Firearms Rulings

Title Description
2016-5 – Marking Variance for Government Defense Contractors (66.05 KB)

The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) authorizes an alternate method or procedure to the firearms marking requirements contained in title 27, Code of Federal Regulations (CFR), sections 478.92 and 479.102. Specifically, ATF authorizes licensed manufacturers of certain destructive device munitions that are manufactured for and transferred to the U.S. Government (USG) to mark these destructive device munitions with sequential lot numbers, provided conditions set forth in this ruling are met.

2016-4 – Electronic Transmission of Form 6A Information to CBP (55.07 KB)

ATF Ruling 2016-4 - The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) authorizes an alternate method or procedure in lieu of the method or procedure prescribed in the regulations that currently require an importer to submit to U.S. Customs and Border Protection (CBP) an original, paper copy of ATF Form 6A, Release and Receipt of Imported Firearms, Ammunition and Implements of War (Form 6A), to import firearms, ammunition, and other defense articles.

2016-3 – Consolidation of Records Required for Manufacturers (142.74 KB)

Approved alternate method or procedure for licensed firearms manufacturers to consolidate their records of manufacture or other acquisition of firearms with their separate firearms disposition records, provided all of the conditions in this ruling are met.  Supersedes Ruling 2010-8.

2016-2 – Electronic ATF Form 4473 (159.83 KB)

Approved alternate method or procedure for FFLs to use an electronic version of Form 4473, instead of the paper format, provided the conditions set forth in this ruling are met.  Supersedes ATF Rul. 2008-3.

2016-1- Requirements to Keep Firearms Records Electronically (156.2 KB)

Approved alternate method or procedure for licensed importers, licensed manufacturers, licensed dealers, and licensed collectors to maintain their firearms acquisition and disposition records electronically instead of in paper format provided the conditions set forth in this ruling are met.  Supersedes ATF Ruling 2013-5.

2015-1 - Manufacturing and Gunsmithing (69.18 KB)

Any person (including any corporation or other legal entity) engaged in the business of performing machining, molding, casting, forging, printing (additive manufacturing) or other manufacturing process to create a firearm frame or receiver, or to make a frame or receiver suitable for use as part of a "weapon … which will or is designed to or may readily be converted to expel a projectile by the action of an explosive," i.e., a "firearm," must be licensed as a manufacturer under the GCA; identify (mark) any such firearm; and maintain required manufacturer’s records. A business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements of the GCA by allowing persons to perform manufacturing processes on firearms (including frames or receivers) using machinery or equipment under its dominion and control where that business controls access to, and use of, such machinery or equipment. ATF Ruling 2010-10 is clarified.

2014-1 - Manufacturing/Inventory of Machineguns for LE and Military (48.71 KB)

A manufacturer licensed and qualified under the GCA and NFA may manufacture and maintain an inventory of machineguns for future sale to Federal, State, or local government agencies without a specific government contract or official request; provided, the machineguns are properly registered, and their subsequent transfer is conditioned upon and restricted to the sale or distribution of such weapons for the official use of Federal, State, or local government agencies. A manufacturer may deliver machineguns it has manufactured to another qualified manufacturer for any manufacturing process; provided, the first manufacturer maintains continuous dominion or control over the machineguns. A manufacturer may transfer machineguns it has manufactured for present or future sale to a Federal, State, or local government agency to another qualified manufacturer for any manufacturing processes or storage; provided, the manufacturer has a specific government contract or official written request documenting that it is an agent of the government agency requesting and authorizing such transfer. ATF Ruling 2004-2 is clarified.

2013-3 - Adopting Identification of Firearms (51.33 KB)

Approved alternate method or procedure for licensed manufacturers and importers of firearms, and makers of NFA firearms, to adopt the serial number, caliber/gauge, and/or model already identified on a firearm without seeking a marking variance, provided all of the conditions in this ruling are met. Licensed manufacturers seeking to adopt all of the required markings, including the original manufacturer’s name and place of origin, must receive an approved variance from ATF.  Supersedes ATF Ruling 75-28, and clarifies ATF Industry Circular 77-20.

2013-2 - NFA Electronic Forms (822.44 KB)

Approved alternate method or procedure for FFLs, legal entities, and government agencies to file ATF Forms 1, 2, 3, 4, 5, 9, and 10 using ATF eForms, provided all of the conditions set forth in this ruling are met.   

2013-1 - Electronic Form 6 and 6A (90.18 KB)

Approved alternate method or procedure for individuals, Federal firearms licensees, and registered importers of articles enumerated on the U.S. Munitions Import List (USMIL) to file ATF Form 6 - Part I and Form 6A electronically using ATF eForms, provided all of the conditions set forth in this ruling are met.  Supersedes ATF Rulings 2003-6 and 2010-9. 

2012-3 - AFMER Electronic Form (106.51 KB)

Approved alternate method or procedure for licensed manufacturers to submit the Annual Firearms Manufacturing and Exportation Report (AFMER), ATF Form 5300.11, electronically using ATF eForms, provided all of the conditions set forth in this ruling are met. 

2012-1 - Time Period for Marking Firearms Manufactured (127.51 KB)

Marking and recordkeeping requirements for firearm frames and receivers.

2011-4 - Pistols Configured from Rifles; Rifles Configured from Pistols (82.73 KB)

Unassembeld parts and configurations of parts of pistols, rifles, handguns or other weapons that result in a  firearm as defined under the NFA, 26 U.S.C. 5845(a)(3); 26 U.S.C. 5845(a)(3) and (a)(4); 26 U.S.C. 5845(a)(3) and (a)(4); and 26 U.S.C. 5845(a)(4).

2011-1 - Importers Consolidated Records (381.87 KB)

Approved alternate method or procedure for licensed importers to consolidate their records of importation or other acquisition of firearms and their separate firearms disposition records, provided all of the requirements stated in this ruling are met.

2010-10 - Manufacturing Operations Maybe Performed by Licensed Gunsmiths Under Certain Conditions (134.84 KB)

Any person licensed as a dealer-gunsmith who repairs, modifies, embellishes, refurbishes, or installs parts in or on firearms (frames, receivers, or otherwise) for, or on behalf of a licensed importer or manufacturer, is not required to be licensed as a manufacturer under the GCA, provided the firearms are:  (1) not owned, in whole or in part, by the dealer-gunsmith; (2) returned by the dealer-gunsmith to the importer or manufacturer upon completion of the manufacturing processes, and not sold or distributed to any person outside the manufacturing process; and (3) already properly identified/marked by the importer or manufacturer.

2010-6 - State of Residence (97.66 KB)

For the purpose of acquiring firearms under the GCA, a U.S. citizen who temporarily resides in a foreign country, but also demonstrates the intention of making a home in a particular State, is a resident of the State during the time period he or she actually resides in that State. The intention must be demonstrated to a Federal firearms licensee by presenting valid identification documents.

2010-3 - Identification of Maxim Side-Plate Receivers (181.89 KB)

The right side-plate of a Vickers/Maxim-type firearm, manufactured with its camming lobe affixed in the proper location, and without an ATF approved block that prevents installation of machinegun fire control components, is a machinegun receiver, and therefore, a machinegun as defined by the GCA and NFA. Provided it has not been disassembled into its component parts, a complete Vickers/Maxim-type machinegun that is currently registered in the National Firearms Registration and Transfer Record with its serial number located on a component part of the receiver box other than the right side-plate has been lawfully registered under the NFA and may be lawfully possessed by the registrant under 18 U.S.C. 922(o).

2010-1 - Temporary Assignment of a Firearm by an FFL to an Unlicensed Employee (19.5 KB)

Requirements for temporary assignment of a firearm by an FFL to its unlicensed employees for bona fide business purposes, where the actual custody of the firearm is transferred for a limited period of time, and where title and control of the firearm remain with the FFL; and by an FFL to its unlicensed agents, contractors, volunteers, or any other person who is not an employee of the FFL, even for bona fide business purposes. Supersedes Revenue Ruling 69-248 and modifies ATF Ruling 73-19. Industry Circular 72-23 is no longer in effect.

2009-5 - Firearms Manufacturing Activities Identification Markings of Firearms (15.96 KB)

Exception to marking requirements for licensed manufacturers who perform a manufacturing process on firearms for, or on behalf of, another licensed manufacturer, provided such firearms already have been properly marked with a serial number and other identifying markings required by 27 CFR 478.92(a) and 479.102(a), provided all other requirements stated in this ruling have been met.

2009-2 - Installation of Drop In Replacement Parts (11.96 KB)

Licensing requirements under the GCA for any person who installs “drop in” replacement parts in or on existing, fully assembled firearms. A “drop in” replacement part is one that can be installed in or on an existing, fully assembled firearm without drilling, cutting, or machining. A replacement part, whether factory original or otherwise, has the same design, function, substantially the same dimensions, and does not otherwise affect the manner in which the weapon expels a projectile by the action of an explosive.

2009-1 - Firearms Manufacturing Activities-Camouflaging or Engraving Firearms (338.59 KB)

Licensing requirements under the GCA for persons engaging in the business, activity or process that primarily adds to or changes a firearm's appearance, by camouflaging a firearm by painting, dipping, or applying tape, or by engraving the external surface of a firearm.

2008-1 - Fabrique Nationale Herstal SA (FN) FNC Rifle (11.32 KB)

The upper assembly of the Fabrique Nationale Herstal SA (FN) FNC rifle is classified as the receiver of the firearm for purposes of the Gun Control Act, 18 U.S.C. Chapter 44, and the National Firearms Act, 26 U.S.C. Chapter 53.

2006-2 - Classification of Devices Exclusively Designed to Increase the Rate of Fire of a Semiautomatic Firearm (67.72 KB)

The NFA and GCA definition of machinegun includes a part or parts designed and intended for use in converting a weapon into a machinegun. This language includes a device that, when activated by a single pull of the trigger, initiates an automatic firing cycle that continues until the finger is released or the ammunition supply is exhausted.

2005-4 - A Ported Device Attached to the Barrel of a Paintball Gun (13.4 KB)

Certain integral devices intended to diminish the report of paintball guns are not “firearm silencers” or “firearm mufflers” under the Gun Control Act of 1968 or the National Firearms Act.

2004-5 - Minigun Ruling (12.41 KB)

The 7.62mm Aircraft Machine Gun, identified in the U.S. military inventory as the "M-134" (Army), "GAU-2B/A" (Air Force), and "GAU-17/A" (Navy), is a machinegun as defined by 26 U.S.C. 5845(b). Rev. Rul. 55-528 modified.

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