First ruling by ATF for 2015...

[Miketodd]

Looks like this could put the kabosh on 80% AR/AK lower build parties...

http://www.atf.gov/sites/default/fi...ling-2015-1-manufacturing-and-gunsmithing.pdf

And go!

 

[churchmouse]

If I read it right that will only effect 80% builds.....

 

[Miketodd]

Right, will correct my post.

 

[RobbyMaQ]

Is this specifying that one cannot take an 80% build to a gunsmith or machinist to use their equipment to mill it?
Or is this specifying that an individual may not do the milling themselves at all?
or both?

 

[churchmouse]

Is this specifying that one cannot take an 80% build to a gunsmith or machinist to use their equipment to mill it?
Or is this specifying that an individual may not do the milling themselves at all?
or both?

It is cloudy in its writing.....at least to me.

 

[Destro]

I read several things.

1, a person cannot complete enough work on an unmarked 80% receiver to make it a "firearm", then take that "firearm" to a FFL or business and have the rest of the work completed.

2, a "business" cannot do the machine work, or allow the customer to do the machine work, or use tools, etc. on their property without a manufacturing licnese and completing a 4473. The reciever will need to be marked if completed.

3, commerical "build parties" are a no go, regardless of the receiver, 80% or otherwise.

BATFE has had this position for awhile, they just now put it in writing.

 

[churchmouse]

I read several things.

1, a person cannot complete enough work on an unmarked 80% receiver to make it a "firearm", then take that "firearm" to a FFL or business and have the rest of the work completed.

2, a "business" cannot do the machine work, or allow the customer to do the machine work, or use tools, etc. on their property without a manufacturing licnese and completing a 4473. The reciever will need to be marked if completed.

3, commerical "build parties" are a no go, regardless of the receiver, 80% or otherwise.

BATFE has had this position for awhile, they just now put it in writing.

Thanks. Clears it up a bit.

 

[CathyInBlue]

Unaddressed is the individual hobbyist maker who does not request or receive emolument or consideration for the use of his non-business machine shop. If anyone wants to have a AR/AK build party at their house, in their garage, using their personal tools which are not used for business purposes, then this rule means nothing.

Build party ahoy! Of course, each person must do all of the work on their own firearm build themselves. That hasn't changed, but the crop of tools on which they are permitted to do this machining work has just shrunk to exclude all machines and tooling owned by a business, group, or other entity which makes money using those machines and tooling in normal operation. Now, only machines and tooling owned individually are available to 80% lower finishers.

What it does do is neuter gun trusts who might want to set up a jointly owned machine shop for the purpose of members of the trust doing their own gunsmithing, including manufacture of personal firearms from blanks/80% receivers on tooling that they own in trust, rather than individually.

 

[Destro]

What it does do is neuter gun trusts who might want to set up a jointly owned machine shop for the purpose of members of the trust doing their own gunsmithing, including manufacture of personal firearms from blanks/80% receivers on tooling that they own in trust, rather than individually.

I read it that the "trust" must be an FFL

A business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements under the GCA simply by allowing individuals to initiate or manipulate a CNC machine, or to use machinery, tools, or equipment under its dominion or control to perform manufacturing processes on blanks, unfinished frames or receivers, or incomplete weapons.

 

[CathyInBlue]

I read it that the "trust" must be an FFL

A business (including an association or society) may not avoid the manufacturing license, marking, and recordkeeping requirements under the GCA simply by allowing individuals to initiate or manipulate a CNC machine, or to use machinery, tools, or equipment under its dominion or control to perform manufacturing processes on blanks, unfinished frames or receivers, or incomplete weapons.

Exactly. They're neutered. As would be any other association (so much for freedom of association) who wanted to pool their individual resources to buy a single instance of expensive machine tools for the use of all of the members of the association (or society or trust or…).

 

[Destro]

Exactly. They're neutered. As would be any other association (so much for freedom of association) who wanted to pool their individual resources to buy a single instance of expensive machine tools for the use of all of the members of the association (or society or trust or…).

Well i belive that is still perfectly legal...as long as your not using with firearms

 

[CathyInBlue]

That's what Rule 2015-1 is all about. Person A using machine tool M owned by person X to "manufacture" firearm F. If A=X and both are not businesses, trusts, associations, etc., etc., all is well. If X is a business, trust, association, etc., etc., then the BATFE has their knickers in a twist.

 

[Miketodd]

^^^I read anopinionon a nfa bgroup that if a person is using someone elses tools, even if the tool owner is not a business, since the tool owner is involved in the process with their tools or knowledge, they are becomming an unlicensed manufacturer.

 

[Hkindiana]

So, if I lend a hand drill to a buddy, and he uses it to complete an 80% receiver, then I am now a manufacturer because my tool was used?

 

[Miketodd]

Would you really use a hand drill to complete an 80% lower? I think this ruling is BS. But your average joe doesn't own a drill press or cnc machine.

 

[Destro]

So, if I lend a hand drill to a buddy, and he uses it to complete an 80% receiver, then I am now a manufacturer because my tool was used?

if he borrows it from you and does the work at his house, then no.

 

[RobbyMaQ]

What of businesses who rent cnc machines/Tools? They'll need a disclaimer sheet stating you won't produce firearms with their equipment?

 

[mbills2223]

It is cloudy in its writing.....at least to me.

typical

 

[Destro]

What of businesses who rent cnc machines/Tools? They'll need a disclaimer sheet stating you won't produce firearms with their equipment?

Well if your renting it and taking it home, then you would be good to go. Can you rent a CNC machine like a carpet cleaner?


Basically they are going after Jim Fuller

 

[ModernGunner]

More stupidity from the BATFE? Gee, who woulda thunk?