Do I need to be licensed as a manufacturer if I acquire used firearms on which I will perform a manufacturing process (e.g. cerakote) for subsequent sale or distribution?

Yes. The final rule amended the definition “engaged in the business” as it relates  to a ‘‘gunsmith’’ in 478.11 to mean, in part a person who, as a service performed on existing firearms not for sale or distribution, devotes time,  attention, and labor to repairing or customizing firearms, making or fitting special barrels, stocks, or trigger mechanisms to firearms, or placing marks of identification on privately made firearms in accordance with this part, as a regular course of trade or business with the principal objective of livelihood and profit but shall not include a person who manufactures firearms (i.e., frames or receivers or complete weapons) by completion, assembly, or applying coatings, or otherwise making them suitable for use, requiring a license as a manufacturer.  

Last Reviewed July 22, 2022