ATF Ruling 2016-5 Guidance - Marking Variance for Government Defense Contractors

Answers to questions about marking variances for destructive device munitions manufactured as part of a valid United States Government (USG) contract.

Why is ATF issuing this guidance for Ruling 2016-5?

Pursuant to ATF Ruling 2016-5, how should the alternate markings be applied to satisfy the requirements of, and comply with, the existing United States Government (USG) contract?

How must the markings be applied to the destructive device munitions?

Are there any other marking requirements?

What information must be supplied to ATF prior to engaging in the manufacturing process?

What, if anything, can be done with the destructive devices that are ultimately rejected from a USG contract or are overages from a USG contract?

Does the marking variance extend to sub-contractors associated with the contract?

When is a subcontractor considered “a party” to “an existing USG contract” for purposes of ATF Ruling 2016-5?

Does the marking variance extend to any Foreign Military Sale (FMS) customers included in those DOD USG contracts?

Can the manufacturer submit additional lot numbers, if needed, as a result of lot “slippage” or a change in lot number mid-production due to unforeseen issues? If so, how should this be done?

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