may conduct on items held in these facilities. Together, these changes reduce regulatory ambiguity for importers and licensees operating within international trade environments.

09P: Importing Dual-Use Frames, Receivers, or Barrels - NPRM

ATF is proposing to clarify that Federal Firearms Licensees may lawfully import firearm barrels and frames/receivers capable of being used on both sporting and non-sporting firearms provided that an identified sporting configuration for the barrel or frame/receiver exists at the time of importation. The proposed rule also clarifies that once lawfully imported, a dual-use barrel or frame/receiver may be incorporated into the assembly of a sporting, non-sporting, or NFA-regulated firearm, subject to compliance with all other applicable federal firearms laws.

10P: Importing Training Rounds - NPRM

ATF is proposing to formally clarify in regulation that ”training rounds” — including inert, marking, or simulated-projectile products used for training purposes — do not meet the statutory definition of "ammunition" under the Gun Control Act (GCA) and are therefore not regulated under the GCA or the Arms Export Control Act provided the round is not for a firearm. This codification provides regulatory certainty for importers, manufacturers, and law enforcement suppliers who produce, acquire, or distribute these products.

16P: Converting Temporary to Permanent Imports for Defense Articles - NPRM

ATF is proposing to create a formal administrative process through which a firearms importer may convert a temporarily imported firearm to permanent import status by submitting an ATF Form 6 application when a temporary import authorization has expired or is otherwise no longer operative. Under current regulations, importers whose temporary import authorization expires must re-export, permanently reimport, or destroy the firearm — options that impose significant cost and logistical burden. The proposed rule fills this regulatory gap with a streamlined conversion pathway while maintaining all applicable import controls.

17P: Allowing Makers to Adopt Certain Markings for National Firearms Act - NPRM

ATF is proposing to allow individuals who make National Firearms Act (NFA) firearms by altering existing firearms to adopt markings already applied by the original manufacturer rather than applying additional, redundant markings. Because the original importer and manufacturer’s serial number and markings are already required by statute and regulation, this proposal eliminates a duplicative regulatory requirement while ensuring NFA marking requirements are satisfied. ATF has previously accommodated this practice through individual variances; this proposed rule codifies that accommodation into regulation to provide consistent, clear guidance across the industry.

23P: Clarifying Delivery to a Common or Contract Carrier When Transporting Firearms - NPRM

ATF is proposing to clarify that, for purposes of the Gun Control Act’s  provisions governing the delivery of firearms and ammunition to common or contract carriers, a person traveling aboard a common or contract carrier while personally maintaining direct control over a firearm or ammunition does not constitute "delivery" of that firearm or ammunition to the carrier. This clarification addresses longstanding regulatory ambiguity regarding the obligations of law-abiding travelers who retain physical possession of a firearm during common carrier travel.

24P: Revising Definitions of “Adjudicated as a Mental Defective” and “Committed to a Mental Institution” - NPRM

ATF is proposing to modernize the regulatory definition of “mental defective” — the term used in the Gun Control Act to identify a category of persons prohibited from possessing firearms — to reflect current medical and legal standards. The proposed rule would refine the term “mental defective,” associating it with “intellectually disabled” and clarify that a person receiving assistance in only one functional area (such as financial management) would not, on that basis alone, be considered prohibited under this definition. The proposal also clarifies existing prohibitions. Specifically, individuals committed to a mental institution resulting from a determination that an individual is a danger to themselves or others or is found not guilty by reason of insanity, properly fall within the definition of “committed to a mental institution,” and not within the definition of “mental defective.”

25P: Clarifying Exceptions to the Brady Act Background Check Requirement - NPRM

ATF is proposing to clarify the regulatory standards that govern when a state-issued firearms permit qualifies as an alternative to a National Instant Criminal Background Check System (NICS) check under the Brady Handgun Violence Prevention Act. The proposed rule makes targeted regulatory adjustments to require confirmation that the state permit is both valid and unexpired and that the language of the state statute conforms with certain requirements established by Congress. The proposed rule provides clearer guidance for Federal Firearms Licensees operating in states where such permits are recognized.

33P: Selecting Biological Sex on ATF Forms  - NPRM

ATF is proposing to amend its regulations to clarify that, in response to questions about sex on ATF forms, individuals should select their biological sex. This refers to the individual’s immutable biological classification as either male or female and does not include the concept of gender identity. These are clarifying amendments to align ATF’s regulatory forms with the President’s signed Executive Order 14168, Defending Women From Gender Ideology Extremism and Restoring Biological Truth to the Federal Government and do not alter any substantive eligibility criteria.

36P: Definition of Business Premises - NPRM

ATF is proposing to clarify the regulatory definition of ‘business premises’ for Federal Firearms Licensees (FFLs) to explicitly include properties that adjoin each other or that are adjacent to each other and share a common parking lot, sidewalk, or road. This clarification is intended to resolve regulatory ambiguity for licensees whose operations span multiple adjacent buildings or parcels and to provide a consistent, clear standard for FFL licensing determinations.

41P: Firearms Transactions and Straw Purchases - NPRM

ATF is proposing to amend its regulations to provide greater regulatory clarity around the federal prohibition on straw purchases. A straw purchase effectively hides the identity of the actual purchaser/ultimate recipient of the firearm and circumvents the regulatory requirements for a firearm transfer by forgoing background checks and impeding the ability of law enforcement to trace guns involved in the commission of a crime to the true purchaser/ultimate recipient. The proposed rule is intended to provide clearer guidance for licensees, including which transactions are not considered straw purchases, thereby supporting enforcement efforts against true straw purchases. 

47P: Creating a Definition of “Willfully” for Firearms Violations - NPRM

ATF is proposing to formally define the term “willfully” in its implementing regulations as it applies to violations of the Gun Control Act, specifically in the context of ATF’s authority to suspend or revoke a Federal Firearms Licensee (FFL) license or impose civil penalties. The proposed definition would implement the standard established by the U.S. Supreme Court in Bryan v. United States, under which a person acts “willfully” when they know their conduct is unlawful, even if unaware of the specific statutory provision being violated.

Last Updated: April 29, 2026

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