WASHINGTON — The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF) today announced a ruling that will affect any person licensed as a dealer-gunsmith performing certain processing or finishing on firearms owned and marked by a federally licensed firearms manufacturer. The ruling will also affect licensed manufacturers and licensed importers who have contracts with specialized gunsmiths to perform a variety of processes involved in producing firearms.
The ruling holds that licensed firearms dealer-gunsmiths are not engaged in a manufacturing business, and are not required to hold a manufacturers license, under certain specified conditions. The ruling was issued to address modern firearms manufacturing processes, which often involve a number of contractors other than the manufacturer whose name is marked on the firearm.
Under the ruling, licensed dealers may perform manufacturing services if (1) the firearms are not owned by the licensed dealer-gunsmith; (2) the licensed dealer-gunsmith returns the firearms to the licensed manufacturer or licensed importer upon completion of the manufacturing process and does not sell or distribute the firearms to any other person; and (3) the firearms were properly identified and marked by the importer or manufacturer in accordance with the law and regulations.
ATF Ruling 2010-10 clarifies concerns and addresses questions about activities such as bluing, anodizing, powder-coating, plating, polishing, heat and chemical treating that have caused confusion over activities requiring a federal firearms manufacturers license, firearms marking requirements, and firearms record keeping requirements.
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